“Behind the Green Curtain”

2. “Behind the Green Curtain” Terri Germain August 3, 2009 The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

3. “Green” is… Low Toxicity? Safe for Aquatics? Renewable? Sustainable? Organic? Biodegradable? Water Conservation? Low VOC? Natural? Safe? Environmentally Benign? Energy Saving? The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

4. Have Some of These Attributes Readily Biodegradable Non-Toxic & Non-Sensitizing Low Aquatic Toxicity Low or No VOCs Neutral pH at Use Non-Combustible/Flammable Concentrated Formulations Works Well in Cold Water Recyclable Packaging From Renewable Resources Generally Do Not Contain Phosphorus compounds Hypochlorite Phenolic compounds Ethylene Glycol Ethers Carcinogens Heavy metals Phthalates Alkylphenol Ethoxylates “Green” Environmentally Friendly Products The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

5. The U.S. Federal Trade Commission (FTC) and the International Standards Organization (ISO) consider this claim to be too vague to be meaningful to consumers. The FTC guidance requires manufacturers to either avoid such terms or substantiate and qualify them to avoid misleading consumers. To comply with the ISO standard for environmental claims (which is voluntary), companies must not use them on their products. The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

6. Just a Few Initiatives…. The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

7. #1 Where it came from… Renewable Resource “Organic” Vegetable vs Animal Recycled Feedstock #2 Where it’s going… Environmental Fate Biodegradability Aquatic Toxicity Let’s Focus a Bit on Ingredients… Remember, Green is also about Safety (Neutral pH vs very high of very low pH), Energy Consumption (Hot water vs Cold Water), Packaging (recycled, post consumer), Concentrate vs RTU, Transportation (Local ingredients vs transoceanic) And on, and on, and on…. The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

8. #2 Environmental Fate • Key Drivers • Biodegradability • Aquatic Toxicity • No Carcinogens • Common U.S. Green Certifiers • EPA’s Design for the Environment (DfE) • GreenSeal • EcoLogo (Canada) The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

9. Design for the Environment (DfE)www.epa.gov/dfe/index.htm I&I Partnership • DfE's Formulator Program encourages partners to reformulate products to be environmentally safer, cost competitive and effective. The Formulator Program reduced ~ 160 million pounds of chemicals of concern in 2007. • Many of the industry's major I&I players are already or are in the process of becoming DfE partners. • State govt purchasing entities now include DfE recognition in their specifications for eco-friendly products. Consumer Products Partnership • DfE is now working with the consumer cleaning products sector. • DfE has also partnered with Wal-Mart's Chemical-Intensive Product Network to develop sustainability scorecards for suppliers and manufacturers. The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

10. DfE Formulator Program Steps to Partnership • Contact EPA DfE to discuss product submissions. • Search for safer ingredients on CleanGredients™. • Request 3rd-party ingredient profiling. • NSF International and ToxServices are qualified to provide this service. • Submit ingredient profiles to EPA DfE. • Sent by third-party on behalf of the formulator. • Review ingredient profiles – EPA technical workgroup. • Post-assessment discussion with submitter. • Sign partnership agreement. • 3-year agreement between formulator and EPA The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

11. DfE Formulator Program Steps to Partnership The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

12. NSF Third Party Review Costs Fee Per Product $400 A one-time, flat fee charged for each product or unique trade name: (includes administration, data entry, and summary report) Fee Per Ingredient $525 Single ingredient (first time review; includes complete literature search and data validation) $1050 Proprietary ingredient (first time review, includes contacting supplier, complete literature search and data validation) $1250 Fragrance (first time review) No Charge Pre-reviewed ingredients (includes ingredients listed on CleanGredients or previously reviewed for your company Fees as of July 2008 – Contact NSF for updated pricing The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

13. DfE Standard Surfactant Screen • Must not contain CMRs (Carcinogenic, Mutagenic or Toxic to Reproduction) • Must not Bioaccumulate • Aquatic Tox and Biodegradation • In general, there is a predictable relationship between acute aquatic toxicity and chronic aquatic toxicity for organic chemicals, i.e. chemicals that have high acute aquatic toxicity also have high chronic aquatic toxicity. Since acute aquatic toxicity data are more readily available, the DfE Screens use these data to screen chemicals that may be toxic to aquatic life. • Generally, >60% mineralization (to CO2 and water) in 28 days. • Products of concern are compounds with high acute aquatic toxicity (L/E/IC50 ≤ 10ppm) and a slow rate of biodegradation (greater than 28 days). The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

14. Design for the Environment (DfE)Detergent Ingredients Partnership • DfE has partnered with the GreenBlue Institute to develop a tool for easy, reliable identification of ingredients with optimal performance and environmental characteristics. • CleanGredientsTM at www.cleangredients.org • CleanGredientsTM was developed by a multi-stakeholder advisory committees and includes Surfactants and Solvents • An ingredient in listed as “not meeting DfE criteria” does not mean it cannot be used. • The formulator must have a case for the use – such as “there is nothing better in the market place for this application.” • Each year the DfE will ask the formulator the question and the answer has to be the same. The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

15. www.cleangredients.org The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

16. The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

17. Green Seal Standards • Degreasing Agents in Production and Maintenance Operations (GS-34) • Consumer Soaps, Cleansers, and Shower Products (GS-44) • General-Purpose, Bathroom, Glass, and Carpet Cleaners Used For Household Purposes (GS-8) • Industrial and Institutional Cleaners (GS-37) • Hand Cleaners and Hand Soaps Used for Industrial & Institutional Hand Purposes (GS-41) • Industrial & Institutional Floor Finishes and Floor Finish Strippers (GS-40) • Laundry Care Products (GS-48) In development The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

18. Green Seal Standards • Primary Criteria • Non toxic • No Allergens, Carcinogens, Mutagens, and Reproductive Toxins • Not Skin Corrosive or Capable of Serious Eye Damage • Not a Skin Sensitizer or Primary Skin Irritant • < 1.0% Skin Absorbing Ingredients i.e. Governmental Industrial Hygienists (ACGIH) Threshold Limit Value list (TLV) carrying a skin notation, or substances that are listed on the German Deutche Forschungsgemeinschaft (DFG) Maximum Allowable Concentrations (MAK) list with a skin absorption H notation. • Does not cause Asthma • Generally < 1.0% VOC • Low Aquatic Tox and Good Biodegradability • Full Listing at http://www.greenseal.org/certification/environmental.cfm The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

19. Trouble with Green Seal Standards? • CRI Withdraws Support for Green Seal Standard • GS-37 measures product efficacy against a "nationally recognized" product rather than against an approved standard. • GreenSeal did not allow the participation of all stakeholders in the development process for GS-37 • GS-37 arbitrarily bans chemicals according to a list, without regard for proper risk assessment - a practice which runs contrary to accepted scientific practices. • At various points, it seemed that peer-reviewed scientific data was discounted in favor of preconceived bias on the part of the standard developers. • GS-37 4th Edition was released without a second ratifying ballot, even after a first ballot failed to achieve a majority. The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

20. HI&I “Green” Requirements • DfE and Green Seal require: • Aquatic Toxicity Data • DfE requires ready biodegradability of ingredients if aquatic tox is GHS Acute Category I or II • Green Seal has different requirements for different standards. Generally they require ≥ 100 mg/L LC50 of daphnia, fish and/or algae on finished product at use • Biodegradation Data • DfE requires Readily or Ultimate Biodegradability • Green Seal has different definitions and requirements for biodegradability • Both will accept OECD testing that EU Authorities are requiring • Green Seal has many more requirements involving VOCs, carcinogens, sensitizers, fragrances, dyes, prohibited ingredients, etc. • Packaging and Use Instructions are also part of “Green.” • Neither require that ingredients are derived from Renewable Resources! The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

21. #1 Resource Utilization • Key Drivers for “Natural” • Renewable Feedstock aka Renewable Carbon • Organic • Reduction and/or Elimination of PetroChemicals • Common Natural / Organic Standards • USDA’s National Organic Program • Ecocert • National Products Association • Oasis The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

22. Natural & Renewable Based • A step toward Sustainable Chemistries • Allows use of limited resources for other needs • Can be calculated two ways • Vegetable content of surfactants • For example: 55% the active surfactant Cocamidopropyl Betaine is vegetable derived. • “New” Carbon vs “Old” Carbon • For example: 65% of the carbon atoms in the active surfactant Cocamidopropyl Betaine are “new” carbons meaning vegetable derived. The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

23. Sodium Coco-Sulfate Mackol CAS-100N The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

24. Cocamide MIPA / Coco monoisopropanolamide Mackamide CPA The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

25. www.greenstarproducts.org Means 76% is Natural Derived The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

26. Natural & Renewable The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

27. Clear & Natural Shampoo No heating required All surfactants and conditioners are vegetable derived Formulation solids is 46% vegetable content Formaldehyde-free Formula #708 The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

28. Surfactant Producer Approaches • Stepan • “Biorenewable Carbon IndexTM” • Cognis • “Green Chemical SolutionsTM” • McIntyre (Rhodia) • “Naturally Mild” The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

29. The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

30. Allowable Chemical Processes • USDA NOP and NSF Organic • Hydrolysis, e.g. Wheat Amino Acids • Esterification, e.g. Glyceryl Stearate • Saponification, e.g. Sodium Cocoate • OASIS & NPA • Everything above plus… • Sulfation, e.g. Sodium Coco-Sulfate • Hydrogenation, e.g. Hydrogenated Palm Oil • Hydrogenolysis, e.g. Hyd. Palm Alcohols The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

31. Allowable Chemical Processes • OASIS & NPA (continued) • Etherification, e.g. Polyglyceryl Stearate • Glycosidization, e.g. Lauryl Glucoside • Acylated amino-acids, e.g. Lauroyl Glutamates • Ecocert • Everything above plus… • Amphoterics & Betaines • Cationic Guar The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

32. Whole Foods • Premium Body Care Quality Standards • “People are looking for safer, more natural body care products, but there is a lot of confusion about what "natural" actually means. So, with more than 25 years of experience and 2 years of tough scientific research review, we have stepped up to help give concerned consumers something to count on.” • Standard List Last Updated 2/15/2008 The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

33. ReckittBenckiser Spartan Clorox S.C. Johnson Zep Seventh Generation Procter & Gamble Who’s Green? Anyone Who’s Anyone! The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.

34. Summary • If anyone asks you for “green” ingredients ask them: • Green …like from natural renewable resources? or.. • Green …like DfE and GreenSeal with biodegradable and low aquatic toxicity? or… • Both? • If anyone asks you what “green” is… • It is still blue + The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement.