In a regulation-free zone, suppliers need to show leadership

By Bridget Gardner* Green products are defined as “those that have less of an impact on the environment or are less detrimental to human health that traditional equivalents”. So is it illegal to call a product green if it isn’t? Absolutely. Making a false or misleading ‘green’ claim contravenes the Trade Practices Act and is […]
By Bridget Gardner*
Regulation-free green zone
Bridget Gardner
Green products are defined as “those that have less of an impact on the environment or are less detrimental to human health that traditional equivalents”.
So is it illegal to call a product green if it isn’t? Absolutely. Making a false or misleading ‘green’ claim contravenes the Trade Practices Act and is commonly called ‘green washing’. By law a manufacturer must be able to demonstrate exactly how their product reduces risk of harm.
But based on the above definition, with a little creative marketing and a lot of wishful thinking, one could argue that a pH neutral product causes less damage than a corrosive pH2 equivalent, and therefore is ‘green’. And this lack of clarity is causing a great deal of confusion.
The Australian Government sets no regulations for cleaning product design, let alone for green products. It is argued that regulation stifles innovation and that the green rule book is constantly changing anyway as new problems are discovered. But I’m sure a little more leadership from Canberra would be welcomed by manufacturers and consumers alike.
Standards and ecolabels
There are, however, government standards for tests that can determine whether a product (or ingredient) reduces specific environmental or heath problems, such as ready biodegradability. Testing against standards provides third party evidence of low environmental risk. But how many of these standards does a product have to meet in order to call it green? Or put another way, what are the characteristics of a green product?
Ecolabels are voluntary standards that have compiled a list of criteria, standards and tests for ‘environmentally preferred products’, such as the Good Environmental Choice Australia (GECA) Standard for Cleaning Products. GECA also collaborates with international ecolabels such as Green Seal (USA), Blue Angel (Germany) and Environmental Choice New Zealand.
Does that mean that only products certified by an eco label can be called ‘green’? Not necessarily, but it is a more reliable method for the consumer because:
* They do the hard work for us
* A full list of ingredients is required
* All claims must be supported with evidence
* They are comparing apples with apples
An ecolabel standard does have limitations:
* It only applies to chemical cleaning products
* No criteria for sustainable production or ingredients
* The ‘in/out’ system does not rate products or encourage innovation
* It is voluntary (but uptake is growing rapidly)
Green characteristics
Let’s explore then, the ten most important characteristics of a green product, the health and environmental impacts they reduce, and how to tell if a product complies or not.
1. Ready biodegradability: ‘Biodegradable’ is a meaningless term unless qualified as ‘readily’ (quickly). The Australian standard for Ready Biodegradability is AS4351 (1996). Be aware that the claim may only apply to the detergent (surfactant) component which may only be 5% of the whole product. Further, not all detergents are biodegradable. APEO and NPEs found in some pH neutral and laundry detergents are persistent and toxic to fish. Whole product testing or ecolabel certification will ensure the product can break-down rapidly and completely.
2. Low Volatile Organic Compounds: VOCs found in solvents, sealants, air-fresheners and stain removers can cause indoor air pollution. The acceptable level by Green Star1 is less than 50g of VOCs per litre for floor sealants and 5% w/w by GECA for solvents. The level of VOCs can be determined by a laboratory.
3. No ‘chemicals of concern’: Scientists are concerned that some chemicals may cause harm in very low doses; they may accumulate in the body, cause disease years later, or harm unborn babies. Such substances are often called ‘chemicals of concern’ and are either prohibited or restricted (under 0.1%) from ecolables and some cleaning contract procurement guidelines (lists will vary).
Accordingly, many products claim to be ‘free of’ specific chemicals and/or fragrances. To support this claim, the product should either have ecolable certification, declare a full list of ingredients on the MSDS, or provide a signed statement by the manufacturer on request. (Chemicals in concentrations under the NOHSC Hazardous cut-off level do not have to be listed on the MSDS).
4. Renewable: ‘Natural’, ‘organic’, ‘plant-derived’… as these terms have no legal meaning they can be very misleading. The concept is that as many synthetically derived chemicals are associated with disease, plant-based will be safer. But are they? Firstly not all ‘natural’ ingredients are safe – arsenic anyone? Solvents containing high levels of d-limonene (derived from orange oil) can actually be quite hazardous. Another misleading phrase is ‘organic’, which simply means ‘carbon-based’ – an example being benzene – and very different to ‘certified organic’. Finally, palm oil production (commonly used in detergents) is often responsible for de-forestation.
However, green chemistry is an exciting area of science and innovative products made from renewable materials and sustainable production are increasing. The term ‘renewable’ is defined as ‘materials that must be replenished by natural processes at the same rate they are used’. There is no standard for ‘renewable’ so all these claims may be supported with the same evidence as per point 3.
5. Non-hazardous and non-toxic: Does the MSDS state a product is hazardous or not, according to NOHSC criteria? Simple yes or no. However because it is so easy to define it can easily become a red herring. Is a product containing an ingredient 1% lower than the hazardous cut-off level now safe? If wearing gloves could prevent exposure to a hazardous substance stated to be a skin irritant due to being concentrated, and it does not contain ‘chemicals of concern’, I would argue that it is still may be deemed  ‘green’.
‘Non-toxic’ is more difficult to define. Technically, T for Toxic is reserved for VERY toxic, lethal substances. By definition then, 99% of chemical cleaning products sold could be called non-toxic. Toxicity testing (LD50) can be conducted on a range of organisms and impacts: dermal toxicity, rat, daphnia, fish etc. We don’t (fortunately) conduct toxicity tests of humans so these tests are used as an indicator for human health. If you are a chemist you may be able to interpret the results – I can’t. But the fact that a company has voluntarily tested their finished products and released the results means they are supporting their non-toxicity claims and being transparent.
6. No phosphorus: If phosphorus (phosphate) enters freshwater it acts like fertiliser, promoting excessive algae growth that suffocates other aquatic life. This is a bigger issue in the country of origin (e.g. China) due to manufacturing run-off, than where it is used and put down the sewers. However it is still best practice to use detergents with no added phosphorus or low levels, especially where sewage farms are not ocean-based. There are simple and inexpensive phosphorus laboratory tests available to support claims.
7. Chemical-free: True chemical-free methods use water or friction instead of, obviously, chemicals. The benefits are an undisputed elimination of VOCs, ‘chemicals of concern’ and fragrances etc. They can also reduce packaging waste and associated transportation costs. However, they are only ‘green products’ if used and maintained correctly so that a) cleaners do not add traditional chemicals to improve performance and b) they last. Saving money up front buying cheaper brands will be neither financially nor environmentally sustainable long-term.
8. Resource and water minimisation: Chemical, water or packaging minimisation through smarter product design or reuse are also legitimate green innovations. The environmental impact of the huge quantity of cleaning supplies used on an annual basis across Australia must be enormous. Some cleaning equipment suppliers provide ‘calculators’ to support claims of resource savings during use.
9. Recycled content: Other equipment manufacturers have reduced the demand for natural resources by using recycled materials in their design, such as mops, packaging, and paper products. Ensure the content percentage and type of recycled materials is declared on the label.
10. Environmentally sustainable: As with all green initiatives, environmental claims must be supported with third party evidence.

Three key methods are:

*Life-cycle analysis (LCA) calculates the environmental impact of a product’s entire ‘life’, from materials harvest to waste. LCA is conducted by independent bodies using recognised metrics and is very expensive. EcoSpecifier (Australia) has recently launched the Green Tag™ tool that uses LCA to rate products, but no cleaning products have yet been rated.
*Eco foot-printing evaluates how much planet (water, soil, energy etc) a product requires to manufacture and/or use.
*Carbon foot-printing measures the carbon a product emits throughout its life. The Carbon Reduction Label, recently launched in Australia by Planet Ark, provides a credible label for products that have had their carbon footprint certified to international standards.
Green or sustainable cleaning is still in its infancy in Australia and the cleaning industry still lacks regulations, guidelines and compliance from bodies such as the GBCA1. Therefore it is up to suppliers to show leadership and users to demand accountability, as many already have. It is always easier to stay ahead of the ball than play catch-up.

1. Green Star is the environmental building rating system by the Green Building Council Australia (GBCA)
* Bridget Gardner is director of Fresh Green Clean, a consulting and training company in sustainable cleaning and hygiene. She is considered by many as Australia’s leading independent expert in the field.


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