panel session: retailer "sustainability" initiatives - a background and discussion of...

Leading Canadian Trade Association for the Personal Care Products Industry

© Copyright 2014 (all rights reserved)

Retailer ‘Product Sustainability’ InitiativesA Discussion of Potential Implications for

Consumer Product Regulation

A Science Perspective

CHP Canada/CCTFA Health & Beauty Conference 2014

JW Marriott The Rosseau Muskoka ResortSeptember 19, 2014


Disclaimer

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All information shared during this presentation are the expressed opinions of the presenter and all related presentation materials are the property of the Canadian Cosmetic, Toiletry and Fragrance Association (CCTFA). This information is shared for the purpose of this specific speaking engagement and should not be made public or circulated without prior approval and written consent from the presenter and the CCTFA. Information as presented should not be relied upon as legal advice and companies are advised to consult with legal counsel to verify the relevance and applicability of any information provided.


Outline

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Ingredient campaigns under the “sustainability” umbrella –‘Let’s call a spade a spade’

The ‘real’ picture – why the sole focus on personal care?

The quest for ‘green’ – not necessarily safer

Undermining sound scientific regulatory decision‐making –the Canadian CMP at risk


What’s In a Word?

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‘Product Sustainability’ Fiction

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Beauty and Personal Care Products Sustainability Summit

Reality…

Ingredient campaigns hiding under the ‘product sustainability’ umbrella

Not at all about sustainability performance, rather largely about managing so called ‘toxics’(the pressure group agenda)

“To improve sustainability performance in the personal care and beauty industry”

Forum for the Future (2014)


‘Product Sustainability’ Fiction [cont.]

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“CALLING A SPADE A SPADE”

If these initiatives are really about “sustainability”‒ Carbon footprint‒ Energy management‒ Ethical sourcing ‒ Sustainable development‒ Resource conservation‒ Waste management‒ etc.

In addition to…Substance/Product stewardship

(green chemistry)


‘Product Sustainability’ Fiction [cont.]

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Substance/product stewardship and the management of ‘toxics’ should be one, relatively small component to an overall “sustainability” (environmental) model

Sound management of chemicals and responsible product stewardship are integral to the personal care business (producing a ‘toxic’ product would not be in the interest of industry)

If one wanted to make a “sustainable” difference; focus should perhaps be on other facets

Well intentioned, but misguided focus


‘Sustainable Product’ Standard†

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Criteria Points Scoring DeterminantsIngredients 50 ‐ 0 points (one or more ingredients on designated hazards lists*)

‐ Max. of 25 points (no ingredients on hazards list but ‘high’ generic hazards [e.g. Fragrance, etc.])

‐ Max. of 40 points (no ingredients on hazards list but ‘low’ generic hazards [e.g. enzyme, etc.])

‐ 50 points (no ingredients on designated lists and no generic ingredients)

Transparency 20 ‐ 20 points (if complete list of ingredients are available on pack and/or website; purposes of ingredients are provided; no generic ingredients)

Animal Testing 5 ‐ 5 points (third‐party certification prohibiting animal testing in development or production)

Packaging 20 ‐ 20 points (recyclable by a ‘substantial majority’ of consumers; primary packaging is comprised at least of 25 – 35% of post‐consumer and/or post‐industrial materials; includes how 2 recycle labelling on pack)

Water Quality 5 ‐ 5 points (no ingredients considered to be hazardous to aquatic environment**)

* Prop 65; ECHA SVHCs; EU Endocrine Priority List; US EPA PBTs; Chemicals of High Concern to Children, Washington Department of Ecology)** ECHA GHS (acute/chronic hazards)

† Powered by Underwriters Laboratories (UL) Good Guide™ Purview Platform [TARGET’s MODEL]

Hum

an Health

Environment &

Comm

unity


‘Sustainable Product’ Standard [cont.]

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75 – 80% of the score is focused on ingredient management

Is this an appropriate weighting?

Other key ‘environmental sustainability’ parameters missing (carbon footprint, resource management, etc.)

Reality…

Ingredient campaigns hiding under the ‘sustainability’ umbrella

Not at all about sustainability performance, rather largely about managing so called ‘toxics’(the pressure group agenda)


The ‘Real’ Picture in Perspective

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‘Sustainable Product Standard’

We took it for a TEST DRIVE


The ‘Real’ Picture in Perspective [cont.]

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Product ‘A’Aqua, sugars (fructose, glucose, sucrose), fibre, glutamic acid, aspartic acid, leucine, arginine, alanine, valine, glycine, proline, isoleucine, serine, threonine, phenylalanine, lysine, methionine, tyrosine, histidine, cystine, tryptophan, linoleic acid, linolenic acid, oleic acid, palmitic acid, stearic acid, palmitoleic acid, ash, phytosterols, oxalic acid, ascorbic acid, tocopherols, thiamin, anthocyanins, ethyl ethanoate, 2‐methyl butyraldehyde, pentanal, methylbutyrate, octene, hexanal, decanal, 3‐carene, limonene, styrene, nonane, ethyl‐3‐methylbutanoate, hydroxylinalool, linalool, terpinyl acetate, caryophyllene, alpha‐terpineol, alpha‐terpinene, 1,8‐cineole, citral, benzaldehyde, benzene‐1,4‐diol, methylparaben, ethanol, pectins, mannitol, and ‘fresh air’ (nitrogen, oxygen, carbon dioxide)



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Product ‘A’Aqua, sugars (fructose, glucose, sucrose), fibre, glutamic acid, aspartic acid, leucine, arginine, alanine, valine, glycine, proline, isoleucine, serine, threonine, phenylalanine, lysine, methionine, tyrosine, histidine, cystine, tryptophan, linoleic acid, linolenic acid, oleic acid, palmitic acid, stearic acid, palmitoleic acid, ash, phytosterols, oxalic acid, ascorbic acid, tocopherols, thiamin, anthocyanins, ethyl ethanoate, 2‐methyl butyraldehyde, pentanal, methylbutyrate, octene, hexanal, decanal, 3‐carene, limonene, styrene, nonane, ethyl‐3‐methylbutanoate, hydroxylinalool, linalool, terpinyl acetate, caryophyllene, alpha‐terpineol, alpha‐terpinene, 1,8‐cineole, citral, benzaldehyde, benzene‐1,4‐diol, methylparaben, ethanol, pectins, mannitol, and ‘fresh air’ (nitrogen, oxygen, carbon dioxide)

SCORE = 5 – 10/100



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Product ‘B’Aqua, sodium, magnesium, potassium, acetaldehyde, acrylamide, benzaldehyde, benzene, benzofuran, benzo(a)pyrene, caffeic acid, chlorogenic acids, catechol, benzyl acetate, 1,2,5,6‐dibenanthracene, ethanol, ethylbenzene, formaldehyde, furan, furfural, hydrogen perioxide, benzene‐1,4‐diol, limonene, styrene, toluene, phenols, 4‐methylimidazole, quinic acid, cafestol, kahweol, n‐methylpyridinium, + many more (1,000+) substances



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Product ‘B’Aqua, sodium, magnesium, potassium, acetaldehyde, acrylamide, benzaldehyde, benzene, benzofuran, benzo(a)pyrene, caffeic acid, chlorogenic acids, catechol, benzyl acetate, 1,2,5,6‐dibenanthracene, ethanol, ethylbenzene, formaldehyde, furan, furfural, hydrogen perioxide, benzene‐1,4‐diol, limonene, styrene, toluene, phenols, 4‐methylimidazole, quinic acid, cafestol, kahweol, n‐methylpyridinium, + many more (1,000+) substances

SCORE = 0 – 25/100



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SCORES = 0 – 25/100

PRODUCT ‘A’ PRODUCT ‘B’

All ‘Natural’ Blueberries Cup of Java



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naphthalene

acenaphthylene

acenaphthenefluoranthene

fluorene

pyrene

anthracene

benzo[a]anthracene

chrysene

benzo[b]fluoranthenebenzo[k]fluoranthene

benzo[a]pyrene

Dibenz(a,h)anthracene

Benzo[g,h,i]perylene

Indeno[1,2,3-c,d]pyrene

Polyaromatic Hydrocarbons (PAHs)

Household Generator



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WHY ARE THEY LIMITED TO PERSONAL CARE?(singling out)

If such initiatives are truly about‘product sustainability’


Green Overboard – More ‘Real’ Perspective

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‘GOING GREEN’ = Natural

curare tetrodotoxin digitalis

SAFER???



Slide 19

Titanium Dioxide (TiO2)

IARC 2B (possibly carcinogenic to humans)

Proposition 65 List

Mineral sunscreen ingredient

Ingredient and transparency criteria (products developed with human health in mind)

BEGS THE QUESTION

HOW APPROPRIATE and/or PRACTICAL IS THE‘PRODUCT SUSTAINABILITY’ STANDARD?


Hazard vs. Risk

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Science‐Based Regulatory Decision Making

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Chemical Management in Canada

Chemical Management Plan (CMP)

Comprehensive assessment of existing substances in Canadian commerce

Comprehensive program to manage the introduction of new substances to Canadian commerce

Science‐ and risk‐based approach

Independent arbitrator(Environment/Health Canada)


Science‐Based Regulatory Decision Making [cont.]

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Retailer ‘Product Sustainability’ Initiatives

Undermines the science‐ and risk‐based approach implemented by Government of Canada

Undermines the credibility of one of the world‐leading chemical management programs

Forced substitution strategies that do not necessarily lead to safer more ‘sustainable’ products

Is this really what we want? Need?

Is this really what the consumers want? Need?

Segmentation (does it make sense to focus solely on personal care)?


Science‐Based Regulatory Decision Making [cont.]

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Retailer ‘Product Sustainability’ Initiatives

RETAILERS

IMPACT on private label (house brands)???


‘Product Sustainability’ – Moving Forward

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OPPORTUNITY FOR ENGAGEMENT

Industry does not object to sustainability initiatives

In fact, sustainability and environmental and social responsibility are fundamental tenets of the CCTFA’s strategic plan

‒ Appropriately focused

‒ Designed to address more appropriate ‘sustainability’ endpoints

‒ Not centred around an unfounded/unsupported ‘toxics’ model that ultimately does not deliver ‘greener’ or ‘safer’ products

How can we collaborate with retailers to deliver meaningful sustainability solutions that truly make an impact on society (while respecting science and the sound management of chemicals)?


Closing Thoughts

Slide 25

SILOXANES (D5)Board of Review

‘TOXIC TEN’

‘DIRTY DOZEN’

‘MEAN FIFTEEN’

Minister of Environment Adopts ConclusionsIndependent Panel of International Renown Toxicologists

Siloxane D5 does not pose a danger to human health or the environment


Challenge Moving Forward

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Thank You

Retailer ‘Product Sustainability’ Initiatives: A Discussion of Potential Implications for

Consumer Product Regulation A Science Perspective

Beta MontemayorCanadian Cosmetic, Toiletry and Fragrance Association (CCTFA)

[email protected](905) 890‐5161 ext. 239

CHP Canada/CCTFA Health & Beauty Conference 2014(September 19, 2014)

mailto:[email protected]