In 2008, a collaboration of businesses and environmental organizations released the visionary BizNGO Principles for Safer Chemicals:

1. Know and Disclose Product Chemistry
2. Assess & Avoid Hazards
3. Commit to Continuous Improvement
4. Support Public Policies & Industry Standards

The question of how to implement these Principles is the inspiration for the just released BizNGO Guide to Safer Chemicals (aka “The Guide”). Many a “downstream user” of chemicals, those organizations that use chemicals by virtue of the products they purchase, have stumbled on the path to developing and implementing a chemicals management program.

The Guide is a how-to resource for managing chemicals in products, processes, and feedstocks for downstream users of chemicals. This practical, easy-to-use guide is intended to revolutionize the way companies are able to move away from hazardous chemicals and replace them with safer alternatives. It is a resource of current and best practices of how organizations are implementing programs that advance safer alternatives to chemicals of high concern to human health or the environment  Today’s business leaders recognize that comprehensive programs for safer chemicals are essential to innovation, informed decisions, and clear communication with suppliers.

Every week new scientific research links exposure to chemicals of high concern in products to the increasing incidence of serious chronic health problems, including asthma, childhood cancers, infertility and learning and developmental disabilities. The uncertainty surrounding the safety of chemicals is eroding consumer confidence in a wide range of products.

The Guide uses a hiking metaphor of four benchmarks—Trailhead, Base Camp, High Camp, and Summit—for the journey to implementing the BizNGO Principles for Safer Chemicals. The benchmarks are relative indicators of performance, not absolutes. The benchmarks increase in complexity and difficulty as they move upwards from Trailhead, actions commonly taken by organizations first moving beyond compliance, to summit, actions taken by only a few.

Principle #1a—Know Chemicals across the Life Cycle of Products (business-to-business sharing of information)

Knowing the chemicals in products, manufacturing processes, and feedstocks is foundational to advancing safer chemicals in products and supply chains. The Guide provides many examples of the steps organizations are taking to knowing chemicals across the supply chain. Seagate, for example, runs a comprehensive program to collect from its suppliers full chemical and material ingredients of all the components in its hard drives.

Principle #1b—Disclose Chemicals across the Life Cycle of Products (sharing of information to the public)

Chemical ingredient transparency, sharing chemical information to the public, is an essential component of innovation, clear communication to customers, and informed decisions for many business leaders. For example, Whole Foods Market’s Eco-Scale Rating for household cleaning products requires full ingredient disclosure on the label. And the just released Health Product Declaration (HPD) form sets a new standard for disclosure in the building products sector.

Principle #2—Assess & Avoid Hazards

A critical element in the implementation of a safer alternatives program is the frameworks and tools that organizations use to inform their identification of chemicals of high concern, evaluation of alternatives, and the selection and implementation of safer alternatives. HP, for example, is implementing a systematic process for evaluating chemicals of high concern, using an “Integrated Alternatives Assessment” with hazard assessment completed using the GreenScreen. And Nike’s approach to chemicals management includes evaluating the chemical inputs into its materials, specifying preferred chemistries and materials, and conveying these metrics to its suppliers along with other opportunities for greening their chemistries.

Principle #3—Commit to Continuous Improvement

Downstream users of chemicals lack clear, standardized metrics for evaluating progress to safer chemicals. There is no standardized “chemical footprint” tool like the carbon footprint metric for energy use. In fact, the The Guide’s benchmarks for Principles #1 and #2 are the closest to a standardized metric for a chemical footprint that we have. Dignity Health’s pilot of a beta version demonstrates how an organization can use The Guide to evaluate its progress on the paths to safer chemicals.

Principle #4—Support Public Policies and Voluntary Initiatives

The active participation of businesses and health care organizations, among others, is necessary for the successful integration of the Principles and The Guide’s benchmarks into public policies and voluntary initiatives. The collective voice of downstream users engaging in public and private spaces is critical for growing the global movement to safer alternatives to chemicals of high concern to human health and the environment. Ultimately corporate leaders will only succeed if their efforts are mainstreamed globally.

The Guide is a living resource and will evolve as we learn more about how organizations are implementing the BizNGO Principles. Please share your thoughts and work as you advance up the paths to safer chemicals.

Opponents to California Safer Consumer Product Regulations are ramping up pressure on Governor Brown to delay finalization of the regulations. Recently they rallied 16 California legislators to send a letter to Governor Brown requesting a delay in implementation. Yesterday an arm of the California Chamber of Commerce, the California Foundation for Commerce & Education, released a report arguing that the California Department of Toxic Substances Control (DTSC) “has failed to meet its obligations to provide a meaningful economic analysis” of the regulations as required by the Administrative Procedure Act.

Originally the Safer Consumer Product regulations were to be completed by December 31, 2010. Now two years late, opponents are pressing for further delay in the regulations.

Meanwhile Maine is already implementing its Safer Chemicals in Children’s Products program, which includes alternative assessments to chemicals of concern. The U.S. Environmental Protection Agency is cranking out alternatives assessments to chemicals of concern, including BPA, NPEs, and certain flame retardants and phthalates. And Washington State Department of Ecology is developing guidance to help business and industry identify safer alternatives to toxic chemicals.

Legislators already passed AB 1879 (the law behind the Safer Consumer Product Regulations) in 2008, it’s time for California to finalize the Safer Consumer Product regulations.

BizNGO  sent our concise chemicals policy reform notes to Congressional staff and reporters. It details how very busy BizNGO has been the last few weeks leading up to the House Bill drop sometime this month.

Biz NGO member, Howard Williams of Construction Specialties, nicely summarizes why the building industry needs full information on chemical ingredients in the supply chain.   His blog in The Hill outlines that legislation can be written in a way to protect confidential business information, yet provide critical information on chemical content across the business supply chain.   Similarly, Pat Beattie in the Huffington Post Op Ed writes about why the traditional MSDS sheets (Material Safety Data Sheets) are a flawed system of chemical information for product manufacturers and consumers and why B2B chemical ingredient information exchange would be far superior.  This lack of chemical ingredient information effectively turns companies into ‘chemical detectives’ as the Biz NGO Chair, Mark Rossi, writes in an article for the Safer Chemicals Healthy Families campaign.

We wait with expectation to see if the House Bill incorporates the three measures our BizNGO participants have identified that would address the need for greater transparency:

1) A requirement to disclose chemical ingredients across the supply chain (with confidential business information protections);
2) A provision to allow the Environmental Protection Agency (EPA) to collect chemical use data as needed for safety determinations; and
3) A minimum requirement to provide consumers with information on chemicals of high concern in products.

The benefits of more chemical ingredient disclosure from the chemical industry for their buyers down the supply chain and ultimately for consumers cannot be argued particularly from an economic point of view.  The multi billion dollar health care industry alone is a case in point.  Rachelle Wenger of Catholic Health Care West with its $9 billion in annual revenue and the largest health care provide in California points out that “If chemicals reform reduced toxic chemical exposures that translated into just a tenth of one percent reduction in health care costs, it would save the U.S. health care system an estimated $5 billion every year.”   Similarly Kathy Gerwig of Kaiser Permanente, the nation’s largest integrated health care delivery program with $40 billion in annual revenues states that “It is very time consuming to develop a list of chemicals of high concern, determine which products they are in, identify alternatives and evaluate their safety, performance and cost. ..  “We would benefit from public policy that requires manufacturers to ensure adequate safety testing of chemicals in their products and make that data available for review.”

Perkins+Will, the 3rd largest architectural firm globally and another member of BizNGO adds another perspective.  As Robin Guenther explains  “Amazingly, it’s hard to fathom that as architects we don’t always know what chemicals are in the building materials we use. It’s time for this to change. It’s time to bring a new set of baseline criteria to building design and construction by starting with the elimination of toxic chemicals in building materials.”  Her perspective made me ponder how well the LEED accreditation system deals with chemicals in building products particularly as, she points out, manufacturers of building materials, furniture and equipment still face no requirement to disclose all of the substances present in their manufactured items.

It is hard to get one’s head around the fact that we are living in a world of untested chemicals.   But there is a clear reason why we are in this state of ignorance.  When the Toxic Substance Control Act was established in 1976 there were over 60,000 chemicals in commerce with no requirement for any assessment of their health and environmental impact.  Since then the EPA has requested data on only 200 of these chemicals.   Because the public erroneously believes that the government MUST have laws in place to check for product safety or that manufacturers MUST be testing all the products they sale, this state of affairs has been perpetuated for 34 years.  The latest President’s Cancer Panel declared the Toxic Substances Control Act (TSCA) of 1976 as the “most egregious example of ineffective regulation of environmental chemicals.” Why?  The Panel goes on to observe that “because companies are required by TSCA to report information about known health hazards caused by any of their products, to avoid litigation or the costly ban or restricted use of a product, chemical companies generally do not conduct toxicity tests. Under TSCA, EPA can only require testing if it can verify that the chemical poses a health risk to the public.  Since TSCA was passed, EPA has required testing of less than 1 percent of the chemicals in commerce and has issued regulations to control only five existing chemicals. Companies are required to provide health and safety data for new chemicals and to periodically renew approvals for the use of pesticides, but historically, chemical manufacturers have successfully claimed that much of the requested submissions are confidential, proprietary information. As a result, it is almost impossible for scientists and environmentalists to challenge the release of new chemicals.”

So there you have it in a nutshell.   And that is why BizNGO is focusing on the need for transparency of chemical ingredient disclosure through the supply chain so that we can begin to leave a better business model built on common sense and accountable for the world we will pass on to our children.