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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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ACS Sustainable Chemistry & Engineering

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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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ACS Paragon Plus Environment

ACS Sustainable Chemistry & Engineering 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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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]

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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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These records were reduced to


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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

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groupings of chemicals that were not amenable to categorization (“unassigned” and “insoluble

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solids”) with greater than ten occurrences among the broad cleaning product types. The

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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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More than 87% of the ingredients with more than ten occurrences among the broad cleaning

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product types fall into one or more of these chemical categories or groups.

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Relationship between Ingredients and FC

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To assign FC for each ingredient, review was conducted of numerous sources. Sources varied in

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the number of ingredients for which they provided FC

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information; number of assignments per source is shown in Figure 4. Function information

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differed between sources in terms of nomenclature and degree of specificity. The INCI

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Dictionary provided function information for the greatest number of ingredients (293) followed

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by the CSPA Dictionary17 (252). There was significant overlap in the function – ingredient

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assignment provided these sources.

INCI

293

CSPA Data Source

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252

SCIL

228

CPISI

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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



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


Page 20 of 38

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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.

21



140

All Purpose Cleaners

120

Dish Care Products 100


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

Page 22 of 38

60

40

20

0

FUNCTIONAL-USE CLASS (FC) 373 374

Figure 5. Number of ingredients of each FC within broad product types 22


Page 23 of 38 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


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

23



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.

24


Page 24 of 38

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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

25



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

26


Page 26 of 38

Page 27 of 38 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

467


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

27



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.

28


Page 28 of 38

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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.

29



513

REFERENCES

514

(1) Wibbertmann, A., I. Mangelsdorf, K. Gamon, R. Sedlak. 2011. Toxicological properties and

515

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516

sulfonates, and α-olefin sulfonates. Ecotoxicol. Environ. Saf. 74: 1089-1106. DOI:

517

10.1016/j.ecoenv.2011.02.007.

518

(2) Könnecker, G., J. Regelmann, S. Belanger, K. Gamon, R. Sedlak. 2011. Environmental

519

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520

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521

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(3) Sanderson, H., J.L. Counts, K.L. Stanton, R.I. Sedlak. 2006. Exposure and prioritization—

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524

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526

(4) Sanderson, H., C. Tibazarwa, W. Greggs, D.J. Versteeg, Y. Kasai, K.L. Stanton, R.I.

527

Sedlak. 2009. High Production Volume Chemical Amine Oxides [C8–C20] Category

528

Environmental Risk Assessment. Risk Analysis, 29 (6): 857-867. DOI: 10.1111/j.1539-

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6924.2009.01208.x.

530

(5) Stanton, K., C. Tibazarwa, H. Certa, W. Greggs, D. Hillebold, D. Woltering, R. Sedlak.

531

2009. Environmental risk assessment of hydrotropes in the United States, Europe, and

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Australia. Integr. Environ. Assess. Manage., 6(1): 155–163. DOI: 10.1897/IEAM_2009-

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A. Willing, S.D. Dyer, K. Stanton, R. Sedlak. 2009. An overview of hazard and risk

536

assessment of the OECD high production volume chemical category – Long chain alcohols

537

[C6-C22] (LCOH). Ecotoxicol. Environ. Saf. 72: 973-939. DOI:

538

10.1016/j.ecoenv.2008.10.006.

539

(7) Fisk, P., R.J. Wildey, A.E. Girling, H. Sanderson, S.E. Belanger, G. Veenstra, A. Nielsen,

540

Y. Kasai, A. Willing, S.D. Dyer, K. Stanton. 2009. Environmental properties of long chain

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alcohols. Part 1: Physicochemical, environmental fate and acute aquatic toxicity properties.

542

Ecotoxicol. Environ. Saf. 72: 980-995. DOI: 10.1016/j.ecoenv.2008.09.025.

543

(8) Schäfers, C., U. Boshof, H. Jürling, S.E. Belanger, H. Sanderson, S.D. Dyer, A.M. Nielsen,

544

A. Willing, K. Gamon, Y. Kasai, C.V. Eadsforth, P.R. Fisk, A.E. Girling. 2009.

545

Environmental properties of long-chain alcohols, Part 2: Structure–activity relationship for

546

chronic aquatic toxicity of long-chain alcohols. Ecotoxicol. Environ. Saf. 72: 996-1005.

547

DOI: 10.1016/j.ecoenv.2008.07.019.

548

(9) Belanger, S.E. H. Sanderson, P.R. Fisk, C. Schäfers, S.M. Mudge, A. Willing, Y. Kasai,

549

A.M. Nielsen, S.D. Dyer, R. Toy. 2009. Assessment of the environmental risk of long-

550

chain aliphatic alcohols. Ecotoxicol. Environ. Saf. 72: 1006-1015. DOI:

551

10.1016/j.ecoenv.2008.07.013.

552

(10) Veenstra, G., C. Webb, H. Sanderson, S.E. Belanger, P. Fisk, A. Nielsen, Y. Kasai, A.

553

Willing, S. Dyer, D. Penney, H. Certa, K. Stanton, R. Sedlak. 2009. Human health risk

554

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555

10.1016/j.ecoenv.2008.07.012.

556

(11) Stanton, K. and F. Kruszewski. 2016. Quantifying the benefits of using read-across and in

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silico techniques to fulfill hazard data requirements for chemical categories. Regul. Toxicol.

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Pharmacol. 81:250-259. hDOI: 10.1016/j.yrtph.2016.09.004.

559

(12) Sanderson, H., Greggs, W., Cowan-Ellsberry, C., DeLeo, P., and R. Sedlak. 2013.

560

Collection and Dissemination of Exposure Data Throughout the Chemical Value Chain: A

561

Case Study from a Global Consumer Product Industry. Hum. Ecol. Risk Assess., 19:4, 999-

562

1013.

563 564

(13) International Fragrance Association (IFRA). 2011. IFRA Transparency List. Available at: http://www.ifraorg.org/en-us/ingredients [Accessed 5 July 2017].

565

(14) National Library of Medicine (NLM). 2015. Hazardous Substances Data Bank (HSDB).

566

Available at: https://toxnet.nlm.nih.gov/newtoxnet/hsdb.htm [Accessed 5 July 2017]

567

(15) United States Environmental Protection Agency (USEPA). 2015. Safer Chemical

568

Ingredients List (SCIL). Available at: http://www2.epa.gov/saferchoice/safer-

569

ingredients [Accessed 5 July 2017].

570

(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

572

(PCPC).

573 574

(17) Consumer Specialty Products Association (CSPA). 2015. Consumer Product Ingredients Dictionary, 3rd ed. Washington, D.C.

575

(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

577

cleaning products (HERA) Homepage. Available at: http://www.heraproject.com. [Accessed

578

5 July 2017]

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579


(19) OECD (Organisation for Economic Co-operation and Development). 2017. Internationally

580

harmonised functional, product and article use categories. ENV/JM/MONO(2017)14, 17

581

May 2017, Paris, France: Organisation for Economic Co-operation and Development.

582

Available at:

583

www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=env/jm/mono(2017)14

584

&doclanguage=en [Accessed July 5, 2017].

585

(20) ACI (American Cleaning Institute) 2010. Consumer Product Ingredient Communication

586

Initiative homepage. Available at:

587

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

591

Savonnerie, de la Detergence et Des Produits D'entretien (AISE) and CEFIC, Brussels.

592

Available at: http://www.heraproject.com/files/HERA%20TGD%20February%202005.pdf

593

[Accessed September 29, 2017].

594

(22) California Legislative Information. 2017. Senate Bill No. 258 (SB-258) Cleaning Product

595

Right to Know Act of 2017. Available at:

596

https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB258

597

[Accessed November 20, 2017].

33



598

TABLES

599

Table 1. Product types and number of products surveyed in each type Product Type

Page 34 of 38

No. of Products


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


618

Bar detergent Laundry detergent-Hand wash-Bar

1

Bleach Bleach, liquid

1

34


Page 35 of 38 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


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

35



Page 36 of 38


Dish 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

36


Page 37 of 38 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


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

37



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.

38


Page 38 of 38

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