|1,4 dioxane, from wiki commons|
1,4-dioxane isn't passed along supply chain with a label, hall pass, or note
Let's use this opportunity to remind ourselves that toxic chemicals are not always passed along the supply chain in the typical manner.
This is why we need to be questioning suppliers not just about product ingredients but about processes as well. Information about raw materials and product-ingredient chemicals and substances must be collected, culled, and considered, yes, as we have said; information about process must be collected, culled and considered too. Because:
1,4-dioxane is NOT listed as an ingredient
1,4-dioxane is created inadvertently due to chemical processing - it's thus a manufacturing byproduct, not a manufacturing ingredient. Therefore, toxic as it can be, 1,4-dioxane is not listed on ingredient labels.
Toxic chemicals are not always:
- listed in product ingredients
- identified in raw material labels, even with CLP labelling
- passed from supplier to manufacturer with a disclaimer statement, as in, "Here are your chemicals, and by the way, some are toxic and/or illegal."
1,4-dioxane is a petrochemical carcinogen
Nevertheless, 1,4-dioxane is classified by the U.S. Environmental Protection Agency or EPA as a probable human carcinogen. It's said to be safe for consumers in "trace amounts," which themselves are ill-defined. California's Proposition 65 requires that consumer products contain no more than 10 parts per million (ppm) of 1,4-dioxane.
Consumers can be exposed to 1,4-dioxane through a myriad of different sources. The popular Herbal Essences shampoos recently had to be reformulated because of too much of it.
California's EPA says that 1,4-dioxane, at sufficient amounts:
- is known to cause cancer
- may cause kidney, respiratory, and neurological toxicity.
Wanted: sophisticated supply chain questionnaires
It's one thing to identify toxic or potentially toxic chemicals in a supply chain, as the landmark REACH regulation in Europe is trying to do, for instance.
It's another thing to check for > trace amounts of not ingredients but process by-products. Sophisticated supplier questionnaires are key. There is some sophisticated software for materials disclosure out there, for instance, REACHtracker at http://www.reachtracker.com - the SaaS plug-and-play software module from Actio Corp.
Also, there is software called Material Disclosure software from the same company. Material Disclosure is a REACH compliance software on steroids, meaning it is used not just for REACH, but also for RoHS, California Prop 65 compliance and GADSL and Green Chemistry -- as well as certification and compliance regarding all other local and global product manufacturing and distribution regulations of the chemical-environmental ilk.
A software for chemical regulatory compliance in a product supply chain -- that is, software that tracks toxic substances in a product -- must either allow for custom questionnaires and/or include queries about processing by-products such as 1,4-dioxane in its default questionnaires.
Things to keep in mind
1,4 Dioxane is a byproduct, not an ingredient. A regulatory parameter such as California's Prop 65 should not catch you off-guard, as it did Proctor & Gamble, when they had to make significant reformulations to one of their top products.
Very notably, P&G does great work on the green products and green supply chain front, so naturally they get and deserve a break. Our focus is not on blacklisting or even brownlisting a particular company. Few of us have halos.
The key things to know about toxic byproducts in a supply chain are:
- if P&G got caught, it's happening in other supply chains
- the regulations are not getting more lax as time goes on
- even CLP or GHS labeling won't fix it
- there are ways to prevent it
- CA Prop 65: http://oehha.ca.gov/prop65/background/p65plain.html
- Article on P&G reducing levels of 1,4-dioxane in its Herbal Essences line of hair care products: http://www.naturalnews.com/028560_Herbal_Essences_shampoo.html
- EPA: http://www.epa.gov/iris/subst/0326.htm