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Cleaning product ingredient safety – What is the current state of availability of information regarding ingredients in products and their function? Paul C. DeLeo, Michael Ciarlo, Courtney Pacelli, William Greggs, Edward Spencer Williams, W. Casan Scott, Zhen Wang, and Bryan W Brooks ACS Sustainable Chem. Eng., Just Accepted Manuscript • DOI: 10.1021/ acssuschemeng.7b03510 • Publication Date (Web): 20 Dec 2017 Downloaded from http://pubs.acs.org on December 28, 2017
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Cleaning product ingredient safety – What is the current state of availability of
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information regarding ingredients in products and their function?
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Paul C. DeLeo, American Cleaning Institute, 1331 L Street, N.W., Suite 650, Washington, DC
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20005, USA Michael Ciarlo, EA Engineering, Science, and Technology, Inc., PBC, 225 Schilling Circle Suite 400, Hunt Valley, MD 21031, USA Courtney Pacelli, EA Engineering, Science, and Technology, Inc., PBC, 225 Schilling Circle Suite 400, Hunt Valley, MD 21031, USA William Greggs, Soleil Consulting, 4195 Dingman Drive, Sanibel, FL 33957, USA Edward Spencer Williams, Department of Environmental Science, Baylor University, One Bear Place #97266, Waco, TX 76798, USA W. Casan Scott, Department of Environmental Science, Baylor University, One Bear Place #97266, Waco, TX 76798, USA Zhen Wang, Department of Environmental Science, Baylor University, One Bear Place #97266, Waco, TX 76798, USA Bryan W. Brooks, Department of Environmental Science, Institute of Biomedical Studies,
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Environmental Health Science Program, Baylor University, One Bear Place #97266, Waco,
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TX 76798, USA
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Corresponding Author
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Paul C. DeLeo, Ph.D.
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Principal
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Integral Consulting Inc.
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200 Harry S. Truman Parkway, Suite 330
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Annapolis, MD 20401
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(410) 573-1982
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[email protected] 28 29
Keywords: read-across, hazard assessment, exposure assessment, risk,
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ABSTRACT
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In the present study, we aimed to define and report the universe of ingredients used in consumer
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cleaning products in the United States. To develop exposure estimates associated with the use of
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these cleaning product ingredients, an inventory was developed using data provided publicly by
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product formulators. The inventory included compilation of product uses, ingredient names, and
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ingredient uses for over 13,000 ingredient listings from over 1,000 products surveyed. Ingredient
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listings were consolidated to produce the Ingredient Inventory, a list of 588 unique name-CAS
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registry number combinations. Ingredients were associated with specific product uses. For each
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ingredient in the inventory, chemical class and function were researched. Ingredient functions
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were defined in terms of functional-use classes (FCs). Existing FC lists provided by EPA’s Safer
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Choice Program, EU REACH, INCI Dictionary, manufacturer websites and other sources were
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reviewed and FCs from each source compiled and compared. FC naming conventions and
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assignments were then harmonized with the recently developed OECD Functional Use Category
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listings. This study presents the methods used to create the inventory, determine the appropriate
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FC(s) for each ingredient and fill data gaps using alternate sources and read-across. It further
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presents trends in ingredient occurrence across both FCs and broad cleaning product types,
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i.e. laundry care, dish care, hard surface cleaners, as well as the distribution of FC types within
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product types. This unique inventory of cleaning product ingredients
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(http://www.cleaninginstitute.org/science/ingredients_and_assessments.aspx) is hosted by the
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American Cleaning Institute, an industry trade association that represents the formulators of
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more than 90% of the consumer cleaning products in the United States. Such publicly available
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data can now be used for future hazard assessments, and when coupled with associated exposure
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assessments, employed to support screening-level risk assessment of ingredients in cleaning
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products as a baseline to better quantify the sustainability of consumer cleaning products in the
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United States.
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INTRODUCTION
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There has been a great desire among a number of stakeholders to improve access to data
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regarding the safety of chemicals in commerce in recent decades. The U.S. Environmental
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Protection Agency’s (USEPA’s) 1998 Chemical Right-to-Know Program helped to spawn a
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global initiative to increase transparency of safety data for high production volume (HPV)
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chemicals (i.e., produced at more than 1,000,000 pounds annually) reflecting public concern with
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chemical management known as the HPV Chemical Challenge Program. Simultaneously, the
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global chemical industry announced its intention to work with Organization of Economic
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Cooperation and Development (OECD) on a working list of approximately 1,000 high volume
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substances as priorities for investigation. The member companies of the American Cleaning
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Institute (ACI; formerly the Soap and Detergent Association), which include manufacturers of
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institutional and consumer cleaning products and the suppliers of associated ingredients,
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sponsored important cleaning product ingredients under these programs. ACI initially sponsored
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291 chemicals in 10 different chemical categories (based on chemical and structural similarity)
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with a total global market volume of nearly 10 billion pounds (1999 values). Ten consortia for
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the chemical categories were organized with representation from 62 companies including many
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members of global partner industry groups. ACI was uniquely suited to lead this effort having
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members from the manufacturers of the chemical ingredients as well as formulators of finished
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cleaning products (i.e., up- and down-stream in the value chain).
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The primary objective of the HPV chemical program was to have a screening information data
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set (SIDS) dossiers completed for each chemical. A number of innovative non-testing
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approaches were used to fill data gaps including application of the read-across approach where
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endpoint information for one chemical (the source chemical) is used to predict the same endpoint
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for another chemical (the target chemical), which are considered to be sufficiently similar. In
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addition, ACI conducted human and environmental exposure assessments and screening level
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risk assessments for the chemicals they sponsored. Additionally, peer-reviewed journal articles
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were published regarding the hazard data, exposure assessment and screening level risk
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assessment for the categories of alkyl sulfates, alkane sulfonates and α-olefin sulfonates,1,2 amine
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oxides,3,4 hydrotropes,5 and long chain alcohols6,7,8,9,10 used in consumer cleaning products. Also,
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Stanton and Kruszewski11 quantified the benefits of the HPV Chemical Challenge Program for
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those chemicals sponsored by ACI with respect to avoided test animal use (100,000 to 150,000)
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and avoided expenditures ($50,000,000 to $70,000,000).
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More recently, manufacturers of consumer cleaning products have been nearly universally
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publicly disclosing ingredients used in their products. With the advent of widely available
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product ingredient information coupled with the experience in developing hazard, exposure and
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screening level risk information for chemicals in cleaning products, ACI established its Cleaning
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Product Ingredient Safety Initiative (CPISI) in 2011. The goal of the program was to provide a
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single Internet-based location for publicly available human safety data for every chemical
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ingredient used in every formulated consumer cleaning product manufactured by ACI members
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including a summary of available human hazard data, an exposure assessment and a screening-
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level risk assessment. A key component of the CPISI was the identification of the function for
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each ingredient. Understanding function is important for both communication and exposure
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assessment. In terms of communication, consumers are interested in ingredient function as an
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indicator of its necessity for inclusion in products they use.
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The primary purpose of the present study is to review the experience associated with the
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development of the CPISI Ingredient Inventory and the subsequent information generated. More
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specifically, we review the methods used to compile an inventory of cleaning product types,
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ingredients, chemical categories, and FCs. We then analyze trends relating product use,
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ingredient, chemical category, and FC with specific focus on the availability of function data. In
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addition, in this and the accompanying paper, we demonstrate the extent to which chemical
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human safety data have been made available by the cleaning products industry and show how it
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may be used to communicate the (minimal) risks associated with proper use of the products.
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METHODS
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The CPISI Ingredient Inventory consists of relatable databases developed in sequence. The first
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database was compiled to relate products to manufacturer ingredient listings, including the
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capture of any concentration, function, or chemical category data provided by the manufacturer.
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The second database was compiled to cross reference naming conventions, provide information
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on chemical category and structure, and resolve duplicate, overlapping, or non-specific names.
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The third database constituted a final list of ingredient identifiers, including FC and chemical
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category assignments.
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Product-Ingredient Database Development
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To develop a database relating product types to ingredients, a review was performed of
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member company product ingredient listings. Each manufacturer’s website was surveyed to
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identify laundry care, dish care, and hard surface cleaning products intended for consumer
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home use in the United States. This review was facilitated by web resources developed as
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part of ACI’s Consumer Product Ingredient Safety Initiative, which served as a central hub
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for accessing member sites. Surveys of 13 different manufacturers were conducted and
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1,093 products were evaluated. These surveys were completed between January and
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November of 2012.
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An initial pilot survey was performed in which data for approximately 20 individual products
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was compiled. Based on this pilot, data fields were re-evaluated, expanded, and redefined to
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facilitate data capture. Each product was assigned to a standardized product sub-types to
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facilitate exposure modeling as part of subsequent steps of the CPISI. Product types were defined
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based on general use (i.e. dish care, fabric care, all-purpose cleaners, etc.), specific use (i.e.
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machine dish detergent, laundry booster, etc.), and product form (i.e. liquid, tablet, spray, etc.).
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Information regarding product use was typically available from manufacturer descriptions of the
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product from member company websites. A standardized list was developed based on pilot
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surveys and expanded when new product types were encountered. This produced a total of 36
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product sub-types, which are presented in Table 1.
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The survey was expanded beyond the pilot data set to encompass a broad range of product uses
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within laundry care, dish care, and all-purpose/hard-surface cleaning; however, it was limited to
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formulated consumer products, and thus durable articles such as scrub brushes and sponges were
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not included. Commercial and industrial cleaning products were not included, nor specialty
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cleaning products that are not represented by ACI such as oven and jewelry cleaners.
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Additionally, products that are classified as disinfectants or sanitizers under the Federal
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Insecticide, Fungicide and Rodenticide Act (FIFRA) were generally excluded as US EPA
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provides a risk assessment framework under FIFRA independent of the goals of CPISI.
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However, some disinfectant products were ultimately included in the survey as the nature of a
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particular product may not have been immediately obvious at the time it was initially reviewed.
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For each product, listed ingredient names were recorded. Manufacturers web sites differed in the
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way ingredients were listed for each product. In some cases, ingredient names were provided as a
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list, while in others they were available from product Safety Data Sheets (SDS). In some cases,
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additional information such as Chemical Abstract Service (CAS) registry numbers, ingredient
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function, and/or ingredient concentration range were available from the listing. In a small
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number of cases, additional information was obtained directly from the manufacturer by request.
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In total, ingredients from 1,093 surveyed products made by 13 manufacturers distributed over all
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36 product sub-types was the initial source data. The initial list of products and ingredients
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totaled over 13,000 entries.
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Ingredient Naming Cross Reference
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Once data were compiled, a series of queries were used to consolidate naming conventions.
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Many ingredients are used in more than one product, so many of the 13,000 entries that formed
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the initial list were repeats of the same ingredient name.
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approximately 1,000 unique listed ingredient name-CAS combinations. In many cases,
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ingredient names were duplicative, overlapping, or general in nature. As such, a series of steps
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were taken to standardize chemical naming/identification and product use/ingredient function.
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The first step in data consolidation was to identify synonyms and broad or mutually inclusive
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chemical naming. Some of the same ingredients are listed by different manufacturers using
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different names, while other ingredients are listed by a general name that could describe more
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than one unique chemical. Each listed ingredient was reviewed and one or more common names
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were assigned using naming conventions from trade literature and chemical nomenclature.
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Ingredients identified as durable articles such as wool, polyester or fabric, which might be part of
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the delivery device for the cleaning formulation, were removed from the database. Where
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ingredients were identified by generic names or by chemical category names, they were replaced
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by more specific ingredient names. To be as inclusive as possible, it was assumed that any of the
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chemicals represented by a generic name or included in a chemical category could be used in
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those products. Past studies,1-12 other inventories, and trade literature provided sources of lists of
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more specific ingredient names that could be used for generic names and chemical categories.
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Where ingredients were listed by manufacturers with a CAS registry number or European
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Community Number (ECN), these were used to inform naming. In cases where a CAS number
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was not available, one was assigned based on searches of the listed name in the Toxic Substances
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Control Act Chemical Substance Inventory (TSCA Inventory), International Cosmetic Ingredient
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Dictionary and Handbook (Gottschalck and Breslawec 2012; aka International Nomenclature of
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Cosmetic Ingredients (INCI) Dictionary), European Chemical Agency (ECHA), U.S. National
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Library of Medicine Toxicology Data Network (TOXNET), Cosmetic Ingredient Review (CIR)
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and other databases. Final CAS assignment was limited to CAS utilized in the United States as
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listed under inventory compiled by US EPA under the Toxic Substances Control Act (TSCA). In
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cases where a CAS number could not be reliably assigned, a project specific identifier was
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assigned. Some of the ingredients included in the Ingredient Inventory were not specifically
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listed on consumer cleaning products; however, due to their potential for representation by more
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generalized naming conventions, they were added to the Inventory. This includes naming
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conventions derived from ACI and International Fragrance Association (IFRA) compilations.12,13
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The consolidation and standardization of naming required multiple refinements over the course
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of the CPISI effort as new information was obtained regarding composition of specific listed
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ingredients. Naming standardization and consolidation resulted in a final list of 588 unique
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chemicals. In most cases, those chemicals are represented by a unique name-CAS combinations.
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However, in the case of some of the proprietary materials, a trade name was used.
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Functional-Use Class (FC) and Chemical Category Assignment
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The final Ingredient Inventory comprised 588 unique ingredients. Each unique ingredient was
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assigned a tracking code, chemical category, and FC. Chemical category was assigned to aid in
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identifying any additional ingredients necessary to represent general naming conventions;
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improve use of read-across in searching for hazard data as part of later stages of CPISI, and to
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aid in assigning FC. Chemical categories were entered when listed by the manufacturer.
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Additional category assignments were made based on previous studies;1-12 review of sources
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such as the EPA and OECD HPV chemical programs, Human and Environmental Risk
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Assessment on ingredients of household cleaning products (HERA),18 TOXNET Hazardous
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Substances Data Bank (HSDB);14 and general review of chemical structure. Categories were
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updated throughout the course of CPISI as new information was obtained regarding ingredient
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identity; the inventory currently includes 49 chemical categories and 1 category for unassigned
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ingredients.
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FC was assigned to each ingredient using a multi-step process. In some cases, manufacturers
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included an indication of ingredient function with their product-ingredient listings. This was
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recorded and given priority as an indicator of function. Function information was also collected
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from reliable existing databases and studies were used to collect function information for each
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ingredient. These sources included the USEPA’s SaferChoice website;15 the INCI Dictionary;16
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the Consumer Specialty Products Association (CSPA) Consumer Product Ingredients
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Dictionary;17 the International Fragrance Association (IFRA) Transparency List;13 and past
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studies3 and the HERA project.18
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To assign a FC, function information was reviewed across sources. FC names were standardized
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based on the recently published OECD list of harmonized functional use categories.19 When
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selecting a FC, priority was given to functions stated by the manufacturer unless the stated
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function was overly broad. In some cases, ingredients perform multiple functions and thus
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several were assigned. Where data gaps existed, a read-across approach was used to assign a FC
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to ingredients with a similar composition or chemical structure. This was based in part on
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chemical category. This approach provided a FC assignment for each ingredient on the
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Ingredient Inventory.
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RESULTS
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The Ingredient Inventory consists of 588 ingredients derived from an initial review of over 1093
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products from 36 product sub-types.
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information are publicly available on a website maintained by the American Cleaning Institute
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(www.cleaninginstitute.org\cpisi). While the focus of the survey was cleaning products sold in
The Ingredient Inventory and related human safety
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the United States, the results of this work have global relevance as many of the cleaning product
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manufacturers have a global presence with similar formulations sold in other geographies. In
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addition, the chemicals used to formulate the U.S. products are used globally and the safety
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information, in particular the hazard information, are globally available and in many cases were
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derived from global sources (e.g., OECD HPV Chemical program, EU REACH).
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Trends in Product Sub-Types
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The number of products offered by surveyed manufacturers varied from a minimum of 27 to a
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maximum of 280 including flankers, that is, all of the fragrance or specialty function variants of
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a branded product. Of 13 manufacturers, nine provided products in each of the broad product
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type (fabric care, dish care, all-purpose cleaners), three provided only fabric care and all-purpose
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cleaning products, and one provided only fabric care products.
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Of the 1093 products evaluated, the greatest number (618 products) are associated with fabric
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care (see Table 1). Over half of fabric care products are identified either as liquid detergents
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(43%) or powered detergents (22%). Liquid conditioners (21%) and dryer sheets (8%) account
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for most of the remainder, with other fabric care products such as bar detergent, bleach, pre-
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treatments, and tablet detergents constituting a small proportion (6%) of the total; however, at the
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time of the survey, unit-dose laundry products such as liquid laundry packets were just being
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introduced into the market but have gained rapid acceptance such that their proportion would
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likely be much higher were a similar survey conducted today. All-purpose cleaners are the next
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most abundant product type (304 products). These include liquid sprays (35%), hand wash
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liquids (34%), hand wash wipes (13%), aerosol sprays (8%), hand wash gels (6%), and hand
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wash powders (4%). Dish care products included 171 labels dominated by hand wash liquids
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(73%) followed by automatic dishwasher liquids (11%), tablets (10%), and powders (4%).
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Liquid rinse aids and pot and pan cleaners make up the remaining 3%.
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Trends in Ingredient Occurrence
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Of the 588 inventory ingredients, the greatest diversity was found in all-purpose cleaning product
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types (353 ingredients; see Figure 1). Almost as many (343 ingredients) was observed in fabric
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care products, and a smaller number (236 ingredients) were found in dish care products. There
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was significant overlap in ingredient use between product type, with 230 ingredients (39%)
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found in two or more product types, and 114 ingredients (19%) shared among all three product
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types. There were also a significant number of ingredients unique to individual product types:
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153 for all-purpose cleaners (26%), 137 for fabric care (23%), and 68 for dish care (12%). The
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ingredients used most frequently included common enzymes, surfactants, salts, acids, and bases.
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Figure 1 Number of individual ingredients identified in three product types of cleaning products
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The mean number of ingredients listed for an individual product varied by FC. Dish
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care products displayed the highest mean number of ingredients per product with 14.5 (sd = 8.6),
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ranging from a minimum of 2 to a maximum of 31. Fabric care products had a mean number of
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ingredients per product of 13.1 (sd = 9.1) with a range of 1 to 43, while all-purpose cleaners had
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a mean of 9.4 (sd = 4.7) ingredients and a range of 1 to 25 (Figure 2). Of specific product sub-
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types, machine-wash laundry detergents (liquid and powder) and hand wash liquid dish
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detergents had the highest mean number of ingredients, while bleach and laundry bar soap had
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the lowest.
Mean
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Figure 2. Mean number of ingredients per product for major cleaning product type
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Trends in Ingredient Naming
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A number of trends were identified during the process of naming consolidation. The majority of
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listed ingredient names were comparable to or consistent with names and CAS registry numbers
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available from publicly available compendia. Names that were not readily associated with a
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specific name and CAS fell into three categories: general names, stylized names, or
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proprietary/trade names. Ingredients within the alcohol ethoxylates chemical category provide a
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useful example. Over 1,000 of the 13,000 initial entries indicated the inclusion of an alcohol
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ethoxylate in a product, with 50 different naming conventions and 20 different CAS (including 16
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no CAS listed). Of these, 13 constituted general names such as “ethoxylated alcohols” or
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“secondary alcohol ethoxylate.” In some cases, names were listed with a CAS for a more specific
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ingredient name, and in others they were not. An additional 36 provided names that specified
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chain length or otherwise provided a more specific information regarding which particular
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alcohol ethoxylates were included (e.g., C12-C14 alcohol ethoxylate). Many of these entries
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could be associated with specific CAS. However, some consisted of trade names (e.g., C12-15
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Pareth-9) that were difficult to associate with specific CAS. One additional ingredient had a
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proprietary name that was later learned to refer to an alcohol ethoxylate.
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Relationship between Ingredients and Chemical Category
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Ingredients were assigned to one of 49 chemical categories based primarily on chemical structure
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though occasional FC were included to permit most ingredients to be categorized. These are
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shown in Figure 3. Of the 588, a total of 72 ingredients (12%) were proprietary or unique
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compounds that did not fit a larger grouping. The most populous chemical categories (22) with
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greater than ten occurrences across the broad cleaning product types include (in descending
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order) glycerides, colorants, aliphatic acids and salts, inorganic acids and salts, alcohol
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ethoxylates, quaternary ammonium compounds, ethers, polycarboxylates, chelating agents,
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sulfonic acids and sulfonates, alcohol ethoxysulfates, aliphatic hydrocarbons, amine oxides,
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polyols, alkyl sulfates, alkyl polyglycosides, fatty nitrogen derived amides, enzymes,
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carbohydrates, silicates, botanicals and alkanolamines. In addition, there were two large
314
groupings of chemicals that were not amenable to categorization (“unassigned” and “insoluble
315
solids”) with greater than ten occurrences among the broad cleaning product types. The
316
frequency of occurrence of the chemcicals in the most populous categories is found in Figure 3.
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140
Laundry Care Products
120 NUMBER OF OCCURRENCES OF A CHEMICAL CATEGORY
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47
318 319
Dish Care Products 100
All purpose cleaners 80 60 40 20 0
CHEMICAL CATEGORIES Figure 3. Number of occurrences of ingredients in each chemical category within broad cleaning product types.
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320
More than 87% of the ingredients with more than ten occurrences among the broad cleaning
321
product types fall into one or more of these chemical categories or groups.
322 323
Relationship between Ingredients and FC
324
To assign FC for each ingredient, review was conducted of numerous sources. Sources varied in
325
the number of ingredients for which they provided FC
326
information; number of assignments per source is shown in Figure 4. Function information
327
differed between sources in terms of nomenclature and degree of specificity. The INCI
328
Dictionary provided function information for the greatest number of ingredients (293) followed
329
by the CSPA Dictionary17 (252). There was significant overlap in the function – ingredient
330
assignment provided these sources.
INCI
293
CSPA Data Source
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60
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252
SCIL
228
CPISI
202
IFRA
180 0
50 100 150 200 250 300 Number of Ingredients from Database with Listed Function
350
331 332
Figure 4. Summary of sources for FC information (INCI = INCI Dictionary; CSPA = CSPA Dictionary;
333
SCIL = U.S. EPA SaferChoice/Safer Chemical Ingredient List; CPISI = ACI Cleaning Product 19
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334
Ingredient Safety Initiative product survey; IFRA = IFRA Transparency List;)
335 336
FC nomenclature differed between sources both in specificity and relevance to cleaning
337
products. OECD and US EPA SaferChoice/Safer Chemicals Ingredient List (SCIL)
338
nomenclature focused primarily on a small number of broad, highly standardized FCs, with each
339
ingredient associated with a smaller number of broad functions. The OECD harmonized
340
functional use categories offers detailed definitions for each function and goes further to include
341
synonyms within many functions (e.g. pH regulating agent also referred to as buffering agent,
342
pH adjuster, neutralizing agent). INCI Dictionary and CSPA Dictionary provided a more diverse
343
set of categories that were, in some cases, more detailed, and often assigned multiple functions to
344
an individual ingredient. For example, for many alcohol ethoxylates, alcohol alkoxylates, and
345
alcohol ethoxysulfates, both SCIL and OECD include “Surfactant” as the only listed function.
346
CSPA included the term “Surfactant” as part of function names, but further specified for each
347
surfactant whether the purpose is as a cleaning agent, emulsifying agent or solubilizing agent,
348
and whether the surfactant was anionic or ionic. The INCI Dictionary used the term “Surfactant”
349
but often included other listed functions such as cleansing, emulsifying, and foaming that
350
expanded the functional characterization. These trends were apparent across other functions as
351
well. It is important to note that in some cases INCI included FCs that were not necessarily
352
relevant to cleaning products, e.g., hair conditioner.
353 354
Of 588 ingredients, 293 were assigned FC based on results from one or more publicly available
355
information sources (e.g. SCIL, ACI, etc.). Specifically, 158 were assigned based on information
356
provided in formulator listings, whereas 137 were assigned FC based on some degree of read20
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357
across. Read-across is the process of reviewing information for closely related chemicals, i.e.
358
chemicals with a comparable structure. FCs were largely standardized based on OECD guidance;
359
in a small number of cases, formulator FCs that did not have a comparable OECD category were
360
utilized when other information was lacking.
361 362
Ingredients were assigned one or more of 41 FCs, with some ingredients assigned two or three
363
FCs. See Table 2 and Figure 5. Over 80% of ingredients fall within 10 major FCs. These
364
classes include surfactant, fragrance, dye, viscosity modifier, solvent, chelating agent, pH
365
regulating agent, opacifier, abrasive, and biocide. Trends were relatively consistent across
366
product types for these ingredients. The most common functions were shared between product
367
types. Many less common functions were found in only one or two product types. There was
368
overlap among ingredient use between categories. The number of chemical categories
369
represented in each FC closely reflected the number of ingredients per FC. Surfactants included
370
representatives of 20 different chemical categories, followed by fragrances (8), solvents (7),
371
viscosity modifiers (7), and chelating agents (7). Most FCs spanned 3 chemical categories or
372
fewer.
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140
All Purpose Cleaners
120
Dish Care Products 100
Laundry Care Products
80 NUMBER OF INGREDIENTS
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47
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60
40
20
0
FUNCTIONAL-USE CLASS (FC) 373 374
Figure 5. Number of ingredients of each FC within broad product types 22
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375
DISCUSSION
376
As part of the current review effort, we developed the Ingredient Inventory as part of the CPISI,
377
which demonstrates the ability to use publicly available information to identify much of the
378
universe of ingredients used in household cleaning products. The Ingredient Inventory and
379
associated safety information are housed on a single web portal
380
(www.cleaninginstitute.org/cpisi) to provide a one-stop shop for those seeking to utilize the data.
381
The size of this Inventory is large but appears manageable for purposes of supporting exposure
382
assessment, hazard assessment, and screening level risk assessment. The current study further
383
demonstrates that it is possible to readily assign chemical categories and FCs for the majority of
384
ingredients from publicly available sources. This inventory provides a relatively high degree of
385
specificity and completeness regarding the specific ingredients utilized and their function. While
386
a small number of ingredients were proprietary, most could be characterized in terms of function
387
based on information from the manufacturer.
388 389
Ingredient Naming
390
One of the more substantial challenges associated with compiling the inventory was
391
standardization of ingredient identifiers. Listed ingredients varied by manufacturer in terms of
392
specificity and nomenclature. Despite the variation, the vast majority of names could be readily
393
associated with standardized ingredient names and/or CAS numbers. In some cases, listed
394
ingredient names that were general could potentially be associated with multiple ingredients. A
395
small subset of ingredients was identified as proprietary and could not be related to standardized
396
names.
397
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398
Products and Ingredients
399
In terms of product types surveyed, fabric care accounted for the greatest number of products,
400
followed by all-purpose cleaners and then dish care. Fabric care was also associated with the
401
broadest array of product forms, uses, and flanking brands, which likely accounts for the
402
diversity of products. The number of ingredients used in each product varied, with a majority of
403
products containing less than 10 listed ingredients.
404 405
Chemical Categorization
406
Assignment of chemical categories proved useful for read-across assignment of FC. Guidance
407
for assigning chemical categories19 is useful but leaves a broad range of possibilities for choosing
408
a naming framework. As such, defaulting to systems used by past studies3,21 proved essential to
409
efficient and effective naming, as did frequent reviews and re-assignments as new data were
410
collected throughout the course of the project. Ingredients fell into a broad range of chemical
411
categories, requiring use of 48 groupings as well as an “ungrouped” category. The top twenty
412
categories accounted for only 62% of the ingredients, which reflects the diversity of categories
413
across all 588.
414 415
Functional-Use Class (FC) Assignment
416
FC was identified as important for the project early on because of consumer interest level in why
417
specific ingredients are used; interest among stakeholders in identifying sustainable alternative
418
ingredients for substitutions; and the potential for use of frame formulas in determining
419
ingredient concentration as part of exposure assessment. This study demonstrates that FCs can be
420
readily assigned to commonly used ingredients based on publicly available data.
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421 422
Publicly available sources provided FC information for over two-thirds of inventory ingredients.
423
FCs for the remaining ingredients were readily assigned based on read-across informed by
424
chemical structure. In a small number of cases, ingredients were identified as proprietary and
425
functional use information was obtained from the manufacturer. Different public data sources
426
provided different specific nomenclature for FC dependent upon the scope and nature of the
427
source. Manufacturer listings provided directly relevant data, but were limited to a small subset
428
of manufacturers who provide function data per product. Manufacturer listings also varied in
429
terminology. The INCI Dictionary and CSPA Dictionary provided the most comprehensive
430
treatment of function for listed ingredients, using detailed and extensive systems of
431
nomenclature. However, some functions were not necessarily relevant to cleaning products. No
432
individual data source addressed all of the ingredients on the Ingredient Inventory, and there
433
were many overlaps in the ingredients addressed between data sources.
434 435
For assigning FC, the OECD naming framework was useful because nomenclature was
436
consistent with the level of specificity utilized in frame formulas and relevant to a general
437
understanding of ingredient purpose. Since no one source addressed all inventory ingredients,
438
and since some sources listed more functions than others, effective assignment of FC required
439
review of functional information across sources.
440 441
A small number of FCs account for most ingredients. These include surfactants, fragrances, dyes,
442
viscosity modifiers, solvents, chelating agents, pH regulating agents, opacifiers, abrasives, and
443
biocides. The number of chemical categories represented in each FC closely reflects the number
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444
of ingredients per FC. These trends were the same across fabric care, dish care, and all-purpose
445
cleaning products. Among cleaning products, surfactants include the greatest diversity of
446
chemical categories, followed by fragrances, solvents, viscosity modifiers, and chelating agents.
447 448
Implications for Risk Assessment
449
The objectives of the CPISI included development of the current Ingredient Inventory, and
450
subsequent exposure assessment, hazard assessment, and screening level risk assessment. As
451
such, the experience and results of developing the Ingredient Inventory are relevant not only to
452
these other efforts but to consumer product risk assessment efforts in general. First, the effort
453
demonstrates the ability to derive a concise set ingredients associated with distinct product uses
454
based on publicly available information. The ability to identify specific ingredients was key to
455
compiling relevant hazard data from public sources, and the ability to associate these ingredients
456
with specific products was key to exposure assessment as each product type is associated with
457
specific habits, practices, and exposure routes/levels. The ability to assign and refine chemical
458
categories was important for efforts to collect hazard data. Chemical categories were used to
459
inform read-across to identify hazard data in cases where direct data were otherwise lacking.
460 461
The assignment of FCs will be key to future exposure assessments of cleaning product
462
ingredients. Exposure assessment requires estimation of ingredient concentration per product
463
type. In cases where ingredient concentration data were unavailable from formulator data
464
sources, frame formulas from cleaning product trade literature can be used to estimate ingredient
465
concentrations. These frame formulas provide information regarding typical range of
466
concentration per product use in terms of ingredient function; thus, function can serve a key
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purpose for future ingredient exposure estimates.
468 469
CONCLUSIONS
470
We were successful in identifying ingredient information for consumer (household) cleaning
471
products using publicly available sources, typically voluntarily provided by the product
472
manufacturer on one of their websites. In the near future, such information will be required by
473
law for cleaning products sold in the U.S.22 Though the focus of our survey was consumer
474
cleaning products sold in the U.S., there is global relevance to the outcome as cleaning product
475
manufacturers and ingredient suppliers are serving global markets as is evidenced by the fact that
476
much of the ingredient safety information was derived from global sources (e.g., OECD HPV
477
chemical program, EU REACH).
478 479
While product manufacturers have used a standardized approach regarding the ingredient
480
identity information that is typically reported,20 there is variability. In addition, the nomenclature
481
used to identify ingredients is generally intended for commercial purposes (e.g., formulating
482
products) rather than public health purposes (e.g., understanding hazards and risks). While this
483
may pose some challenge to drawing public health conclusions, we found we were able to make
484
those connections. The convergence of commercial and public health interests in this area is
485
rapidly evolving.
486 487
Regarding ingredient function information, such information has not been included in voluntary
488
initiatives and is not reported as frequently. However, there appears to be a trend towards
489
increased inclusion of such information as more stakeholders are questioning the necessity of
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490
ingredients in consumer products. Though the focus on ingredient function in the public health
491
literature is a relatively recent phenomenon, it has suffered from some inconsistencies as source
492
information is not always readily available or require interpretation. Product manufacturers’
493
source information is often presented on websites that are geared towards their consumers and,
494
as such, they need to use terminology that is accessible to a broad audience. Commercial
495
terminology may not be suitable for consumers; therefore, it may be necessary for the public
496
health researcher to translate terminology in their research. We have found this is not a difficult
497
task. However, we would simultaneously recommend that public health and environmental
498
researchers familiarize themselves standardized ingredient function nomenclature such as those
499
found in the INCI Dictionary or the OECD Internationally Harmonized Functional Categories.
500 501
These are exciting times for consumer product manufacturers, their customers and other
502
stakeholders as there is unprecedented interest regarding the ingredients in products, their
503
functions, and better understanding their human and environmental safety profiles.
504
Manufacturers are responding by providing such information, which affords unique opportunities
505
for independent public health and environmental researchers to test hypotheses that products in
506
commerce are safe for consumers and the environment when used as intended.
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507
Acknowledgements
508
This work was funded solely and entirely by the American Cleaning Institute.
509 510
Conflict of Interest
511
The authors were compensated for their work as permanent employees or through contract with
512
the American Cleaning Institute.
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sulfonates, and α-olefin sulfonates. Ecotoxicol. Environ. Saf. 74: 1089-1106. DOI:
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10.1016/j.ecoenv.2011.02.007.
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Sedlak. 2009. High Production Volume Chemical Amine Oxides [C8–C20] Category
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(5) Stanton, K., C. Tibazarwa, H. Certa, W. Greggs, D. Hillebold, D. Woltering, R. Sedlak.
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019.1.
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(6) Sanderson, H., S.E. Belanger, P.R. Fisk, C. Schäfers, G. Veenstra, A.M., Nielsen, Y. Kasai,
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A. Willing, S.D. Dyer, K. Stanton, R. Sedlak. 2009. An overview of hazard and risk
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assessment of the OECD high production volume chemical category – Long chain alcohols
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[C6-C22] (LCOH). Ecotoxicol. Environ. Saf. 72: 973-939. DOI:
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10.1016/j.ecoenv.2008.10.006.
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(7) Fisk, P., R.J. Wildey, A.E. Girling, H. Sanderson, S.E. Belanger, G. Veenstra, A. Nielsen,
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alcohols. Part 1: Physicochemical, environmental fate and acute aquatic toxicity properties.
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Ecotoxicol. Environ. Saf. 72: 980-995. DOI: 10.1016/j.ecoenv.2008.09.025.
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(8) Schäfers, C., U. Boshof, H. Jürling, S.E. Belanger, H. Sanderson, S.D. Dyer, A.M. Nielsen,
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A. Willing, K. Gamon, Y. Kasai, C.V. Eadsforth, P.R. Fisk, A.E. Girling. 2009.
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Environmental properties of long-chain alcohols, Part 2: Structure–activity relationship for
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chronic aquatic toxicity of long-chain alcohols. Ecotoxicol. Environ. Saf. 72: 996-1005.
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(9) Belanger, S.E. H. Sanderson, P.R. Fisk, C. Schäfers, S.M. Mudge, A. Willing, Y. Kasai,
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A.M. Nielsen, S.D. Dyer, R. Toy. 2009. Assessment of the environmental risk of long-
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10.1016/j.ecoenv.2008.07.013.
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(10) Veenstra, G., C. Webb, H. Sanderson, S.E. Belanger, P. Fisk, A. Nielsen, Y. Kasai, A.
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Willing, S. Dyer, D. Penney, H. Certa, K. Stanton, R. Sedlak. 2009. Human health risk
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silico techniques to fulfill hazard data requirements for chemical categories. Regul. Toxicol.
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(12) Sanderson, H., Greggs, W., Cowan-Ellsberry, C., DeLeo, P., and R. Sedlak. 2013.
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Collection and Dissemination of Exposure Data Throughout the Chemical Value Chain: A
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1013.
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(13) International Fragrance Association (IFRA). 2011. IFRA Transparency List. Available at: http://www.ifraorg.org/en-us/ingredients [Accessed 5 July 2017].
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(14) National Library of Medicine (NLM). 2015. Hazardous Substances Data Bank (HSDB).
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Available at: https://toxnet.nlm.nih.gov/newtoxnet/hsdb.htm [Accessed 5 July 2017]
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(15) United States Environmental Protection Agency (USEPA). 2015. Safer Chemical
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Ingredients List (SCIL). Available at: http://www2.epa.gov/saferchoice/safer-
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ingredients [Accessed 5 July 2017].
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(16) Gottschalck, T.E. and Breslawec, H.P., eds. 2012. International Cosmetic Ingredient
571
Dictionary and Handbook, 14 ed. Washington, D.C.: Personal Care Products Council
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(PCPC).
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(17) Consumer Specialty Products Association (CSPA). 2015. Consumer Product Ingredients Dictionary, 3rd ed. Washington, D.C.
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(18) Association Internationale de la Savonnerie, de la Detergence et Des Produits D'entretien
576
(AISE). 2017. Human and Environmental Risk Assessments on ingredients of household
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cleaning products (HERA) Homepage. Available at: http://www.heraproject.com. [Accessed
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5 July 2017]
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(19) OECD (Organisation for Economic Co-operation and Development). 2017. Internationally
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harmonised functional, product and article use categories. ENV/JM/MONO(2017)14, 17
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May 2017, Paris, France: Organisation for Economic Co-operation and Development.
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583
www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=env/jm/mono(2017)14
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&doclanguage=en [Accessed July 5, 2017].
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(20) ACI (American Cleaning Institute) 2010. Consumer Product Ingredient Communication
586
Initiative homepage. Available at:
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http://www.cleaninginstitute.org/sustainability/ingredient_communication_initiative.aspx
588
[Accessed July 14, 2017].
589
(21) Human & Environmental Risk Assessment on Ingredients of Household Cleaning Products
590
(HERA). 2005. Guidance Methodology Document. Association Internationale de la
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Savonnerie, de la Detergence et Des Produits D'entretien (AISE) and CEFIC, Brussels.
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Available at: http://www.heraproject.com/files/HERA%20TGD%20February%202005.pdf
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[Accessed September 29, 2017].
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(22) California Legislative Information. 2017. Senate Bill No. 258 (SB-258) Cleaning Product
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Right to Know Act of 2017. Available at:
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https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB258
597
[Accessed November 20, 2017].
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598
TABLES
599
Table 1. Product types and number of products surveyed in each type Product Type
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No. of Products
All Purpose Cleaners
304
Powder Hand wash powder
11
Liquid Liquid spray, diluted
105
Hand wash liquid
103
Hand wash wipe
40
Aerosol Spray
25
Hand wash gel, diluted
18
Hand wash gel, undiluted
1
Liquid spray, undiluted
1
Dish Care Products
171
Liquid detergent Hand wash, liquid
124
Automatic (machine) dishwashing (ADW), liquid
18
Liquid rinse aid ADW rinse aid/film or spot remover
2
Powder detergent ADW powder
7
Pot and pan cleaner, hand wash powder
3
Tablet detergent ADW tablet/packet
17
Laundry Care Products
618
Bar detergent Laundry detergent-Hand wash-Bar
1
Bleach Bleach, liquid
1
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Dryer sheets Fabric conditioner dryer sheets, softeners
44
Laundry detergent, sheet
2
Fabric conditioner dryer sheets, boosters
1
Liquid conditioners Fabric conditioner rinse added liquid, softeners
86
Fabric freshener/deodorizer, liquid spray
20
Ironing aid/conditioning product, aerosol spray
16
Fabric freshener/deodorizer, aerosol spray
4
Ironing aid/conditioning product, liquid spray
4
Liquid detergent Laundry detergent, liquid
258
Laundry detergent booster, liquid
9
Liquid pretreatment Laundry pretreatment, spray liquid
9
Laundry pretreatment, hand wash liquid
5
Laundry pretreatment, hand wash wipe
2
Laundry pretreatment, spray aerosol
2
Powder detergent Laundry detergent, powder
124
Laundry detergent booster, powder
13
Tablet conditioner Fabric conditioner tablet/packet/crystal, softeners
3
Tablet detergent Laundry detergent booster, tablet/packet
8
Laundry detergent, tablet/packet
5
Laundry machine cleaner, tablet/packet
1
600 601
Table 2. Ingredient FCs
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All Purpose Cleaners
Dish Care Products
Laundry Care Products
Abrasive
14
3
4
Absorbent
1
--
--
Adhesion promoter
1
--
--
Anticaking agent
1
2
2
Antioxidant
4
6
4
Antiredeposition agent
--
--
2
Antiscaling agent
2
2
--
Antistatic
5
3
10
Binder
1
--
1
Biocide
13
2
6
Bittering agent
1
--
--
Bleaching-Oxidizing agent
6
4
6
Brightener
--
--
4
Chelating agent
19
16
20
Cleaning agent
2
5
9
Corrosion Inhibitor
2
3
4
Defoamer
2
1
5
Deodorizer
--
--
2
Dispersing agent
3
3
6
Dye
30
17
30
Emollient
2
3
2
Emulsifier
9
2
7
Film former
4
2
5
Function
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ACS Sustainable Chemistry & Engineering
Foamant
1
1
--
Fragrance
49
46
47
Humectant
--
--
2
Opacifier
11
6
12
pH regulating agent
18
13
22
Pigment
2
2
3
Preservative
11
11
7
Process regulator
--
3
3
Processing aid, not otherwise listed
--
1
--
Propellant
4
--
5
Solubility enhancer
3
3
6
Solvent
32
17
17
Stabilizing agent
8
8
14
117
68
103
UV stabilizer
2
1
--
Vehicle carrier
--
--
1
Viscosity modifier
33
12
28
Surfactant
602
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603 604
Table of Contents (TOC) Graphic
For Table of Contents Use Only 605
Public data were collected which described an inventory of 588 chemicals found to formulate
606
consumer cleaning products in the United States, and their function in the products.
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