Written on: December 1, 2017 by Nicholas Georges
Consumers are demanding transparency from all facets of life and product manufacturers are stepping up to the challenge. That’s why many household and commercial product companies, in addition to longstanding voluntary disclosure programs, supported California Senate Bill 258, the Cleaning Product Right to Know Act, which was signed into law on Oct. 15, 2017.
The Consumer Specialty Products Association (CSPA) was a key negotiator of this landmark law that successfully balances consumer and worker demands for more ingredient information with complex implementation issues, including the need to protect certain proprietary and confidential business information. This law was a carefully crafted compromise developed through intense non-governmental organization (NGO)/industry stakeholder negotiations that resulted in an ingredient communication proposal backed both by environmental advocates and name-brand consumer product companies.
The law covers air care products, automotive products and polish or floor maintenance products used primarily for domestic, janitorial or institutional cleaning purposes. It also covers general cleaning products, the definition of which includes the Federal Insecticide, Fungicide & Rodenticide Act (FIFRA)-registered products whose purpose is to disinfect, but in that case, only for online disclosure.
How to comply with California SB-258? The most important piece to compliance is rather obvious, but needs to be stated: know your product. This will likely require an increased amount of ingredient communication up and down the supply chain.
The new law utilizes a number of designated lists and requires manufacturers to provide specific ingredient information, both on label and online, which each have different requirements.
The law has also set out a hierarchy for the naming convention of any disclosed ingredient. If a name is not available in those systems, then a name from the next listed system shall be used (a generic name is allowed to protect CBI). The order is as follows:
The CSPA Dictionary is a web-based comprehensive technical reference, with over 780 CSPA Dictionary names, more than 3,000 technical or other names and more than 1,000 trade names used by 65 suppliers. The CSPA Dictionary allows for near instantaneous updates and is continually revised to update existing records and to include new ingredients.
I encourage all of you not familiar with the CSPA Consumer Product Ingredient Dictionary to visit www.productingredients.com and consider becoming involved. This is a tool that anyone can subscribe to – not just CSPA members. Yes, the primary purpose of the dictionary is ensuring standard ingredient nomenclature and definitions; however, it is a valuable tool for formulation chemists in R&D, regulatory compliance personnel (you can find information on VOC status, FIFRA 25(b), Proposition 65 listings and other useful information for each chemical). Ingredient suppliers can add ingredients and brand names to be included, making them known to product formulators. With retailers starting or expanding their chemical management programs, and states other than California working on their own ingredient disclosure requirements, this is a tool that makes compliance easier, which is a win for companies and consumers. SPRAY