Contractors are facing an increasing demand for green chemicals, but finding a single accepted standard to go by is difficult, to say the least. There is, however, some light at the end of the tunnel: R&R spoke with Sam DeAth, president of Sensible Life Products, to discuss recent activity by the U.S. Environmental Protection Agency regarding “green” antimicrobials.
Restoration & Remediation:The EPA recently announced it is considering allowing environmentally friendly marketing claims for disinfectants. Sensible Life Products has been discussing this with them for years; can you give us some background?
Sam DeAth: I’d love to! I know “green” is a hot topic and the drums have been beating loudly over this in the past year in the media, but to understand how big this news is, it helps to realize just how far the EPA has come from its inception in 1970.
The EPA was started to protect the environment from polluting chemicals. Its mission is to protect public health and the environment from risks posed by pesticides and to promote safer means of pest control. Disinfectants were originally categorized and regulated as “pesticides” along with some other very nasty insecticides, herbicides and rodenticides.
Most, if not all, of these products posed some significant level of risk either to humans or to the environment. So you can see where the EPA’s head was at the time and why all pesticides were assumed to be hazardous. You can also see why they have been slow to accept that disinfectants can be “green.” It’s a pretty big mental shift for them.
SD: Well, the EPA’s system is set up to assess the health and environmental risks posed by a chemical and to publicize these risks on the product labels, along with appropriate instructions that, if followed precisely, would ensure the chemicals are used safely and effectively. They review all the toxicity data submitted by the manufacturer from independently approved labs, plus all other information available publicly, like studies from other countries, other manufacturers’ MSDSs, other government agencies, etc. I know we alone submitted two or three banker’s boxes of data and studies, so I’m sure that by now the agency has accumulated an absolutely massive library of information.
Based on the data, each product is then assigned corresponding warnings, precautionary and first aid statements, and assigned a general signal word like “caution,” “warning” or “danger.” Up until recently, every antimicrobial on the market had been assigned a signal word.
As the green chemistry movement started maturing, the products kept performing better and getting cheaper, which made the larger companies start to invest in natural ingredients, and it suddenly became a glaring problem that the EPA regulations specifically forbade any of the common green claims such as “natural,” “safe,” “non-toxic,” “environmentally friendly,” even “biodegradable” because they implied safety and were counterintuitive to their historical mindset.
R&R: It’s a bit odd that the EPA has a well-defined system for measuring exposure risks for people, but has not developed standards for how a product’s ingredients will impact the overall environment.
SD: We ran into this in 2003 while registering our botanical antimicrobial product. And like I said, we had the data to prove our claims. Ours was the first antimicrobial technology in decades that had completely new chemistry. It was a long process to prove to the EPA that you can have an active ingredient that kills bacteria, mold and viruses as well as the old-school products, but that poses no harm to human health or the environment, even from aggregate exposure including infants and children.
However, this paradox makes sense when you compare it to the human immune system; our antibodies fight off bacteria and viruses all day long but don’t harm our bodies. Still, it was a total paradigm shift for the EPA because this product didn’t fit their definitions. After jumping through all the hoops, they finally registered our product without any label warnings! At the time, however, they weren’t ready to tackle the environmental issues. They did let us use the word “botanical” because we actually grow thyme oil, our active ingredient. It was a little disappointing because we had the data to prove our other environmental claims, but they didn’t have the standardized criteria established yet, so they wouldn’t allow us to talk about any of the environmental benefits of the product. So, I’m very happy they are finally coming around on this now and are going to set new standards!
This decision by the EPA to entertain environmental terms is also driven by the public. For years now people have been expecting to see the buzzwords like biodegradable, sustainable and renewable on antimicrobial products. These features are incredibly important, but until now haven’t been allowed in the regulated world of disinfectants, and by the same token, the truly responsible products have not been able to differentiate themselves from competitors on their own label! So it really is about time for this change, to meet public demand, but also to encourage more positive changes for worker safety and the environment.
SD: Change happens slowly with almost every government agency, especially when legislation needs to be changed. It’s like trying to turn a cruise ship around. They have to be sure of what they’re doing, because they are creating the yardstick against which manufacturers of all chemical products are measured. You can only imagine the responsibility here because they literally are the bureaucratic bottleneck for some of the biggest companies in the world. These rules apply to all the big chemical companies. We manufacturers have no choice but to go through this process because public safety is at risk.
The good news is that they’ve already started to allow some changes! For example, all disinfectants are required to be rinsed off any surface that might result in direct oral or skin contact with the user, such as cutting boards or baby toys. That regulation was in place across the board no matter what your disinfectant was made of because typically they had some type of toxicity if ingested.
The EPA recently gave the first-ever exemption to our botanical disinfectant, because our plant-based active ingredient is an actual herb and approved as a Direct Food Additive by the FDA, so there was no argument that could be made about whether it was safe to ingest or not. They reviewed the toxicity tests, including decades of historical data, and deemed that the product didn’t pose any hazardous risks of ingestion for humans or animals and therefore doesn’t require a rinse or a wipe after application on food contact surfaces or baby’s toys. After we go through our next round of changes to our label with the EPA, this will appear on the label.
That is a huge win for us, and it speaks to the fact that the EPA is changing with current technologies in antimicrobial chemistry and understanding you don’t need a toxic chemical in order to be efficacious.
Diagram 1
SD:As we all know, there is a lot of “greenwashing” going on, and more manufacturers wanting to attach the term to their products in some way or another. Some are valid, some are just to ride the wave any way they can.
To help make some sense of it all, we created a “Many Faces of Green” diagram (Diagram 1) to help clarify the relationship between the commonly used terms and to help the industry make informed or comparative decisions. We need these terms to be standardized to stop the “greenwashing” and the EPA is in a perfect position to do just that.
We can break chemical ingredients into two categories [at] their source. Some are from natural sources like plants and some are synthetically manufactured. Most antimicrobials that are used in our industry are synthetic chemicals. These include glutaraldehyde, phenol or quaternary ammonium. These are man-made and generally not considered “green.”
However, there are some cleaners that are “natural-based” and these are synthetic compounds that mimic natural ingredients. These could cross over into being called somewhat “natural,” although that is arguable for obvious reasons. Natural is the broadest term and used most often in manipulative marketing which also makes it the least helpful. Thankfully, the EPA forbids this term from being used with any disinfectants.
If your definition of “green” is simply being biodegradable, then you would have to include synthetically based bleach, because when sodium hypochlorite degrades, except for a small percentage, it turns into nothing more than salt. So one form of bleach can be considered biodegradable, but that obviously doesn’t account for its VOC content or toxic byproducts in manufacturing.
Biodegradable is a good indicator, but even this can be misleading depending on the method used to test it. For example, some synthetic chemicals may appear to biodegrade to a certain degree under certain conditions, but this still doesn’t mean they are good for the environment, because they may also bio-accumulate over time, building up in the ecosystems, food chains and drinking water.
A more defining term of “green” is sustainable. This includes some of the cleaners that are entering the market that contain bio-surfactants. Depending on their feedstock and types of by-products from production, these bio-surfactants can be a very sustainable option. An example of this would be corn or palm oil-based surfactants.
Ultimately, sustainable is the best guiding principal because it incorporates all the definitions yet cannot be manipulated to achieve some level of green-washing. Simply put, sustainability looks at a product’s life cycle, what it is made from, how it’s made, how much is made, where it gets used and what happens to it after its use. It is also explained as having no impact on several future generations.
Within the definition of sustainable falls the naturally-sourced ingredients that are plant-based, or botanical. We like using botanical because it always means that a product is natural and biodegradable and usually sustainable. The exception to this would be some plant extracts that come from rare, low-yield or hard to grow plants. These would not be considered sustainable.
Lastly, regarding the term safe, a product can be natural, botanical or sustainable but not necessarily safe. Snake venom is natural but isn’t at all safe! So to generalize that green equals safe isn’t true 100 percent of the time, and one should dig a little deeper before assuming that. When it comes to antimicrobials, however, the EPA has already taken care of this for us! They have standardized and defined “safety profiles” for disinfectants, which are communicated on the product label via the signal word and the warnings, so we can leave that in their capable hands since it’s a system that seems to be working.
SD: That’s right. That is a common misconception and, although most natural products tend to have a much better safety profile, it doesn’t mean they are all safe. “Safe” is a sweeping term and can be interpreted to mean many things. What does it mean to the average contractor or homeowner? Does it mean safe under any and all circumstances, like having a bath in it every morning? That was a joke. Or, safe if applied strictly according to the label with appropriate protective clothing? That sounds like nothing more than legalese to me. Or is it meant to mean inherently safe under normal circumstances, ideally including common accidents, like if a child ingests some or there is a large industrial spill or a technician is exposed to it daily?
R&R: It’s been said that everything is toxic at some level, depending on the dose.
SD: Yes, I’ve heard that too. So does that statement mean that every chemical is therefore equally safe or that we should give up trying to find safer alternatives because it won’t make a difference? To illustrate how misleading that rhetoric is, say you have a glass of water, a glass of diet soda and a cup of triple espresso. Which one would you choose to give your baby daughter in her nighttime bottle? It shouldn’t matter if they’re all toxic at some level, right? If it’s true that everything carries some risk, does that mean any amount of risk is equal? If that were true, then hurtling down the highway in a 2009 Volvo would be equally as risky as in a 1970 Pinto. Simply not the case.
To flesh this example out more, most of us drive a car every day. They all get us from A to B, and there are inherent risks with every trip, yet we all accept them and consider driving safe enough. However, if you were given the choice of driving a 1970 Ford Pinto or a 2009 Volvo, which one would you choose? They both get you where you want to go, but is one actually safer?
Common sense tells you that advancements in crash testing and computerized stability control keep you safer in more situations and make the Volvo a wiser choice. Safe can mean getting from point A to point B without losing your life, but it can also mean advanced technology like ABS and air bags in the event of an accident.
This is exactly what is happening with antimicrobials that are claiming to be safe “if used as directed.” While this is technically true for all disinfectants, according to the EPA’s mandate, it does not mean the chemical inside is inherently safe or as safe as any other. It means it can be used with manageable risk if the precautions and instructions are followed explicitly. When the EPA label is covered with warnings, claims of safety seem illogical and can be misleading because, to the EPA, they have addressed the risks by warning the user of them by requiring precautions such as “avoid inhalation of spray” or “use appropriate respirators and protective clothing to prevent inhalation or contact.”
Back to the car example. That is like saying the Pinto is as safe as the Volvo, but the Pinto’s owner’s manual says to avoid all rear-end collisions. Similarly, old-school chemical technology does work but there has been 30 years of advancements since then! Optimized dynamic chemistry using bio-ingredients has revolutionized chemistry and the way chemicals are produced, and will for the foreseeable future. There are now a lot more options.
VOCs [Volatile Organic Compounds] are another area where there is confusion. Some people mistakenly confuse fragrance with VOCs but they are two different things. VOCs are a concern because they volatilize or evaporate into the air and you breathe that compound in. That is obviously not good if the chemical is not something you want to breathe in or it has a poor safety profile.
Cleaning products under your sink are off-gassing imperceptible amounts of VOCs continually, which can negatively affect your indoor air quality. A VOC doesn’t necessarily have a noticeable smell and the opposite is also true, where having a detectable fragrance doesn’t mean a product has VOCs. For example, a botanical fragrance has VOC levels of less then 0.1%. Besides, disinfectants are generally sprayed, so the product is being volatilized anyway, making it even more important to be comfortable with what you are spraying.
There is also a school of thought that all fragrance is bad. However, one of the leading causes of asthma in the industrialized world is a common antimicrobial ingredient that has almost no smell. Neither does cancer-causing dioxin. Would you rather be aware that you are breathing in a chemical, or have no clue? If we aren’t aware what’s in the air we’re breathing, then we can’t make choices to protect ourselves and we are trusting the chemical is OK to breathe in.
True, some people have reactions to fragrances, but the majority of fragrances these days are synthetic. For thousands of years all fragrances were natural and they did not cause the same problems as we seem to have since we developed synthetics. A true allergic reaction to natural fragrance is rare and almost all natural compounds have a fragrance. This push for fragrance-free chemicals has the potential to cause more confusion in my mind.
As you can see, sweeping generalizations can be misleading, especially if left up to the marketers to play this game. Luckily, this is precisely what the EPA takes care of for us! They review all the safety data and reach unbiased conclusions about what warnings should be on the label. They have the expertise and they have no bias. Thanks to this, contractors don’t have to become experts in toxicity, mutagenicity, carcinogenicity, evaluating efficacy methodologies, etc., to uncover the truth. It’s already all there on the label; all we have to do is look, regardless of what the magazine ads may say.
SD: Of course. I assume everyone does at some level, but our approach is to provide independent verification and supporting data of our claims so people can do their own research on what we’re saying.
R&R: So what if someone is most concerned about safety in terms of the environment?
SD: Just to back up a little, we need to make sure the product works, first and foremost. If the antimicrobial is registered with the EPA, meaning it has an EPA number on it, then that number is your assurance that the product has been tested and does what the label says it will do. Then you need to choose an appropriate chemical for the job you are doing. Use a hospital disinfectant for grey water. A hospital disinfectant with TB efficacy in black water and a fungicide for mold jobs. Then you need to consider any particular client’s needs or concerns such as children, pets, asthma, illness, elderly, chemical sensitivities, etc. Once all of those things are determined, then look at the environmental features.
SD: The simplest answer is to look at the ingredients. You can gather that from the product label, the MSDS and any other public documents. If you see any that concern you, a quick check on the public watchdog lists like www.PesticideInfo.org or www.ScoreCard.org will shed a lot of light.
When looking at ingredients in antimicrobials, synthetic vs. sustainable is by far the best indicator of an environmental profile. How many synthetic ingredients are sustainable? Historically, antimicrobials were predominantly synthetic and are therefore not readily biodegradable. They don’t assimilate into the environment very well, and in addition, many bio-accumulate.
This is the difference between something having acute toxicity, such as burning your skin if you spill it, and something that has chronic effects, such as causing cancer or asthma after years of exposure, negatively affecting the quality of life in your later years. The EPA has a standard for acute toxicity, but they now need to identify the effects of long-term exposure of products in order to truly capture an environmental profile.
Usually, product packaging is considered part of sustainability as well, but antimicrobials in our industry come in recyclable jugs, so that really isn’t an issue for us. Concentrated products do reduce the amount of water that is being shipped around but there are only a handful of disinfectant technologies that can be concentrated and none of them are natural or sustainable.
Concentrates also come with their own issues around improper mixing. How many contractors do you know who accurately measure let alone test the hardness, temperature or pH of the dilution water? These things can negatively impact the safety profile and the germ-killing ability of the chemistry. Remember, a product needs to work first and foremost, and who needs more to worry about on the jobsite?
All antimicrobials have directions regarding how the product needs to be disposed of, as a direct result of their review of the ingredients and their potential environmental impact. Again, the EPA has already done the technical work for us. Many products are actually prohibited from even entering waterways or sewage systems. This should be a flag to us and beg the question, “Why?” Disposal laws are only going to be getting stricter in the future too. And as more and more states and municipalities are issuing fines for improper disposal, this will become a widespread public concern and will force large-scale change. This is one reason is why some products are not available for sale in California.
SD: A lot of chemical companies have tried to address the public demand for green products by simply adding a natural ingredient or removing an ingredient that is known to be bad. Then they slap a green sticker on the bottle and call it environmentally friendly. We’ve all seen the phrase “with natural essential oils fragrance” or “ammonia-free” at the grocery store. But one single ingredient does not make up the whole product.
This approach does not address the whole picture when any, or all, of the remaining ingredients can still be problematic. To illustrate, claiming a product is green when it only contains a single plant-based ingredient, like pyrethrin from Chrysanthemums, is misleading, especially when another one of the ingredients is listed on California’s Prop 65 List of Known Carcinogens.
This goes back to what I was saying about being natural but not safe. Pyrethrins are botanically sourced, but they have also recently been prohibited in residential areas, schools, hospitals and daycares by the EPA itself. This product should not be considered botanical, and claims like this aren’t helping the industry’s trust in chemical manufacturers.
Total bottom-up product formulation is the best approach, instead of specific ingredient reformulation. Many manufacturers are rushing to find bio-based alternatives for their existing ingredients. I take a certain amount of pleasure watching the old-school chemists try to rethink their ingredients list. It is a real square peg in a round hole situation.
Natural ingredients are not as predictable as synthetics. They were designed to work within a system, never as stand-alone compounds, so one needs to learn to work within that. We went through that process over 10 years ago, and you basically have to set aside what traditional chemistry teaches and think completely outside the box. It isn’t easy for most chemists to do that.
Many say that we wouldn’t have come up with our technology if we were classical chemists. We could have simply bought 100 percent pure petrochemically sourced synthetic thymol and formulated with that, but we actually grow our thyme in Spain and formulate with the whole essential oil because, first of all, it’s a sustainable feedstock, but most importantly because we believe the whole oil is a complex compound for a reason, and is the key to the product working so well. We actually blend our thyme oil like a winemaker blends grapes, to achieve a specific chemical profile that we have determined to work most effectively. Imagine a classical chemist, who is used to working with white powders, being able to turn his mind to think about his ingredients like a winemaker.
I have found in my life that, as a general rule, the closer to natural you can get is usually better. A great example of this is food. We all know that field tomatoes taste much better than greenhouse tomatoes, even though science has been working for years to engineer a better greenhouse tomato. There is nothing bad about a greenhouse tomato but we all know they have less taste and texture than a tomato that was grown in the ground.
Have you tasted the difference between natural vanilla and synthetic vanilla flavor? It’s unbelievable! And imagine trying to make wine by combining all the chemicals separately instead of fermenting grapes. It is possible that one could achieve the same molecular structure but would it taste the same? Probably not!
There has been a recent resurgence in the engineering and industrial design community that has been termed bio-mimicry. It’s truly fascinating. They are looking to nature to redesign and innovate everyday products. By analyzing butterflies’ wings they have developed a whole new color technology without pigments that produces 5000 plus color shades and will never fade. That microthin technology is already in numerous consumer products like make-up, cars and even bike helmets. One company has completely re-engineered the hammer with a more balanced swing and greater efficient blow just by examining the woodpecker.
To develop a new antimicrobial, we examined the immune system of the world’s toughest plant to understand how it has warded off disease and bacteria for centuries. We discovered nature gave plants their own immune system that acts as a deadly killer to some of the greatest virus threats while the plant lives unharmed. It’s no different than the human immune system; it kills bacteria every minute of every day but it doesn’t harm the person. The balance in nature is an incredible thing, and can give us much greater insight into how to do everyday things even better. Somewhere along the line in developing things faster and cheaper, chemical companies lost sight of the grand design and genius of nature.
SD: While it’s true these third-party environmental groups are excellent for information, many of them don’t have a certification category for disinfectants yet. This is something that has been under review for years as well. Again, antimicrobials have a toxic history and the notion that a product that is a biocide could be environmentally friendly is a huge stumbling block.
In addition, but not the least important, several of these organizations have seen the dollar signs of the green movement growth and become for-profit companies. This means every time they award a stamp of approval it brings them income either by direct payment or royalties from certified product sales. With the larger companies coming into the market, royalties from certification of their products represents a very attractive income stream, so guess what? Some certification bodies massaged their standards so the highest volume chemicals suddenly become qualified for inclusion in the certification.
That is a complete conflict of interest in my mind, and is truly a sad state of affairs for something that people need to be able to trust for real change to occur. In the beginning we tried very hard to steer away from this type of hypocrisy and aligned ourselves with an organization that was completely unbiased. We have been working closely with the EPA’s safe chemistry program called Design for the Environment, which grants the DfE logo on products, but they have not released a definitive standard for disinfectants yet.
The EPA and their DfE department make the right partnership for creating these new unified standards. The EPA has no financial stake in products and they review each individual ingredient with expert chemists from many disciplines to formulate a comprehensive understanding of a product. Allowing environmental claims on disinfectant labels is really the next logical step for the EPA, so I eagerly wait the day of that announcement. Hey, maybe we can do another interview then too?
R&R: So in your opinion, what is the bottom line for how the EPA’s new environmental terms will affect the restoration professional?
SD: First off, the new standardized terms and criteria should reduce the “greenwashing” when it comes to antimicrobials. Manufacturers will only be allowed to use select terms that are regulated by the EPA. Contractors will easily be able to tell the environmentally preferable products from those that aren’t simply by looking at the label.
An even greater advantage, however, is that the contractor can use this to market his business better to the growing segment that are demanding environmentally friendly products be used in their homes and businesses. It should help eliminate a lot of the skepticism that comes from using green chemicals and that will be great news to any restoration contractor. If he is working in any kind of public area; daycares, schools or even government buildings, he can market himself as using “green” chemicals, and that will ring true with his customers.
