It seems that a week rarely passes by without news of yet another toxic chemical being found in a consumer product. Whether it's cadmium on a drinking glass, lead in a toy or bisphenol A in a baby bottle, I would think that consumers would be wondering "Why is this happening? What are manufacturers thinking, putting these substances in their products?"
Surprisingly many manufacturers simply don't know the chemicals in their products. Product manufacturers -- especially of products like computers, building products and automobiles -- often don't know the chemicals contained in the materials they use in their products. Extracting chemical ingredient information from complex supply chains is a challenging task that few companies dare to undertake.
Government support for addressing this problem is absent: no state or federal regulation requires disclosing chemical ingredients in products we commonly buy and use everyday (with the notable exception of products regulated by the Food and Drug Administration). The federal law that is supposed to manage the nation's industrial chemicals has not been updated in 34 years, leaving manufacturers unaware of the potential hazards posed by many of the chemicals they rely on.
Since the mid-1980's, chemical producers have been required by the Occupational Safety and Health Administration (OSHA) to provide Material Safety Data Sheets (MSDSs) to their customers on chemical-intensive products to protect workers from the adverse effects of exposure to these substances. MSDSs provide chemical ingredient and health and safety information for the hazardous ingredients. But once these chemicals are incorporated into an article (such as a solid material like plastic), the flow of information stops. This disconnect is due to the thinking that once a chemical is incorporated into a product or bound into a matrix, there is no longer potential for exposure. In many cases, this may be true, but often the manufacturer may not know how the product will be used by the final consumer or how the product will be disposed of at the end of its useful life.
With Congress prepared to reform the Toxic Substances Control Act (TSCA) of 1976, we now have a chance to address chemical ingredient transparency across the supply chain. Over the past 30 years, the science available to evaluate the health and environmental impacts of chemicals has advanced greatly along with consumer expectations for safer chemicals and products. The proposals moving through Congress require a minimum data set on all new and existing chemicals and would have the US Environmental Protection Agency (EPA) determine safe levels based on hazard, exposure and use information. But how will the EPA make these determinations if the downstream users of chemicals and article manufacturers don't have information on the chemicals in their products? And how can manufacturers of articles, consumer products and retailers make informed decisions on the appropriateness of a particular chemical in their product if there is no requirement for them to have this information?
This sharing of chemical information through the supply chain is not new -- any company doing business in the European Union is required to communicate chemical information up and down the supply chain and similar requirements are being considered in many other countries.
Business-to-business communication of chemical-level information down the supply chain through to article and end-product manufacturers is critical for making informed decisions on the health and environmental impacts of the products used by Americans. Having this information during the design stage of the product allows the manufacturer to thoroughly understand and evaluate the full cost of doing business and strategically manage those costs, taking into consideration potential substance restrictions around the world and costs for regulatory compliance, liability and risks. With this information, manufacturers of articles and consumer products would then have the ability to inform consumers if their products contain particular chemicals of concern.
Improving supply chain communication and chemical information sharing will allow for businesses to make informed and cost-effective decisions about the chemicals incorporated into their products, which, will then allow for communication to consumers and end product users.
Dr. Patricia Beattie is a board-certified toxicologist with extensive experience managing chemicals in complex supply chains. She is now Vice President at SciVera, Inc., and also Principal at the independent consulting firm, Arcalis Scientific, LLC.
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