CSPA opposes penalties for ingredient disclosure requirements. However, CSPA and our members strongly support an appropriate approach to providing accurate ingredient information to consumers. Our industry stands behind the safety of our products and the appropriate use of chemical ingredients in those products. We would like to work with DTSC and the State of California to implement a means of ingredient communication that would provide consumers with the information they can use to make informed decisions regarding the products they use in their homes.
As you know, CSPA and the Soap and Detergent Association (SDA) are currently working with Senator Simitian (D-Palo Alto) on Senate Bill 509 to develop a legislative proposal (for our product categories) that provides meaningful ingredient communication information to consumers, while also protecting proprietary business information. We look forward to continuing to work with DTSC on this initiative as it moves forward in the legislature.
The Soap and Detergent Association (SDA) and its members are strongly committed to ensuring that product labels clearly and plainly communicate the most critical information for the consumer – the product’s safety and usage information. Our members comply with California’s Proposition 65 as well as Federal regulations that require ingredients that contribute substantially to a product’s hazards to be stated on their product labels.
We are aware of legislation under consideration in California (SB 509) that would require all ingredients present in consumer products in concentration greater than 0.1% be listed on manufacturer websites. Our members are receptive to the goal of communicating with consumers about ingredients in their products and SDA is working with the sponsor of SB 509 to develop a meaningful program for ingredient disclosure.
A workable ingredient communication program should include ingredient chemical names while providing flexibility as to the naming system and the media that are used for listing these ingredients. Any system for the disclosure of ingredients must to be sensitive to the manufacturers’ need to protect their proprietary information. The ability to protect such information is critical to fostering the kind of innovation which has been the hallmark of our industry – innovation that improves the safety, effectiveness and convenience provided by the products and reduces environmental impacts.
The WERCS has been collecting ingredient information on new chemical products for the past 22 months for a large retailer. We are working with suppliers and other retailers to share regulatory and sustainability information through an internet data pool process (Global Data Synchronization Network) which is designed to ensure the confidentiality of supplier’s formula information. This chemical information may then be used by retail buyers to screen for products which meet or exceed regulatory or company-specific health or environmental goals. The WERCS has designed a screening tool which uses this chemical information to assist buyers with selecting products which minimize the environmental impact of product use or disposal. Full disclosure of product chemical ingredients is crucial for the success of these types of programs.
This question seems to assume that it is appropriate to generally demand disclosure of product ingredients without safeguards. It is important to bear in mind that protecting proprietary information is a strong market-driver that fosters continuous innovation toward safer, more cost-effective ingredients and products. Failing to address these considerations in a disclosure program could be counterproductive and lead to less innovation, rather than more.
GMA opposes the use of penalties for ingredient disclosure. GMA strongly supports a collaborative approach to providing accurate ingredient information to consumers through ingredient communication. Manufacturers have programs to respond to the information requests and needs of consumers through, for example, toll-free numbers and e-mails. We are always looking for better ways to improve ingredient communication. GMA would like to work with California to implement a means of ingredient communication that would provide consumers with the information they can use to make even better informed decisions regarding the products they use in their homes.
This question seems to assume that it is appropriate to generally demand disclosure of product ingredients without safeguards. It is important to bear in mind that protecting proprietary information is a strong market-driver that fosters continuous innovation toward safer, more cost-effective ingredients and products. Failing to address these considerations in a disclosure program could be counterproductive and lead to less innovation, rather than more.
GMA opposes the use of penalties for ingredient disclosure. GMA strongly supports a collaborative approach to providing accurate ingredient information to consumers through ingredient communication. Manufacturers have programs to respond to the information requests and needs of consumers through, for example, toll-free numbers and e-mails. We are always looking for better ways to improve ingredient communication. GMA would like to work with California to implement a means of ingredient communication that would provide consumers with the information they can use to make even better informed decisions regarding the products they use in their homes.
The only ingredients of importance in disclosure are the ones that pose a significant risk to the environment or human health. The OSHA system imparts the necessary information. Similar requirements for consumer products would be appropriate. Anything beyond that would compromise proprietary technology and would not provide additional benefit.
If specific chemical names are not disclosed due to trade secret information, the risk profile of the chemical could be provided depending on the hazard class and the use threshold. Product ingredients must have a minimal level at which no disclosure is required in line with scientific dose response relationships. Failure to disclose information could have penalties that are weighted to the calculated risk of major environmental or health hazards that would result.
The disclosure of product ingredients to the state of California requires careful safeguards to industry and should only involve known hazardous ingredients. This is already addressed by Proposition 65 regulation. Levying of penalties for failure to dislose all ingredients (hazardous or not) appears to be beyond the scope of this Green Chemistry initiative and would involve unnessessary legilative overlap into Prop. 65.
The state must combine protection of intellectual property and the protection of human, animal and ecological health. Ingredient levels must be required for substances proven to have hazardous effects. The phases os matter and sizes also matter increasingly. Nanoparticles may have multiple paths into the human body. However, protection of intellectual property is essential to drive economy and keep manufacturing jobs, which generate tax revenue for the state. The state must take care to not compromise on either front, business health or human health..
The requirement to disclose product ingredients, including inert or inactive ingredients, to the public should be a critical element of the mandatory data requirements. Without this information, downstream users as well as consumers are blind to potential hazards. As such, providing this information should be mandatory condition for a product to remain on or be introduced into the market. The market, public and government will remain unable to protect the public health and environment or choose safer alternatives without this information.
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Reader Comments (10)
CSPA opposes penalties for ingredient disclosure requirements. However, CSPA and our members strongly support an appropriate approach to providing accurate ingredient information to consumers. Our industry stands behind the safety of our products and the appropriate use of chemical ingredients in those products. We would like to work with DTSC and the State of California to implement a means of ingredient communication that would provide consumers with the information they can use to make informed decisions regarding the products they use in their homes.
As you know, CSPA and the Soap and Detergent Association (SDA) are currently working with Senator Simitian (D-Palo Alto) on Senate Bill 509 to develop a legislative proposal (for our product categories) that provides meaningful ingredient communication information to consumers, while also protecting proprietary business information. We look forward to continuing to work with DTSC on this initiative as it moves forward in the legislature.
The Soap and Detergent Association (SDA) and its members are strongly committed to ensuring that product labels clearly and plainly communicate the most critical information for the consumer – the product’s safety and usage information. Our members comply with California’s Proposition 65 as well as Federal regulations that require ingredients that contribute substantially to a product’s hazards to be stated on their product labels.
We are aware of legislation under consideration in California (SB 509) that would require all ingredients present in consumer products in concentration greater than 0.1% be listed on manufacturer websites. Our members are receptive to the goal of communicating with consumers about ingredients in their products and SDA is working with the sponsor of SB 509 to develop a meaningful program for ingredient disclosure.
A workable ingredient communication program should include ingredient chemical names while providing flexibility as to the naming system and the media that are used for listing these ingredients. Any system for the disclosure of ingredients must to be sensitive to the manufacturers’ need to protect their proprietary information. The ability to protect such information is critical to fostering the kind of innovation which has been the hallmark of our industry – innovation that improves the safety, effectiveness and convenience provided by the products and reduces environmental impacts.
The WERCS has been collecting ingredient information on new chemical products for the past 22 months for a large retailer. We are working with suppliers and other retailers to share regulatory and sustainability information through an internet data pool process (Global Data Synchronization Network) which is designed to ensure the confidentiality of supplier’s formula information. This chemical information may then be used by retail buyers to screen for products which meet or exceed regulatory or company-specific health or environmental goals. The WERCS has designed a screening tool which uses this chemical information to assist buyers with selecting products which minimize the environmental impact of product use or disposal. Full disclosure of product chemical ingredients is crucial for the success of these types of programs.
This question seems to assume that it is appropriate to generally demand disclosure of product ingredients without safeguards. It is important to bear in mind that protecting proprietary information is a strong market-driver that fosters continuous innovation toward safer, more cost-effective ingredients and products. Failing to address these considerations in a disclosure program could be counterproductive and lead to less innovation, rather than more.
GMA opposes the use of penalties for ingredient disclosure. GMA strongly supports a collaborative approach to providing accurate ingredient information to consumers through ingredient communication. Manufacturers have programs to respond to the information requests and needs of consumers through, for example, toll-free numbers and e-mails. We are always looking for better ways to improve ingredient communication. GMA would like to work with California to implement a means of ingredient communication that would provide consumers with the information they can use to make even better informed decisions regarding the products they use in their homes.
This question seems to assume that it is appropriate to generally demand disclosure of product ingredients without safeguards. It is important to bear in mind that protecting proprietary information is a strong market-driver that fosters continuous innovation toward safer, more cost-effective ingredients and products. Failing to address these considerations in a disclosure program could be counterproductive and lead to less innovation, rather than more.
GMA opposes the use of penalties for ingredient disclosure. GMA strongly supports a collaborative approach to providing accurate ingredient information to consumers through ingredient communication. Manufacturers have programs to respond to the information requests and needs of consumers through, for example, toll-free numbers and e-mails. We are always looking for better ways to improve ingredient communication. GMA would like to work with California to implement a means of ingredient communication that would provide consumers with the information they can use to make even better informed decisions regarding the products they use in their homes.
The only ingredients of importance in disclosure are the ones that pose a significant risk to the environment or human health. The OSHA system imparts the necessary information. Similar requirements for consumer products would be appropriate. Anything beyond that would compromise proprietary technology and would not provide additional benefit.
If specific chemical names are not disclosed due to trade secret information, the risk profile of the chemical could be provided depending on the hazard class and the use threshold. Product ingredients must have a minimal level at which no disclosure is required in line with scientific dose response relationships. Failure to disclose information could have penalties that are weighted to the calculated risk of major environmental or health hazards that would result.
The disclosure of product ingredients to the state of California requires careful safeguards to industry and should only involve known hazardous ingredients. This is already addressed by Proposition 65 regulation. Levying of penalties for failure to dislose all ingredients (hazardous or not) appears to be beyond the scope of this Green Chemistry initiative and would involve unnessessary legilative overlap into Prop. 65.
The state must combine protection of intellectual property and the protection of human, animal and ecological health. Ingredient levels must be required for substances proven to have hazardous effects. The phases os matter and sizes also matter increasingly. Nanoparticles may have multiple paths into the human body. However, protection of intellectual property is essential to drive economy and keep manufacturing jobs, which generate tax revenue for the state. The state must take care to not compromise on either front, business health or human health..
The requirement to disclose product ingredients, including inert or inactive ingredients, to the public should be a critical element of the mandatory data requirements. Without this information, downstream users as well as consumers are blind to potential hazards. As such, providing this information should be mandatory condition for a product to remain on or be introduced into the market. The market, public and government will remain unable to protect the public health and environment or choose safer alternatives without this information.