,,,,my major criticism of EPA is that the Agency is divided into separate sections on waste, water, air and the like. These groups are so isolated in regard to their objectives and disciplines that communication between them is compromised. And they compete for funding, public outreach and other objectives.

 

A quick way to illustrate this is to look at the EPA program called Design for the Environment which has a "Safer Product Labeling Program" (http://www.epa.gov/dfe/saferingredients.htm#about). On this site, there are lists of chemicals that can be given one of these coveted labels. If you click on the list of "solvents," the first product on the list is citrus oil. While the label is the triangular yellow label that indicates there are "health concerns," the label indicates it is one of the "Safer Chemical Ingredients." People do not think past this wording. If they did they would learn that this chemical is also an EPA-registered pesticide, a sensitizer, and vastly more toxic by inhalation than any of the other solvents on the list. While there is no US workplace air quality standards for it at present (there were in the past) the German MAK is 5 parts per million--indicating how highly toxic it is by inhalation.

 

Even more interesting, four EPA employees did a study published in 2004 showing that the vapor of the major ingredient in citrus oil (d-limonene) reacts with pollution-levels of ozone to create formaldehyde(1). The level of formaldehyde in a home can actually increase if citrus oil products are used. But since that is an air quality issue, the section of EPA attempting to promote these green or biodegradable chemicals incorrectly lists citrus oil as "safer" and does not take into account the formaldehyde-generation exposure issue for consumers in their homes or any of the other toxicity issues for users.

 

I expect no common sense recommendations for consumers from EPA as long as these separations in objectives exist within the Agency and as long as each branch is selling their ideas to the public with misleading words like "safe."

 

       1. Environmental Science & Technology, published on line, doi:10.1021/es030544b, (2004) 

        Note: I should  look up it's final published citation. Haven't yet.

 

The answer to this, in my opinion, is what I try explain this problem as I do in my training lectures. I separate the objectives of biodegradability, user safety, air quality, and water quality. In fact, I explain the tests used to identify chemicals that meet these various objectives and to illustrate how a chemical found perfectly "safe" under one criterion set can be deadly under another. People need to know this is a complex issue and there is no "safe" chemical that meets all objectives.

 

Then I believe we need to prioritize. The first objective is to keep the user safe. The secondary strategy for protecting the environment is using less and finding projects and ways to express ourselves that don't require toxic chemicals. The third is demanding that manufacturers actually test their chemicals for chronic toxicity before including them in consumer products. Without this toxicity data, there are no additional rational steps to take.

Monona Rossol, M.S., M.F.A., Industrial Hygienist

President:  Arts, Crafts & Theater Safety, Inc.

Safety Officer: Local USA829, IATSE

181 Thompson St., #23

New York, NY 10012     212-777-0062

actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org

 

Subject: EPA to Expand Listing on the DfE Safer Chemical Ingredients List Date: Thu, 4 Dec 2014 15:49:41 -0600 From: oppt.epa**At_Symbol_Here**public.govdelivery.com  The EPA Office of Chemical Safety and Pollution Prevention (OCSPP) is announcing  an initiative to expand the Design for the Environment (DfE) Safer Chemical  Ingredients List (SCIL) with chemicals in new and existing functional component  classes.  We are inviting chemical manufacturers to submit information on their  safer chemicals to EPA for review and listing on the SCIL. Adding more chemicals  to the SCIL should foster innovation and growth in safer products, increase  markets for business, and help protect people and the environment.   The SCIL contains chemicals that meet DfE's rigorous safer chemical criteria and  are eligible for use in the DfE Safer Product Labelling program. To date,  SCIL-listed chemicals have been primarily used in cleaning and detergent  products. The SCIL currently contains chemicals from the ingredient classes  typically found in cleaners and detergents (surfactants, solvents, chelants,  colorants, etc.)..  Numbering over 650 discrete substances, SCIL chemicals have  played an important role in enhancing the transparency of and increasing  participation in the Safer Product Labeling Program.  Product manufacturers and  many others use the SCIL as they develop or enhance formulations to earn the DfE  Safer Product Label, qualify for retailer sustainability programs, meet company  innovation goals, or learn more about the ingredients used to make safer  products. Retailers have used the Safer Product Label to qualify products for  their sustainability programs.  Today's announcement opens the door for the expansion of safer chemicals and  functional-use classes on the SCIL.  EPA has posted a "Steps to SCIL Listing"  document on the web (at www.epa.gov/dfe/howtoscil) to guide chemical  manufacturers through the process.  The Agency is asking manufacturers with  candidate chemicals to work with a DfE-qualified third party to prepare a  profile on the chemical, based on the program's safer chemical criteria.  EPA  will use the profile and Agency criteria and expertise to make the listing  decision.  The presence of safer chemicals in new component classes, and with  new functionalities, on SCIL will create opportunities to label and promote new  types of safer products, potentially bringing the benefits of the Safer Product  Label to new markets and populations of workers and consumers.