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Roadmap Categories and Benchmarks

The Health First Roadmap is intended to provide specific guidance to cleaning product companies on chemical screening and safety.

The roadmap outlines the key categories included in company chemical screening, and benchmarks from “compliance” to the “high road” the ways companies can make progress towards an approach that puts health first. 

HEALTH FIRST

Companies put human health and the environment first. The set of chemicals they allow in their products is very limited to only those that pose no potential health risks to consumers at any level, regardless of exposure pathways. They are transparent about their chemical screening efforts and criteria, and they lead collaborative efforts to move the cleaning products industry towards safer production.

DO NO HARM

Companies ensure that their products do not contain chemicals of concern to human health or the environment. They stay ahead of regulatory changes by prohibiting chemicals deemed hazardous by any jurisdiction in the world and those that consumers and NGOs are concerned about, regardless of levels or exposure pathways.

DO LESS HARM

Companies take action by prohibiting or restricting chemicals deemed hazardous by any jurisdiction in the world, including any chemical for which new regulations emerge. They seek to make these changes across all cleaning products, regardless of levels or exposure pathways.

COMPLIANCE

Companies take no additional action to restrict or prohibit chemicals of concern than is currently required by law. They continue to use chemicals deemed hazardous in other jurisdictions.


1. Chemicals Management

This section focuses on the corporate policies companies use to manage chemicals across all their brands, including goals for reducing chemicals of high concern, and whether progress has been made towards the meeting goals established in the policy.

A. Corporate Chemical Safety Policy

Company has a stated chemicals policy with goals for reducing chemicals of high concern and/or increasing the use of safer chemicals. Measuring a company’s use of chemicals of high concern in products and progress towards using safer alternatives. This includes participating in the Chemical Footprint Project (CFP) survey, and making the information public.

HEALTH FIRST

YES. Has done all of the following:

  • Issued a detailed written policy describing how company ensures thorough chemical safety evaluation, with measurable goals for reducing hazardous chemicals
  • Has a regularly updated restricted substances list (RSL).

DO NO HARM

YES. General policy statement with some detailed information on chemical safety goals.Uses template or follows guidance established by BizNGO Model Chemicals Policy for Brands and Manufacturers. Company may have completed CFP survey, but has not established specific goals for improvement.

DO LESS HARM

YES. General policy statement addressing its commitment to reduce its use of hazardous chemicals, with little or no further information on goals, strategies or practices.
Company has not completed CFP survey.

COMPLIANCE

Company has no written chemicals policy addressing its approach to reducing chemicals of high concern. Has not completed Chemical Footprint Project survey to assess its current approach to chemicals management or track current use of chemicals of high concern.

B. Commitment

Company has made progress on reducing or eliminating chemicals of high concern in products.

HEALTH FIRST

  • Company has made measurable progress towards reduction and/or elimination of chemicals of high concern as compared to the goals stated in its chemicals policy.
  • Completes Chemical Footprint Project survey to determine current use of chemicals of high concern and updates its policy to include additional measurable goals towards improving its chemicals management strategy, chemical inventory, and chemical footprint.

DO NO HARM

Demonstrated commitment that company’s leadership is behind its chemicals policy (public statement by executive leadership CEO letter in sustainability report, e.g.), but no demonstrated progress towards goals of reducing hazardous chemicals

DO LESS HARM

No demonstrated progress towards goals of reducing hazardous chemicals, or did not set out measurable goals in its policy.

COMPLIANCE

No policy / No stated goals for reducing hazardous chemicals


2. Chemicals Assessment

This section encompasses specific approaches, methods and criteria for evaluating chemicals, determining chemicals of high concern to reduce or eliminate, and assessing alternatives to avoid regrettable substitution.

A. Identifying Chemicals of High Concern

Process company uses to determine chemicals of high concern to human health, the environment, or of increasing concern to consumers. This includes specific health and environmental endpoints considered, and how the company uses authoritative lists of chemicals of concern established by scientific and governmental organizations. Encompasses approaches to hazard and exposure assessments and criteria for eliminating chemicals and/or establishing thresholds for chemicals to be restricted. This is a central question in differentiating how one company defines “safe” compared to another.

HEALTH FIRST

Process for identifying chemicals of high concern (COHCs) involves prioritizing:

  • Chemicals regulated in any jurisdiction [CA Prop 65, CA Candidate Chemicals List, Canada Toxic Substances List – Schedule 1, EU allergens etc.], and
  • Hazardous chemicals identified by authoritative scientific bodies [IARC, NTP, TEDX etc.], and
  • Chemicals identified by NGOs as being of concern to their constituencies, and
  • Chemicals associated with adverse health impacts in epidemiological studies published in peer-reviewed journals, and
  • Chemicals identified in products with high rates of reported adverse reactions, and
  • Chemicals identified as having hazard properties when run through GreenScreen List Translator and EPI Suite (where applicable).

Where hazards have been identified, process for evaluating chemicals of high concern involves:

  • Evaluating whether the product containing the chemical is a necessity, and if not whether it can be withheld from market or discontinued
  • Looking to widely used alternatives for the chemical function
  • Fully inventory use of the chemical in all cleaning products, and:
    • Discontinue the relevant product, or
    • Look to widely used safer alternatives for the chemical function, or
    • Conduct alternatives assessment outlined in 2C HEALTH FIRST level to identify safer substitutes for all products in and functions for which chemical is used
  • Prohibiting the chemical and place chemical on Restricted Substances List
  • Making testing methodologies, data, findings, and all other relevant chemical assessment information available to the public.
  • Taking feedback from academic researchers, NGOs, and other external parties on assessment processes and data to inform decision-making about chemical use

Where lack of data or insufficient data make hazard properties of a chemical difficult to identify:

  • Does not include the chemical on its palette, and/or
  • Withholds product containing the chemical from market until alternatives have been identified and evaluated for the relevant function, and
  • Actively seeks to research or invest in research on adverse health and environmental impacts of the chemical

DO NO HARM

Process for identifying chemicals of high concern (COHCs) involves prioritizing using either:

  • Extensive review involving:
    • Chemicals regulated in any jurisdiction [CA Prop 65, CA Candidate Chemicals List, Canada Toxic Substances List – Schedule 1, EU allergens etc.], and
    • Hazardous chemicals identified as by authoritative scientific bodies [IARC, NTP, TEDX etc.], and
    • Chemicals identified by NGOs as being of concern to their constituencies, and
    • Chemicals associated with adverse health concerns in epidemiological studies published in peer-reviewed journals, and
    • Chemicals identified in products with high rates of reported adverse reactions, or
  • Abbreviated process based on:
    • Chemicals identified as having hazard properties when run through GreenScreen List Translator and EPI Suite (where applicable)
    • Chemicals identified by NGOs as being of concern to their constituencies.

Where hazards have been identified, process for evaluating chemicals of high concern involves:

  • Fully inventory use of the chemical in all cleaning products, and:
    • Discontinue the relevant product, or
    • Look to widely used safer alternatives for the chemical function, or
    • Conduct alternatives assessment outlined in 2C HEALTH FIRST level to identify safer substitutes for all products in and functions for which chemical is used
  • Prohibiting the chemical and place chemical on Restricted Substances List
  • Looking to widely used alternatives for the chemical function and/or following alternatives assessment actions in 2C DO NO HARM level

Where lack of data or insufficient data make hazard properties of a chemical difficult to identify,

  • Determines whether there are low level (non-monotonic dose response) exposure concerns for the chemical or any chemicals with similar structures, and:
    • Commit to not use the chemical at any level, or
    • Continue to evaluate the chemical if no low level exposure concerns exist
  • Assesses whether exposure concern is relevant to the product uses (beyond “use as directed”), and
    • If no reasonably anticipated product use is relevant to the exposure concern, continue to use chemical in current products, and commit to not use the chemical in any product with the relevant exposure concern in the future
    • If any reasonably anticipated product use is relevant to the exposure concern, follow steps below.
  • Establishes thresholds at which chemical will not be used that take into account the most vulnerable populations reasonably anticipated to be exposed to the product, including women in different stages of pregnancy and breastfeeding, infants and young children, children at different stages of puberty, people with different types and stages of cancer, and cleaning workers who have higher cumulative exposures to chemicals in cleaning products.
  • When extrapolating risk from animal studies, applies a high standard for determining any potential risks to humans, including vulnerable populations described above.
  • Makes testing methodologies, data, findings, and all other relevant hazard and exposure assessment information available to the public.
    • If following risk assessment guidelines issued by government agencies (National Academy of Sciences, Environmental Protection Agency, World Health Organization), makes explicit how these tools are being used.
  • Takes feedback from academic researchers, NGOs, and other external parties on assessment processes, data, and established margins of safety to inform decision-making about chemical use
  • May still include the chemical on its palette, and
  • Seeks to limit use of the chemical in products, and evaluates alternatives for the relevant function, and
  • Actively seeks to research or invest in research on adverse health and environmental impacts of the chemical

DO LESS HARM

Process for identifying chemicals of high concern (COHCs) involves prioritizing using either:

  • Extensive review involving:
    • Chemicals regulated in any jurisdiction [CA Prop 65, CA Candidate Chemicals List, Canada Toxic Substances List – Schedule 1, EU allergens etc.], and
    • Hazardous chemicals identified as by authoritative scientific bodies [IARC, NTP, TEDX etc.], and
    • Chemicals identified by NGOs as being of concern to their constituencies, and
    • Chemicals associated with adverse health concerns in epidemiological studies published in peer-reviewed journals, and
    • Chemicals identified in products with high rates of reported adverse reactions, or
  • Abbreviated process based on:
    • Chemicals identified as having hazard properties when run through GreenScreen List Translator and EPI Suite (where applicable)
    • Chemicals identified by NGOs as being of concern to their constituencies.

Where hazards have been identified, process for evaluating chemicals of high concern involves:

  • Conducts exposure assessments on hazardous chemicals. Utilizes a limited range of dosage levels in testing process.
  • Establishes thresholds at which chemical will not be used that do not take into account the most vulnerable populations, such as those described above, or does not establish firm thresholds at which chemical will not be used.
  • When extrapolating risk from animal studies, does not apply a high standard for determining any potential risks to humans, including vulnerable populations described above.
  • Based on exposure assessments, chemicals are routinely found to be safe at certain levels.
  • Continues to use hazardous chemicals in products when:
    • Exposure concern does not match product use
    • Low level exposure concerns have not been assessed
    • At levels below which an adverse effect is observed for a limited array of health endpoints, and does not into full account vulnerable populations, including those described above.
  • May follow exposure assessment protocols set out by government agencies (National Academy of Sciences, Environmental Protection Agency, or World Health Organization) but:
    • Does not make testing methodologies, data, findings, and all other relevant hazard and exposure assessment information available to the public
    • Does not takes feedback from academic researchers, NGOs, and other external parties to inform decision-making about chemical use.

Where lack of data or insufficient data make hazard properties of a chemical difficult to identify,

  • Continues to include the chemical on its palette, and
  • Continues to use the chemical in products, and evaluates alternatives for the relevant function, and
  • Monitors new research on adverse health and environmental impacts of the chemical

COMPLIANCE

  • Identifying chemicals of high concern based on applicable laws and regulations
  • Does not conduct chemical hazard assessments using any available third-party method or tool
  • Does not make testing methodologies, data, findings, and all other relevant hazard and exposure assessment information available to the public
  • Does not takes feedback from academic researchers, NGOs, and other external parties to inform decision-making about chemical use.
  • Where lack of data or insufficient data make hazard properties of a chemical difficult to identify, continues include the chemical on its palette, and use it in products.

B. Taking Action on Chemicals of High Concern

Chemicals that the company does not use or uses in restricted amounts in formulated products. Based on process described in 2A (above), the Restricted Substances List (RSL) a company develops constitutes the set of chemicals it is actively working to reduce or eliminate.

HEALTH FIRST

Inclusive of chemicals prohibited or restricted by law in any jurisdiction, AND chemicals with hazard properties not currently prohibited or restricted by law, AND chemicals for which no or insufficient safety data exist.

  • Prohibits chemicals of high concern (COHC) identified and evaluated in 2A HEALTH FIRST level above
  • Additional chemicals identified based on other safety concerns are prohibited and/or restricted. (Beyond RSL)
  • Prohibits/restricts chemicals of concern raised by environmental and public health NGOs
  • Prohibits chemicals for which no or insufficient safety data exist, or where weight of evidence of harm or safety remains unclear
  • Conducts alternatives assessment described in 2A HEALTH FIRST to identify safer alternatives
  • Chemical screening process rules out all chemicals listed in Appendix 1

DO NO HARM

Inclusive of chemicals prohibited or restricted by law in any jurisdiction, AND chemicals not prohibited or restricted by law that the company has identified based on hazard properties and other safety concerns (Beyond RSL)

  • Prohibits chemicals of high concern (COHC) identified and evaluated in 2A DO NO HARM above.
  • Additional chemicals identified based on other safety concerns are prohibited and/or restricted (Beyond RSL)
  • Prohibits/restricts chemicals of concern raised by environmental and public health NGOs
  • Conducts alternatives assessment described in 2C DO NO HARM to identify safer alternatives, and
  • Continues to use chemicals for which no or insufficient safety data exist, or where weight of evidence of harm or safety remains unclear
  • Places a growing number of chemicals on the list of prohibited chemicals as additional epidemiological and toxicological findings shift the weight of evidence towards a chemical’s harm
  • Chemical screening process rules out all chemicals listed in Appendix 1

DO LESS HARM

RSL that is inclusive of chemicals restricted by law in any jurisdiction, applied globally (Beyond RSL)

  • Continues to use hazardous chemicals in products only if:
    • Exposure concern does not match any reasonably anticipated product use (beyond “use as directed”)
    • Low level exposure concerns have been assessed and are not relevant
    • Only at levels below which ANY adverse effect is observed for ANY relevant health endpoint and taking into account vulnerable populations, including those described above.
  • Conducts alternatives assessment described in 2C DO NO HARM or DO LESS HARM levels to identify safer alternatives, and
  • Places a moderate number of chemicals on the list of prohibited chemicals, and/or this list remains stagnant for many years.
  • Chemical screening process continues to allow 1 or more chemicals listed in Appendix 1

COMPLIANCE

RSL that is compliant with regulatory standards in all jurisdictions where products are sold

  • RSL consists of chemicals of concern as restricted or prohibited in certain jurisdictions, and is not applied globally
  • When a chemical must be eliminated to comply with regulation, alternatives assessment does not take adverse human health or environmental impacts into account
  • Company standards continue to allow 1 or more chemicals listed in Appendix 1

C. Alternatives Assessment and Safer Substitution

When replacing a chemical with an alternative, company has a commitment to and process for assessing alternatives to identify safer substitutes and avoid regrettable substitution.

Also addresses the criteria by which enough reports of adverse reactions from product users prompt additional action, including reformulation, redesign, and product discontinuation.

HEALTH FIRST

Alternatives assessment:

  • Uses one of these methods:
    • Conducts/commissions full GreenScreen for Safer Chemicals assessments on all chemicals being considered as replacements. Chemicals assigned Benchmark I or II are not used as replacement chemicals, or
    • Utilizes MadeSafe certification process to identify safer chemical substitutes, or
    • Uses an equally rigorous process for assessing chemical alternatives and identifying safer alternatives. This process would need to be made public so that external parties can verify level of rigor.
  • Sets and follows a high standard at which adverse reaction reports trigger further assessment and/or possible reformulation, redesign or discontinuation

DO NO HARM

  • Runs chemicals through criteria established by Safer Choice, GreenSeal, or EcoLogo product certification processes, or
  • Follows decision-making model detailed in BizNGO Chemical Alternative Assessment Protocol
  • Has an internal system for tracking adverse event reports, and will look to discontinue/reformulate/redesign product if enough reports received, but does not share reporting data externally

DO LESS HARM

  • Consults Safer Choice SCIL List and/or CleanGredients to identify safer chemicals
  • Has signed and follows a process guided by the BizNGO Common Principles of Alternatives Assessment
  • Has an internal system for tracking adverse reaction reports, but does not consider reformulation based on such reports, and does not share reporting data externally.

COMPLIANCE

  • Does not have a stated commitment to or process for avoiding regrettable substitutes when phasing out chemicals of high concern.
  • Does not consider taking further action based on adverse reaction reports, including reformulation, redesign, and product discontinuation.

D. Treatment of Fragrance Ingredients

Standards and practices company uses to ensure that commitment to chemical and product safety incorporates fragrance chemicals, whether the company is a formulator or contracts with external fragrance suppliers.

HEALTH FIRST

Requires full fragrance ingredient disclosure from suppliers, and uses the same process for screening chemicals as used in 2A-C HEALTH FIRST levels above to identify and eliminate COHCs

DO NO HARM

Goes beyond IFRA standards to evaluate fragrance ingredient safety, identify fragrance COHCs, and make progress towards eliminating them as described in 2A-C DO NO HARM levels above.

DO LESS HARM

Fragrance palette is narrower than IFRA list. Does not conduct full assessments of all fragrance chemicals on its palette to identify a thorough list of fragrance COHCs. Assessments that are conducted follow same procedures and standards as described in 2A-C DO LESS HARM levels above.

COMPLIANCE

Assures fragrance supplier complies with standards established by IFRA. Complies with laws and regulations in all jurisdictions where products are sold. Assumes fragrance supplier has already assessed ingredient safety, and goes no further.


3. Disclosure / Transparency

This section looks at whether companies publicly share information about their safer chemicals policies, practices, and criteria. The Chemical Footprint Project is a third-party, industry-friendly, and NGO-supported tool available to measure a company’s use of chemicals of high concern. When companies choose to make their survey responses and score public, this is another way to approach transparency in this arena.

A. Chemicals Policy Transparency

Public disclosure of information about a company’s chemical screening process and criteria, and public reporting on measurable progress through annual sustainability reports (or other print or online communications). Also addresses how the company tracks and responds to adverse reactions reported to them by product users, and its willingness to share reports externally.

HEALTH FIRST

Does all of the following:

  • Publicly discloses chemicals policy and chemicals management goals
  • Annually reports on progress toward stated COHC reduction goals
  • Publishes complete RSL, including an explicit list of prohibited chemicals, and thresholds at which chemicals are restricted.
  • Makes public its hazard and exposure assessment processes, standards, and testing data.
  • Makes public its system for cataloguing adverse reactions experienced by product users, and shares adverse reaction reports to Consumer Product Safety Commission, Food and Drug Administration, and other relevant regulatory agencies

DO NO HARM

  • Company safer chemicals policy is publicly available and EITHER restricted substance list (RSL) is publicly available OR company annually publicly reports on metrics in implementing its safer chemicals policy. (As per Mind the Store retailer scorecard, metrics may include quantifying reductions of COHC by weight, number or percent of products containing COHC, and/or number or percent of suppliers selling products containing COHC).
  • Makes public its system for cataloguing adverse reactions experienced by product users, and shares adverse reaction reports to select third parties.

DO LESS HARM

  • Company safer chemicals policy and a short list of prohibited or restricted ingredients is publicly available.
  • Company commits to publicly disclose its complete Restricted Substance List within 1-2 years.
  • Makes public its system for cataloguing adverse reactions experienced by product users, but does not share adverse reaction reports externally.

COMPLIANCE

  • Does not have or does not publicly disclose its chemicals policy for reducing chemicals of high concern.
  • Does not have or does not make public its system for cataloguing adverse reactions reported by product users.
  • Does not share adverse reactions reports externally.

B. Chemical Footprinting

Measuring a company’s use of chemicals of high concern in products and progress towards using safer alternatives. This includes participating in the Chemical Footprint Project (CFP) survey, and making the information public.

HEALTH FIRST

Completes Chemical Footprint Project survey and publicly reports on score and survey response as well as goals and progress towards reducing its chemical footprint.

DO NO HARM

Develops own method for measuring its chemical footprint and publicly reports on goals and progress towards reducing its chemical footprint (e.g. Walmart).

DO LESS HARM

Measures its chemical footprint, either using Chemical Footprint Project survey or its own method, but does not report publicly on goals or progress.

COMPLIANCE

Does not take steps to measure or reduce its chemical footprint.


4. Industry Collaboration

This section highlights the importance of collaboration among companies that manufacture cleaning products. Such collaborations as the Zero Discharge of Hazardous Chemicals initiatives are included here as the model, where members share the goal of eliminating the use of hazardous ingredients and the presence of hazardous contaminants.

A. Improving safety standards across cleaning products sector

Demonstrable efforts to work collaboratively, share information relevant to chemical screening and safer chemicals, and developing tools and practices that raise the standards across the industry.

HEALTH FIRST

Does all of the following:

  • Works to improve industry-wide data sharing of hazard assessments
  • Leads and participates meaningfully in collaborative green chemistry initiatives
  • Works towards development of industry RSL
  • Seeks to improve company practices to keep ahead of collaborative efforts

DO NO HARM

  • Engages meaningfully in collaborative green chemistry initiatives
  • Works towards development of industry RSL
  • Seeks to improve company practices in step with collaborative efforts

DO LESS HARM

Participates in collaborative green chemistry initiatives

COMPLIANCE

Does not engage in any of the above activities.

The Health First Roadmap is the result of the combined talents of Sarada Tangirala (lead author) and Alexandra Scranton, with editorial review provided by Jamie McConnell, Erin Switalski, and Beth Conway.

Special thank you to the Health First Advisory Committee:

Ann Blake, Ph.D., Environmental & Public Health Consulting

Sally Edwards, Sc.D., Senior Research Associate, UMass Lowell Center for Sustainable Production

Roger McFadden, President, McFadden and Associates, LLC

Mark Rossi, Ph.D., Executive Director, Clean Production Action