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What the EPA's 2024 Safer Choice Standards Mean for PFAS Reduction

FIFRA
Prop65
CWA
General
9
August 2024
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The programme continues to advocate for informed substitution, encouraging the transition from chemicals of concern to safer alternatives.
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The EPA has revised its Safer Choice and Design for the Environment (DfE) standards to enhance transparency and safety in product formulations. The August 2024 updates focus on reducing the use of hazardous substances, including PFAS. Key changes include detailed ingredient disclosure, stringent performance criteria, and rigorous audits for compliance. The updates also address various product categories such as cleaning products, laundry detergents, pet care items, marine lubricants, and antimicrobial products. These revisions aim to promote safer chemicals and improve environmental protection, aligning with regulations like the Pollution Prevention Act, FIFRA, and California Proposition 65.

What are the main changes in the EPA's August 2024 Safer Choice and DfE standards update?

The main changes include enhanced transparency in ingredient disclosure, stricter performance criteria, and rigorous compliance audits. The updates also focus on reducing the use of hazardous substances, such as PFAS. These revisions impact a wide range of product categories, including cleaning products, laundry detergents, pet care items, marine lubricants, and antimicrobial products. The goal is to promote safer chemicals and improve environmental protection.

What are the essential steps manufacturers must take to comply with the EPA's updated Safer Choice and DfE standards?

To comply with the EPA's updated Safer Choice and Design for the Environment (DfE) standards, manufacturers must follow several crucial steps. First and foremost, they need to ensure detailed ingredient disclosure. This involves providing full transparency regarding all ingredients in product formulations, including those intentionally added and known residuals. Manufacturers must use clear and recognisable nomenclature systems to list these ingredients, making it easier for regulators and consumers to understand the product's composition.

Meeting the specified performance criteria is another critical requirement. Manufacturers must submit performance test results that demonstrate their products meet or exceed the standards for their category, such as cleaning effectiveness and safety. This ensures that certified products are not only safe but also effective in their intended use.

Reducing the use of hazardous substances, particularly per- and polyfluoroalkyl substances (PFAS), is a key focus of the updated standards. Manufacturers must identify and eliminate these harmful chemicals from their products, replacing them with safer alternatives that meet the updated criteria. This step is crucial for aligning with the broader regulatory efforts to control and eliminate persistent pollutants.

Compliance audits play a significant role in the certification process. Manufacturers should be prepared for rigorous audits, including on-site and desk audits conducted by qualified third-party profilers. Maintaining accurate records and ensuring that formulations consistently align with the certified standards are essential for passing these audits. Additionally, adhering to the streamlined renewal process is important. Manufacturers must provide timely updates and ensure continuous compliance with the standards to maintain their certification.

Enhancing consumer communication is also a critical aspect of compliance. Manufacturers should make ingredient information readily available on product labels, company websites, or through toll-free numbers. This transparency empowers consumers to make informed choices about the products they use, further promoting the goals of the Safer Choice and DfE programs.

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The U.S. Environmental Protection Agency (EPA) has unveiled significant updates to its Safer Choice and Design for the Environment (DfE) standards, aimed at enhancing the transparency and accessibility of its certification criteria for safer products. These changes, highlighted in green in the revised document, reflect the agency's ongoing commitment to promoting safer chemical formulations and sustainable practices in the cleaning product industry.

Enhanced Transparency and Updated Criteria

The Safer Choice and DfE programmes, renowned for their rigorous standards in product safety and environmental protection, have undergone multiple revisions since their inception. The August 2024 updates focus on several key areas to ensure products meet the highest safety and environmental standards:

  1. General Requirements and Renewals: The updated standards emphasise the importance of detailed product and ingredient information. Manufacturers seeking certification must provide comprehensive data on their formulations, including all intentionally added ingredients, known residuals, and their specific functions. The renewal process for partnerships has been streamlined, requiring timely updates and compliance checks to maintain certification.
  2. Product-Level Requirements: The revisions include specific performance criteria for various product categories, such as window/glass cleaners, all-purpose cleaners, and carpet cleaners. These standards ensure that certified products not only meet safety and environmental benchmarks but also deliver effective performance comparable to conventional products.
  3. Ingredient Communication: To enhance public awareness and consumer confidence, the EPA now mandates more detailed ingredient disclosure. Manufacturers must list all intentionally added ingredients, using clear and recognisable nomenclature systems, and provide this information on product labels, websites, or through toll-free numbers. This move towards greater transparency aims to empower consumers to make informed choices about the products they use.
  4. Audits and Compliance: The revised standards reinforce the need for rigorous audits, including on-site and desk audits conducted by qualified third-party profilers. These audits ensure that manufacturers adhere to the agreed-upon formulations and processes, thereby maintaining the integrity of the Safer Choice and DfE certifications.

Addressing Substances of Concern

The August 2024 updates also place a significant focus on identifying and mitigating the use of substances of concern, including per- and polyfluoroalkyl substances (PFAS) and other potentially hazardous chemicals. PFAS, often referred to as 'forever chemicals' due to their persistence in the environment, are under increased scrutiny for their potential health impacts. The EPA's revised criteria now include stringent evaluation processes to minimise or eliminate the use of such substances in certified products.

Informed Substitution and Lifecycle Considerations

The Safer Choice programme continues to advocate for informed substitution, encouraging the transition from chemicals of concern to safer alternatives. The updated standards also introduce voluntary guidelines for lifecycle considerations, such as reducing carbon-based energy consumption and enhancing packaging sustainability. These guidelines align with broader environmental goals, promoting continuous improvement and innovation in product formulation and manufacturing processes.

Commitment to Continuous Improvement

The August 2024 revisions are part of the EPA's ongoing efforts to advance environmental protection through collaboration with industry stakeholders, environmental groups, and scientific experts. By setting stringent criteria and promoting best practices, the Safer Choice and DfE programmes aim to reduce the environmental impact of cleaning products and safeguard human health.

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