Wanting 4 decimal places in a two decimal place world

Wrestling with the tiger: wanting 4 decimal places in a 2 decimal place world.
I have spent a large amount of time over the last year working on a Technical Advisory Committee within an NGO , striving to help develop a database of "green" ingredients for cleaning product formulators to use. The basic value of such a database for companies like ours, would be as a clearing house of products "pre-approved" by the USEPA's DfE accreditation group. The premise is that if formulators use Cleangredients in their formulations, they can more easily claim that their final products are designed for the environment, within the EPA's definition.This concept sat well with me, as it promotes continuous improvement, eco-efficiency, sustainability, less toxic chemicals in the environment and is a market-based strategy to bring about change, rather than policy driven regulations. These market-based concepts have driven our firm’s efforts for last 15 years or so. Unfortunately, this effort towards producing market based change, has not developed as I had hoped.

Four decimal places in a two decimal place world.

It seems that to qualify, any ingredient to be used in formulation of a green cleaning product, must have a fully existing set of eco-toxicity data. By a full set of data, this means recent laboratory reports of fish, daphnia, algae toxicity, biodegradability, human toxicity, etc. General literature surveys of past work, data summaries by other governmental environmental agencies, reference data for parent compounds, are not suitable sources of data.

Substances that qualify as "green" must have current lab reports even if, they have been in commerce for years and are sited as safe by other nations such as the EU and Japan. Ecological foot print, material mass economics, continuous improvement of processes, pollution prevention potential, etc., are all being ignored… in order to use this process to allow the collection more data.

What became apparent is that for DfE to cover their risk of endorsement, is four decimal places of hard science, when the existing two decimal places of evidence would produce the changes they desire according to their stated mission.

This must sound like sour grapes. Another chemical company trying to skirt responsibility for insuring the chemistry they sell is safe. This is not the case, although I can certainly say that I am soured on this process. We have been redesigning processes and chemistry to be greener since the 1980's, and are starting from a product line that has already been through numerous iterations of "greening". Rocket science is not needed here, just good solid data based on recent studies and historical performance.

This is one of the challenges that company’s face in being out front in the area of sustainable enterprise. The environmental regulator continues to insist on more data, when they have enough to act in a responsible way that could help increase the rate of change through market mechanisms. I guess the US is still waiting for more hard science before acting on global warming, and I guess they will continue to wait for some poor firm to decide its worth the money to run these tests before allowing these chemistries to become "green"...or not?The market will react by dumbing down to the technologies that have the data sets. These data sets do exist for a limited number of commodity surfactants. They are not state of the art, but they are sold in large volumes, so the data exists. Because the data are so costly to produce, and cleaning is not an exact science, products will be produced under this program that is "good enough". Not eco-efficient, but they will be "green" meaning that the data exists and it meets the "standards".

This happened before with "green" products in the 1970's and we got poorly performing green products from companies that have long since gone out of business. The bottom line here is that the potential exists for non-green products to have a better ecological footprint through eco-efficiency than the fully tested, mediocre performers.When a regulator, rather than the marketplace, decides to set a technology or performance standard, look out for mediocrity. Government can produce policy to move market performance but in my opinion government cannot set market standards. The market performs based on consumer behavior. Our government cannot "yet" dictate that. Deciding what product or technology will lead in any market remains the province of the consumer.

In this case the product can be as green as a gourd, and no one buy it. I think it is humorous that this is not well understood at the government level.So, where this is all moving is to further complicate, via regulation, our US markets. This provides an advantage for competitors who do not reside in this country or who just lie about what they are doing and can avoid scrutiny. Meanwhile, we the small businesses that produce a huge share of the innovation, must suffer a huge disincentive, rather than obtain a big dividend from sustainable behavior.

I always remind myself that the best video tape technology was beta-max and no body bought one. The market alone decides what the standards will be.

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