FOR INTERNAL USE ONLY - CONFIDENTIAL

GS-48

BACKGROUND INFORMATION ON THE PROPOSED GREEN SEAL™ STANDARD FOR

LAUNDRY CARE PRODUCTS

March 16, 2012

Green Seal, Inc. • 1001 Connecticut Ave. NW, Ste 872 • Washington, DC USA 20036-5525 (202) 872-6400 • FAX (202) 872-4324 • www.greenseal.org

©2012 Green Seal, Inc. All Rights Reserved

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BACKGROUND INFORMATION ON THE PROPOSED GREEN SEALTM STANDARD FOR LAUNDRY CARE PRODUCTS, GS-48

TABLE OF CONTENTS

Introduction.................................................................................................................................................... 3

Standard Scope ............................................................................................................................................ 3

Life Cycle Overview ...................................................................................................................................... 4

Raw Materials ........................................................................................................................................... 5

Packaging and Reduction of Chemical Use .............................................................................................. 7

Product Manufacturing and Distribution .................................................................................................... 7

Use and Performance ............................................................................................................................... 7

End of Life ................................................................................................................................................. 8

Product-Specific Performance Requirements ............................................................................................... 9

Product-Specific Sustainability Requirements ............................................................................................ 10

Manufacturing Sustainability Requirements................................................................................................ 14

Packaging Sustainability Requirements ...................................................................................................... 14

Training and Labeling Requirements .......................................................................................................... 15

Additional Considerations ........................................................................................................................... 16

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BACKGROUND INFORMATION ON THE PROPOSED GREEN SEALTM STANDARD FOR LAUNDRY CARE PRODUCTS, GS-48

Introduction Laundry care is a segment of the broad cleaning market. Laundry care is a universal activity to maintain fabrics. As such, laundry care products are used for home care and for institutional settings like laundry services, health care, and hospitality. Laundry care products include detergents (liquid and powder automatic, hand), fabric softeners, and laundry care aids (spot and stain removers, bleach, sours, alkali boosters, and fabric fresheners). These products are used with automatic washing/drying machines or for hand cleaning. Given the widespread use of these products their potential to contribute to health and environmental damage is significant. However, some of the potential issues can be reduced and outlined in a standard. As a result, Green Seal has developed a Proposed Green Seal Standard for Laundry Care Products, GS-48, (aka Proposed Standard) to lead to the issuance of a final standard.to help provide guidance to the industry and to provide consumers a way to identify the products they want (via certification to the standard). The intent of this standard will be to reduce, to the extent technically and economically feasible, the environmental, health, and social impacts associated with laundry care products. Standard Scope The scope of the Proposed Standard applies to laundry care products used in households and institutions. The Proposed Standard outlines environmental, health, and social requirements for products that are used to clean, remove stains, and/or otherwise treat the softness, static or wrinkle characteristics of laundry. This includes products such as, but not limited to, liquid, powder, and pre-measured laundry detergent products (tablets/gels/solids), fine washable laundry detergent products (for delicates), stain and spot removing products (pre-treatment and stand-alone), laundry additives (bleaching and softening products), fabric softener (liquids and sheets), sour products, antichlor products, alkali booster products, anti-static products (liquid and sheets), fabric refresher products, anti-wrinkle products, laundry prewash products, laundry starch/sizing/fabric finish products, soap nuts/biobased detergents, detergents for people with sensitive skin, and combination products that may serve several of these functions. This standard does not include the dry cleaning process, dry cleaning solvents, ozone generation and use, or a laundry facility itself. This standard includes fabric protectant products but does not address impregnating products with flame retardant or waterproofing properties. This standard also does not address carpet or upholstery cleaning and maintenance products nor footwear or leather care products. This Proposed Standard will incorporate the current Green Seal Standard for Powdered Laundry Bleach, GS-21, so that when the standard is issued GS-21 will be withdrawn and there will be one standard for laundry care products. The products included in the Proposed Standard are used to treat household washgoods (typically lightly-to-moderately soiled clothes and linens), industrial washgoods (can be heavily soiled clothing and tools/wipers), hospital washgoods (from lightly soiled clothes and linens to heavily soiled items with blood and pathogens requiring special antimicrobial treatment), food service and food manufacturing washgoods (similar to hospital washgoods), and hospitality washgoods (typically lightly soiled linens that have a high visual standard for cleanliness)1. Products used for antimicrobial treatment in a health care or food setting are included in the Proposed Standard. These antimicrobial pesticide products are covered by the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and must be registered with

1 AISE. 2000. Industrial & Institutional Sector Environmental dossier on Professional laundry. http://www.aise.eu/downloads/AISE_pro_laundry_dossier.pdf

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the U.S. Environmental Protection Agency (EPA) under FIFRA (7 U.S.C. 136) or registered with Health Canada’s Pesticide Management Regulatory Agency (PMRA). To treat these goods, the products are generally used with water in various types of machines to facilitate the complex interaction of chemical and physical processes to perform their function. Laundry detergents, for example, are designed to: (1) hydrate soil, (2) remove soil from fabric, (3) fragment soil to aid suspension, (4) prevent the redeposition of said soils, (5) bleach any residual soils to lessen their visual impact, and (6) provide any final modification to the fabric as desired (e.g., deposit perfume, brighteners, etc.). Household machines are either top loading or front loading (80% of machines are top loading2) – with average/medium-sized loads of about 6 pounds3 (though the capacity can be much higher with up to 30 pounds for large-capacity machines). Institutional machines are either large continuous machines or batch machines that are generally similar to household machines with greater programmability and power. Institutional loads are much larger than household machines (typical batch loads are 35 or 50 pounds). Life Cycle Overview The use of laundry care products is ubiquitous and has been the subject of environmental study for the last several decades. The life cycle of these products can be summarized as follows:

• Production of raw materials • Production of packaging • Manufacturing of product • Distribution of finished product to point of purchase and use • Product use • End of life (wastewater and packaging waste)

Life cycle assessment (LCA) studies have been conducted on these products to evaluate the environmental issues, though they have primarily focused on detergents (as a result much of the discussion will focus on these products). Such studies have demonstrated that the use phase of the life cycle is the dominant source of environmental damage from these products. For example, the international Association for Soaps, Detergents and Maintenance Products (AISE) found that the use phase of laundry detergents (controlled by consumers) accounts for 70% of total energy use, 90% of air emissions, and 60% of solid waste through LCA4. An LCA study conducted by Procter & Gamble found that 80% of energy use occurs during the use phase (mainly for heating of the water)5. The use phase clearly dominates the LCA impacts. However, appropriate raw material selection (from different sources to less toxic options), product formulas (including compaction and less sudsing/high efficiency formulas), and packaging can help reduce these impacts along with additional life cycle issues (not evaluated in traditional LCA methods) like human health concerns6. Thus, the main considerations for a sustainability standard include:

• Cold water effectiveness • Concentrated/compacted formulas

2 EIA. (U.S. Energy Information Administration). 2011. Residential Energy Consumption Survey 2009-Detailed Tables. http://www.eia.gov/consumption/residential/data/2009 3 ASTM International. 2005. . Standard Guide for Controlled Laundering Test Using Naturally Soiled Fabrics and Household Appliances. ASTM D2960 4 AISE. Final Report on the Implementation of the A.I.S.E. Code of Good Environmental Practice for Household Laundry Detergents in Europe. January 2003. http://ec.europa.eu/enterprise/sectors/chemicals/files/reports/final_aise_en.pdf 5 Saouter E and Hoof GV. 2002. A Database for the life cycle assessment of Procter & Gamble laundry detergents, International Journal of Life Cycle Assessment, 7(2): 103-114 6 European Ecolabel Revision of Ecolabel Criteria for Laundry Detergents Background Report. 2009. http://ec.europa.eu/environment/ecolabel/ecolabelled_products/categories/pdf/laundry/background_report.pdf

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• Less packaging (goes with concentration) • HE formulas (less sudsing ingredients) • Biodegradable and non-toxic ingredients • Source of ingredients (to the extent that this can be addressed)

Raw Materials The main ingredients used in laundry detergents and stain removing products are surfactants, builders, and bleaching agents. The products also contain processing or delivery aids for product stability and can contain many optional ingredients to provide performance or aesthetic benefits, such as fluorescent whitening agents/optical brighteners, enzymes, anti-redeposition agents, fiber and dye protective agents, frangrances, and suds control agents. Specialty laundry care products may also include other ingredients. Life cycle inventories for the chemical ingredients used in laundry detergents have demonstrated that an increase in the number of ingredients increases the overall energy requirements for these products9. Surfactants are surface active substances that are used in almost all detergents. Surfactants are considered the most essential ingredient in laundry detergents. They are organic substances that have a hydrophobic part and a hydrophilic part used for emulsification and suspension of dirt - the core function is to ensure that the dirt is dissolved and discarded in the end of the washing process and to inhibit re-deposition of the dirt. In the past, the primary surfactant used in laundry detergents was nonylphenol ethoxylate. This material has been voluntarily phased out over time due to its well-known aquatic issues (e.g., it degrades into toxic, non-biodegradable, bioaccumulative hormone disruptors). Currently, most household products do not use nonylphenol ethoxylate; however, 34% of industrial and institutional liquid detergents sales contain nonylphenol ethoxylate (and 41% of powder detergent sales) 10. Alternative surfactants that are commonly used are linear alcohol ethoxylates, nonionic surfactants. These materials do not have the aquatic issues that nonylphenol ethoxylate has, though they are produced using the carcinogen ethylene oxide (which in general is not present in the final material) and the carcinogen 1,4-dioxane is a by-product from the production that ends up being a contaminant residue in the final material. Considering these issues, the consensus in industry is that linear alcohol ethoxylates are still more preferable than nonylphenol ethoxylates. Linear alkylbenzene sulfonates (anionic) and sodium lauryl sulfate are also common surfactants in household laundry detergents. Builders/chelating agents are used to trap minerals in the water and soils that might interfere with the functioning of the surfactants and help buffer the wash to enhance the functioning of the surfactants. Historically, builders contained inorganic phosphate, which causes eutrophication when discharged to waterways – the artificial boom of plant growth (and subsequent death) that depletes the oxygen in the water causing a reduction in fish and water species. Because of the widespread use of laundry detergent and the high levels of phosphate, eutrophication issues were a key problem for these products. In the late 1990’s many states began prohibiting the sale of household laundry detergents containing phosphorus or strictly limiting the content to 0.5%. These state bans became so widespread that by the mid-1990’s the majority of household detergents in the U.S. were phosphate-free. Many of these regulations, however, do not address institutional laundry products that still include inorganic phosphates. Common alternatives to phosphates include citrates, borates*, carbonates, zeolite, and nitrilotriacetic acid (NTA). Bleaching agents help in the removal and decoloring of stains. In some cases oxidative bleach can also provide an antibacterial function. The materials used for bleaching include percarbonate and perborate*, peroxides and peracids, and hypochlorite. Most of the materials require a warm/hot temperature (e.g.,

9Saouter, E., G. van Hoof, T. Feijetel, J.W. Owens. 2002. The effect of compact formulations on the environmental profile of Northern European granular laundry detergents: part II life cycle assessment. International Journal of Life Cycle Assessment. 7 (1): 27-28. 10 TRS letter to EPA Administrator 6/21/2010 ..\codes\TRSA NPE Phase Out Commitment Letter_textileRentalAssociation.pdf

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above 60°C) to function so bleach activators like tetra acetyl ethylene diamine (TAED) are often used with percarbonate or perborate* to enable the washing and bleaching temperature to be lowered11. Additional ingredients can help the function of the product. For example, enzymes (e.g., proteases, lipases) help degrade soils and can work at low temperatures and thus are becoming very common in laundry products. Polymers such as carboxymethylcellulose (CMC) are used to avoid re-deposition of dirt and polyvinylpyrrolidon (PVP) is used as a dye-transfer inhibitor which avoid re-deposition of soaked textile colour. Alcohols (glycerol, ethanol, and propanol) are used to dissolve solid ingredients for liquid products. Optical brighteners, optical brightening agents (OBAs), fluorescent brightening agents (FBAs) or fluorescent whitening agents (FWAs) are chemicals that absorb light in the ultraviolet and violet region (usually 340-370 nm) of the electromagnetic spectrum, and re-emit light in the blue region (typically 420-470 nm). These additives are often used (from 0.05-0.15% in the product) to enhance the appearance of the fabric, causing a perceived "whitening" effect, making materials look less yellow by increasing the overall amount of blue light reflected. Many products (especially liquids) contain preservatives, frequently methylisothiazolinone and benzisothiazolinone, at low concentrations. Fragrance ingredients are not used for functional performance, but more for user preference - to make the textile smell good when dry and ready to use. Soap nuts come from plants of the genus Sapindus (in the Lycchee family, produce nuts that can be used for washing laundry). Soap nuts contain saponins that are natural surfactants. They have been used for washing for thousands of years by native peoples in Asia as well as Native Americans. Soap nuts are commercially available as detergents12. Specialized laundry products often contain unique ingredients to impart the function. Fabric softeners include quaternary ammonia compounds and siloxane/silicone-based ingredients (usually in combination) to help make fabric softer and prevent static cling. A key alternative to quaternary ammonia compounds (since these have health and environmental issues) is propylene glycol - palm-derived emulsifiers are also used. Wrinkle releaser products contain alcohol, polymers, and fragrances. Powder and liquid product forms are available in the market, with liquids as the dominate form in the U.S. There are two primary formulation approaches for liquids. One focuses on the intrinsic benefits of the liquid form, allowing for the incorporation of surfactants at high levels and for pretreatment (i.e., direct application of the product to the stain prior to addition to the washing machine). This route leads to low viscosity, isotropic liquids. The second formulation path uses structured liquid detergents containing high levels of suspended builders such as sodium tripolyphosphate or zeolites. A relatively new approach to detergent delivery is unit-doses, like tablets or pouches. Unit-dose tablets generally have the same formulation and cleaning chemistry as powders/granulates, but offer more convenient dosing13. Liqui-tabs are a single dose of liquid detergent contained in a water-soluble pouch. The cleaning chemistry is the same as in conventional liquid detergents and the water-soluble pouch is typically made of polyvinylalcohol (PVA) or some derivative thereof. Although the formulas are similar, unit dose liquids may contain only 10% water compared to 50% in current liquids (although it has been documented that in practice even lower concentrations of water may be used in unit-dose liquid formats (<5% water and 15-25% solvent) 14,15. Additional innovative formats for unit-dosing are emerging, such as a sheet impregnated with cleaning, softening, and anti-static ingredients – e.g. Purex Complete 3-in-1.

11 AISE. 2000. Industrial & Institutional Sector Environmental dossier on Professional laundry. http://www.aise.eu/downloads/AISE_pro_laundry_dossier.pdf *Borate compounds are classified as reproductive toxins when present at levels greater than 5.5%, according to the GHS. 12 Stoffels, K. 2008. Soap nut saponins create powerful natural surfactant. Personal Care Magazine. http://www.personalcaremagazine.com/Story.aspx?Story=4325. 13 Showell, M. 2005. Handbook of Detergents. Part D-Formulations. Chapter 3. Laundry Detergents. 14 Advertising Age. Tide Pods Launch. New Detergent Form Could Become Multibillion-Dollar Product Proposition. April 26, 2011. http://adage.com/article/news/p-g-reinvents-laundry-150-million-tide-pods-launch/227208/ 15 Showell, M. 2005. Handbook of Detergents. Part D-Formulations. Chapter 3. Laundry Detergents.

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Packaging and Reduction of Chemical Use Research has shown that reducing the packaging through concentrating or compacting the product reduces the environmental impacts from packaging, and thus the product16,17. Also, the use of recycled packaging (e.g., plastic/HDPE) reduces the impact from packaging, though marginally in comparison to the effect from concentrating/compacting18. As a result, compact and super-compact formulations are becoming predominant in the market. These products reduce the amount of detergent per wash load (e.g., 50% less) and thus require less packaging to deliver the same number of washes19. However, unit-dosed products like tablets or liquid pouches can have increased packaging needs to protect the individual doses20. Liquids generally have a higher packaging impact than powders21. Household products also commonly include recycled content in the packaging. Institutional products are typically packaged in bulk (5 gallons or more) and with these larger package sizes, there is usually less packaging per weight of product22. Product Manufacturing and Distribution Manufacturing and distribution of the finished product to the point of purchase is expected to be impacted by the amount of product and packaging moved. So, with concentration/compaction it would be expected that these impacts would be reduced. The LCA studies on laundry detergent are overwhelmed with the other factors discussed (use phase, packaging, and raw materials) that manufacturing and distribution usually end up being minor considerations. However, an unpublished comparative LCA study of current compact powders versus non-compact powders showed that when the use-phase (the most impactful phase) was excluded from the analysis, compact powders reduced the number of trucks and fuel required to transport the detergent23. Use and Performance Although the detergent industry can control impacts associated with the product formula, manufacture, and packaging of detergents, it has no direct control on how the product is used. LCA studies clearly indicate that the largest environmental damages are linked to the products’ use and disposal - namely the wash temperature and the amount of detergent used. Companies are doing what they can to indirectly reduce these impacts, with demonstrated progress (formulas that can work effectively at low temperatures, compact/concentrated formulas)24,25. The use of enzymes and bleach activators have made it possible to wash at lower temperatures26. Additionally, unit–dose packaging reduces the consumer’s tendency to overdose. However, consumers have been resistant to adopt these new innovations (cold water washing and unit dosing). Unit-dose products or products in metered dispensing systems are important in reducing the total chemicals used during washing. Institutional products offer a range of dilution control systems (e.g.,

16 Cole, H. 1994. Super-Clean and Super-Green: The Environmental Case for Concentrated Liquid Laundry Detergents. Washington, DC. 17 Procter & Gamble. Product Development for Sustainable Innovation. Intertech Pira . 2010. unpublished 18 Kuta CC, D.G. Koch, C.C. Hildebrandt, D.C. Janzen. 1995. Improvement of products and packaging through use of life cycle analysis. Resources, Conservation and Recycling, 14:185-198. 19Saouter, E., G. van Hoof, T. Feijetel, J.W. Owens. 2002. The effect of compact formulations on the environmental profile of Northern European granular laundry detergents: part II life cycle assessment. International Journal of Life Cycle Assessment. 7 (1): 27-28. 20 Van Hoof, G.,D. Schowanek , T. Feijtel. 2003. Comparative life cycle assessment of laundry detergent formulation in the UK. Part I: Environmental fingerprint of five detergent formulations in 2001. Tenside Surfactants and Detergents. 40: 266-275. 21 Van Hoof, G.,D. Schowanek , T. Feijtel. 2003. Comparative life cycle assessment of laundry detergent formulation in the UK. Part I: Environmental fingerprint of five detergent formulations in 2001. Tenside Surfactants and Detergents. 40: 266-275. 22 AISE. 2000. Industrial & Institutional Sector Environmental dossier on Professional laundry. http://www.aise.eu/downloads/AISE_pro_laundry_dossier.pdf 23 Procter & Gamble. Product Development for Sustainable Innovation. Intertech Pira . 2010. unpublished 24 Van Hoof, G., D. Schowankek, T. Feijtel, G. Boeiji, P. Masscheleyn. 2003. Comparative life-cycle assessment of laundry detergent formulations in the UK: part II time trend analysis and wash equivalent comparison (1988-2001). Tenside Surfactants Detergents. 40 (5): 276-287. 25 Saouter, E., G. van Hoof, T. Feijetel, J.W. Owens. 2002. The effect of compact formulations on the environmental profile of Northern European granular laundry detergents: part II life cycle assessment. International Journal of Life Cycle Assessment. 7 (1): 27-28. 26 AISE. Final Report on the Implementation of the A.I.S.E. Code of Good Environmental Practice for Household Laundry Detergents in Europe. January 2003. http://ec.europa.eu/enterprise/sectors/chemicals/files/reports/final_aise_en.pdf

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tablets, closed dosing) and are more advanced than household products. Household products include caps with gradations to help with dosing though they are frequently very difficult for consumers to read and interpret, leading to the tendency to use more detergent than is instructed. There are limited unit-dosed product options available in the household market, as noted earlier in this document. Another development from product manufacturers that has helped reduce the use phase environmental impacts is high efficiency (HE) detergents for use in modern machines. HE laundry machines use 20% to 66% the amount of water and as little as 20% to 50% the energy used by conventional top-loading agitator machines,27 but require detergents that are compatible with the low water levels used. These HE detergents are low-sudsing, quick dispersing, and may contain ingredients designed to prevent re-deposition of soils and dyes, which can be a larger issue in low water volumes. Because washing machines have an expected lifespan of 10 years, the newer HE machines have limited penetration in the household market to date. Many products though are compatible with both HE and conventional machines. Health care laundry, in particular, has a high environment burden at the use phase due to the need for antimicrobial action to decontaminate textiles and fabrics. The antimicrobial action of the laundering process results from a combination of mechanical, thermal (hot water), and chemical factors. A temperature of at least 160°F (71°C) for a minimum of 25 minutes is commonly recommended. The use of chemicals, usually chlorine bleach, assures an extra margin of safety and is used at 135°F–145°F (57.2°C–62.7°C). Several studies have demonstrated that lower water temperatures of 71°F–77°F (22°C-25°C) can reduce microbial contamination. Low-temperature washing, however, relies heavily on the presence of chlorine bleach, or other chemicals, to reduce the levels of microbial contamination28. End of Life Once the wash is completed, the wash water is discharged to the sewer. This wastewater is treated in primary (settling) and/or secondary (activated sludge, tickling filters, etc.) processes and possibly followed by tertiary treatment (sand filtration, nutrient removal, etc.), or it is directly discharged into the environment without any type of treatment. There are issues in the waterways from the use of these products (e.g., aquatic toxicity, BOD, eutrophication). Key detergent ingredients contribute to aquatic toxicity including surfactants, followed by fragrances, monoethanolamine (used as neutralizer in liquids), and adipic acid. Additionally, mercury and phenol, which are released during the production of sodium carbonate and sodium sulfate (used in powdered formulations), are also contributors to aquatic toxicity. 98% of biochemical oxygen demand (BOD – a marker of pollution) through the life cycle is associated with the disposal stage of these products even after accounting for removal during treatment29. Powder compaction in the UK has been associated with lower BOD and lower COD, which is attributable to the lower detergent usage per wash. BOD is highest for liquids. Even with lower dosages per wash, BOD is higher for unit dose systems vs. traditional dosing systems. For powder tablets this is due to the use of extra organic material in the tablet coating, while for liquid tablets it is due to higher surfactant levels30. LCA studies have demonstrated that the solid waste impacts for liquid tablets and powder tablets are higher than those for compact powders or compact liquids. This follows the trend of increased packaging use for the tablet formats31.

27 American Cleaning Institute. 2010. High Efficiency Washers and Detergents. http://www.cleaninginstitute.org/assets/1/Page/HE.pdf 28CDC. 2003. Healthcare Infection Control Practices Advisory Committee (HICPAC). Guidelines for Infection Control in Healthcare Facilities.http://www.cdc.gov/hicpac/pdf/guidelines/eic_in_HCF_03.pdf 29 Saouter, E. and G. van Hoof. 2002. A database for the life cycle assessment of Proctor & Gamble laundry detergents. International Journal of Life Cycle Assessment. 7(2): 103-114. 30 Van Hoof, G., D. Schowanek, T. Feijtel. 2003. Comparative life cycle assessment of laundry detergent formulation in the UK: part I environmental fingerprint of five detergent formulations in 2001. Tenside Surfactants and Detergents. 40: 266-275. 31 Van Hoof, G., D. Schowanek, T. Feijtel. 2003. Comparative life cycle assessment of laundry detergent formulation in the UK: part I environmental fingerprint of five detergent formulations in 2001. Tenside Surfactants and Detergents. 40: 266-275.

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Product-Specific Performance Requirements The performance of a product is an important characteristic for purchasers and users. If the product does not meet its performance expectations, it might be disposed of or used in higher concentrations, thus affecting the total environmental burden of the product. As a result, the global guidance for sustainability-based standards, ISO 14020/14024, like this Proposed Standard, requires product performance requirements. The Proposed Standard requires products to demonstrate performance through successful testing under standardized methods applicable for the product category and compared to a reference product or a market-leading product. Since the use of heated water at the use phase dominates the environmental burden for these products, products should be able to perform at the lowest temperature possible. According to the U.S. Energy Information Administration, 45% of U.S. households that clean clothes at home use cold water32. So, performance should be met at the “cold” temperature setting, no more than 80°F +/- 5°F; 27ºC +/- 3°C33 (when compared to a reference product using “warm” water). Institutional users however, use higher temperatures to meet the higher performance expectations (better stain removal, more soil to remove, etc.) so a warmer temperature needs to be used for these products, 105°F +/- 5°F; 41°C +/- 3°C. Antimicrobial pesticide products needed for health care or food settings may require higher temperatures to achieve their approved efficacy level (i.e., for EPA registration) and thus should use the appropriate temperature to demonstrate other functions like dirt removal. Laundry detergent products will need to demonstrate performance of cleaning, color care, and fabric appearance using standardized testing procedures. These are the predominate indicators of performance and were used for the development of reference detergents by the American Association of Textile Chemists and Colorists (AATCC). Cleaning performance notes the cleanliness, brightness, lack of undesirable odors, and stain removal (this also indirectly gets to soil re-deposition). A subset of possible stains were included in the Proposed Standard for cleaning in order to represent the most common stains and a range of stain types including protein (blood), oil (motor oil), tannin (tea), dye (blueberry, grass, mustard), and combination stains (pen, makeup, tomato sauce). Color care performance measures color fastness and limited color change. Fabric appearance evaluates the integrity of the textile after treatment including color and pilling/abrasion. The methods from ASTM International and AATCC outline conditions for testing, but rely on household machines. These methods can also be used for institutional machines (provided proper testing controls are in place). Other test methods may also be used provided the same characteristics (cleaning, color care, fabric appearance) are tested. Since users have a range of water hardness levels (i.e., mineral load), the products will also need to perform at two different, “soft” and “hard”, water hardness levels. Soils and fabric types are specified in the Proposed Standard to help provide standardization for the testing. Testing beyond the conditions in the Proposed Standard, like testing more soils, is not prohibited just not needed to demonstrate conformance to the proposed criteria. Stain removing and bleaching products will need to demonstrate that they clean, avoid soil re-deposition, and remove stains. Softening products will need to demonstrate softness, water absorbency, and static control using one of described evaluation methods. For other specialized product types, like wrinkle removal, there are not applicable test methods available so comparative testing will need to be used.

32 EIA. (U.S. Energy Information Administration). 2011. Residential Energy Consumption Survey 2009-Detailed Tables. http://www.eia.gov/consumption/residential/data/2009 33 AATCC. 2010. Standardization of Home Laundry Test Conditions Technical Manual 2010.

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Product-Specific Sustainability Requirements Green Seal has a portfolio of sustainability standards for cleaning products. In the years of experience with these standards, Green Seal has found that there are several foundational criteria that are common across all types of more sustainable cleaning products. As a result, Green Seal established foundational criteria. These were recently finalized during the development of the Green Seal Standards for Specialty Cleaning Products for Household Use, GS-52, and Industrial and Institutional Use, GS-53. Foundational criteria are set-up to be the same across Green Seal’s cleaning product standards, though some unique exceptions may be included for each standard – any such exceptions proposed are described in this document. The foundational criteria for product-specific sustainability requirements include:

• Formula Disclosure for Certification • Animal Testing • Acute Mammalian Toxicity • Skin and Eye Corrosion • Carcinogens and Reproductive Toxins • Mutagens and Neurotoxins/Systemic Toxins • Endocrine Disruptors • Asthmagens • Respiratory Sensitization • Skin Sensitization • Skin Absorption • Toxicity to Aquatic Life • Aquatic Biodegradability • Bioaccumulating Compounds • Chronic Aquatic Toxicity • Eutrophication • Combustibility • Fragrances • Products Containing Enzymes • Products Containing Microorganisms • Antimicrobial Agents

Exceptions to Foundational Criteria Acute Mammalian Toxicity and Skin and Eye Corrosion: The scope of this standard includes products that are commonly concentrated or compacted to such an extent that they are sold as tablets, water-free liquids/gels, or closed dilution-control systems. These products can provide advantages in the environment and marketplace. There is the benefit of reducing the product’s environmental footprint, by using less water, less packaging, and saving on the energy required to ship and store the products. For the end user, these products can reduce waste, offer precise portion control, and control chemical costs. However, with these benefits comes the downside of potentially having a product with more hazards such as the potential to be toxic by oral ingestion, to cause serious eye damage, or to cause skin corrosion – making them unable to pass the foundational criteria for these concerns. If these products are allowed to meet Green Seal standards, special consideration must be included to provide necessary protections, especially for vulnerable populations, in the product formulation, packaging, and labeling. The requirements for these products are included as separate annexes, one for closed dilution-control systems (only applicable to institutional use products) and another for powders/solids/non-aqueous liquids. These are not new annexes/exceptions to Green Seal cleaning product standards, but they are only included in some of Green Seal’s cleaning product standards.

Inhalation toxicity, from a chronic exposure perspective, is a foundational criterion for most of Green Seal’s cleaning product standards since hard-surface (and carpet) cleaning products require prolonged

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exposure to the product when one is using the product and after using the product. This criterion is based on the evaluation of either repeated inhalation exposure hazard levels or product emissions. However, these considerations are not particularly relevant to the products included in scope of this Proposed Standard (given that they are generally put into a machine and most product residue is rinsed away). Further, inhalation toxicity concerns that are more relevant to the scope of this standard are addressed through the foundational criteria of Acute Mammalian Toxicity, Carcinogens and Reproductive Toxins, Mutagens and Neurotoxins/Systemic Toxins, Asthmagens, and Respiratory Sensitization as well as an additional criterion for volatile organic content limits. Eutrophication: The first official government action taken to reduce phosphorus pollution was the formation of the federal “Joint Industry-Government Task Force on Eutrophication” in 1967, followed by a call from Congress to end use of phosphorus in detergent by 1972 (from 8.7% to 2.2%). In 1994, the laundry detergent industry entered into a voluntary agreement with states to begin phasing out phosphates from their products because the costs of producing different detergents for states with phosphate bans were too high. As of 1999, 27 states and the District of Columbia had passed laws prohibiting the manufacture and use of laundry detergents containing phosphorus34. The laundry detergent bans result in phosphorus being limited to 0.5% in household products. As a result, Green Seal will adopt this limit (for undiluted household products). However, phosphorus is still used in commercial/professional products, with no state or federal regulations limiting its use. Green Seal’s product surveys have shown that phosphorus-containing compounds are still prevalent in institutional products because the laundry has a higher soil level and a high level of cleanliness required. Therefore the level for institutional products will remain the same as the foundational criterion for other cleaning product standards, limited to 0.5% by weight as phosphorus at the as used (diluted) level. Additional Criteria Volatile Organic Content Content: Volatile organic compounds (VOCs) include alcohols, aldehydes, straight chain and cyclic alkanes, aromatic hydrocarbons, halogenated hydrocarbons, terpenes, ketones, and esters. VOCs are common ingredients in laundry care products, including ethanol, fragrances, essential oils, and solvents. VOCs have adverse effects on the outdoor environment (e.g., smog production) and indoor environment (e.g., human health impacts). These effects can be acute in nature (based on limited or short-term exposure) or chronic (based on repeated exposure). For example, adverse health effects from VOCs include mucous membrane irritation, fatigue and difficulty concentrating, and toxic effects such as respiratory issues and carcinogenicity35. VOC exposure is one of the biggest contributors to asthma and other respiratory ailments in school-aged children36. Setting appropriate levels of VOC content is essential to minimizing the potential environmental and health effects of laundry products on workers, children, and otherwise vulnerable or sensitive populations. The Proposed Standard has adopted the allowable State of California’s Air Resources Board (CARB) VOC limits for each applicable product category. However, there are categories that CARB has not set limits for including laundry detergent, bleaching, softening and sour products. Green Seal has proposed limits for these product categories based on a survey of products on the market. Any other product types appear to be able to meet a generic limit of 1% (by weight). Determination of VOC content can be done by summing the content of volatile materials (i.e., those with a vapor press of 0.1 mmHg or more) or using the CARB Method 310 for determining the acceptable levels of VOC content allowed in the various product classes. This method is established and extensively used. CARB 310 provides exemptions to VOC requirements for fragrances and low vapor pressure components of a product. The CARB exemption of fragrances from the VOC content is inconsistent with the criteria in this Proposed Standard, so it is not permitted and volatile fragrances will be considered VOCs. Prohibited Components: There are several hazardous compounds that may not be prohibited as a result of the other criteria in the Proposed Standard but may warrant exclusion in a more sustainable product. 34 Litke, David W. 1999. Review of Phosphorus Control Measures in the United States and their Effects on Water Quality, Report 99-4007. Denver, Colorado: U.S. Geological Survey, National Water Quality-Assessment Program, 1999. 35 Girman, J.R. 1989. Volatile organic compounds and building bake-out. Occupational Medicine: State of the Art Reviews. October- December: 695-712. http://www.ncbi.nlm.nih.gov/sites/entrez?cmd=Retrieve&db=PubMed&list_uids=2690381&dopt=Citation 36 Mendell, M.J. 2007. Indoor residential chemical emissions as risk factors for respiratory and allergic effects in children: a review. Indoor Air.17:259-277.

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Further, there may not be a means to prohibit the compounds based on their human toxicity or ecotoxicity end point. Thus a list of prohibited components is included in the Proposed Standard. For example, there are several known and suspected endocrine disruptors that will be specifically prohibited. By far the largest group of chemicals with endocrine disruptor effects are phthalates, including, but not limited to dibutylphthalate, diethylhexylphthalate, butyl benzyl phthalate, and bis-(2-ethoxymethyl) phthalate. Because a variety of phthalates have evidence of being endocrine disrupters and because phthalates are not important functional ingredients in cleaning, they will be prohibited. Other classes of chemicals found in products in this Proposed Standard that may exhibit endocrine disrupting effects are phenolics, such as o-Phenylphenol37. 2-butoxyethanol is prohibited since it has had conflicting views of its weight of evidence for carcinogenicity (though is currently IARC classification 3, “unclassifiable as to carcinogenicity in humans”) and it is found in these products. The following chemicals are prohibited specifically due to their aquatic hazards, nitro-musks and polycyclic musks. These musks are prohibited because of their bioaccumualtation and aquatic effects. Alkylphenol ethoxylates (APEs) degrade into nonylphenol and other products which are known to persist and bioaccumulate in waterways and aquatic life and act as endocrine disrupters. Heavy metals, including lead, hexavalent chromium and selenium are prohibited as these compounds are known neurotoxins. In addition, to strengthen the bioaccumulation and biodegradation requirements in this Proposed Standard, EPA Toxic Release Inventory chemicals identified as Persistent, Bioaccumulative, and Toxic (PBT) will be prohibited38. Many halogenated organic solvents are known neurotoxins or carcinogens and are, therefore, prohibited in the Proposed Standard. Ozone depleting compounds are also prohibited. The biocide triclosan is a chlorinated aromatic compound with both phenol and ether functional groups. It is used as a synthetic broad-spectrum antimicrobial agent. Triclosan is common in antibacterial dish soaps. Under the appropriate settings and conditions, such as in hospitals to prevent hospital-acquired infections, triclosan has been proven to be effective. But no current data demonstrate any extra health benefits from having antibacterial-containing laundry care products in ordinary situations. For example, the Center for Disease Control and Prevention (CDC) has stated that antibacterial soaps are not necessary in everyday use, and washing hands with ordinary soap and warm water is an effective way to prevent home infections39. Additionally, bacteria resistant to triclosan have been reported in diverse species and environments, but are not a universal phenomenon. There has been evidence of endocrine disruption by triclosan in animal studies, however, several agencies, including the U.S. Food and Drug Administration and EPA, have determined that further study is required on triclosan40 . Scientists recently found triclosan in 58 percent of 85 streams across the U.S., the likely result of its presence in discharges of treated wastewater41. Triclosan has the tendency to bioaccumulate, or become more concentrated in the fatty tissues of humans and other animals that are exposed to this chemical42,43, 44. Due to evidence suggesting that triclosan bioaccumulates and may cause bacterial resistance to biocides, combined with the CDC conclusion that antibacterial soaps are not necessary in everyday use, it is proposed that triclosan be prohibited under this Proposed Standard. Sodium and calcium hypochlorite, better known as bleach, are widely used inorganic halogen compounds. Sodium hypochlorite is a strong oxidizer. Oxidation reactions are corrosive and solutions 37 EPA. 2010. Endocrine Disruptor Screening Program (EDSP). Final List of Chemicals for Initial Tier 1 Screening. http://www.epa.gov/endo/pubs/prioritysetting/finallist.html 38 EPA. 2010. TRI Chemicals. Accessed 6-24-10. http://www.epa.gov/tri/trichemicals/index.htm 39 EC. 2006. European Commission Scientific Committee on Consumer Products (SCCP) Opinion on Triclosan. http://ec.europa.eu/health/ph_risk/committees/04_sccp/docs/sccp_o_073.pdf 40 FDA. 2010. Triclosan: What Consumers Should Know. http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm205999.htm 41 Kolpin DW, Furlong ET, Meyer MT, Thurman EM, Zaugg SD, Barber LB, et al. Pharmaceuticals, hormones, and other organic wastewater contaminants in U.S. streams, 1999–2000: a national reconnaissance. Environ Sci Technol 2002;36(6):1202-1211 42 Samsoe-Petersen L, Winther-Nielsen M, Madsen T. 2003. Fate and Effects of Triclosan. Danish Environmental Protection Agency 43 EWG. 2008. Pesticide in Soap, Toothpaste and Breast Milk - Is It Kid-Safe?: EWG's Guide to Triclosan. http://www.ewg.org/book/export/html/26700 44 Veldhoen N, Skirrow RC, Osachoff H, Wigmore H, Clapson DJ, Gunderson MP, Van Aggelen G, Helbing CC . 2006. The bactericidal agent triclosan modulates thyroid hormone-associated gene expression and disrupts postembryonic anuran development. Aquatic toxicology. 80(3): 217-227

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may burn skin and cause eye damage, particularly when used in concentrated forms. Further, these chemicals can react with other ingredients to generate chlorinated VOCs45. These chlorinated compounds are toxic and probable human carcinogens. These ingredients are commonly used in laundry care products, but because of their high acute and aquatic toxicity they are already significantly limited and, as a result, do not need to be prohibited. Color Components: Green Seal’s life cycle-based standards support cleaner production and green chemistry which, among other things, aim to reduce the use of unnecessary materials. Such a strategy helps reduce the life cycle costs associated with unnecessary materials, from raw material extraction/production, transportation, distribution, and end-of-life. Since added color ingredients are unnecessary functionally for the products in this standard and thus are not commonly used, the Proposed Standard prohibits their use. Optical Brighteners: Optical brighteners are sometimes added to products to deposit onto fabrics and provide the appearance of enhanced brightness for light colored fabrics. These materials do not clean, remove stains, or actually enhance brightness of textiles and thus are not considered necessary for the main function of the products. Optical brighteners are not biodegradable; however they do undergo photodegradation followed by biodegradation of metabolites. They are typically used in low concentrations in the products and according to the Human and Environmental Risk Assessment (HERA) report the estimated risk for health and the environment is low. Green Seal product surveys showed that optical brighteners are not typically used in the household market. Therefore household products will not be allowed to include optical brighteners above 0.01% in the undiluted product. However, the ability to keep institutional use textiles looking white, even after heavy soiling or repeated washing, tends to have the institutional market rely on optical brighteners. The target market for some institutional products, such as the military, restaurants, and hotels further pushes the industry to provide the whitest possible whites and the use of optical brighteners. Therefore institutional products will be allowed to have a higher level of optical brighteners (than household products), up to 0.01% by weight at the as used level. Concentration and Compaction: Life cycle studies of laundry care products have demonstrated that efforts to concentrate or compact products reduce the environmental burden from these products47,48. As a result, the Proposed Standard includes requirements to concentrate products so the amount of product needed to do a load of laundry is reduced – namely by reducing the manufacturing, distribution, packaging, and end-of-life impacts from having dilute/bulky products. The doses that are proposed are based on a Green Seal survey of products in the market (both household and institutional). Institutional products were found to be slightly more concentrated than household products since more advanced packaging can be used to control dosing of small amounts (e.g., closed dilution-control systems). This is included in the proposed requirements. It was found in this survey that some product types may not be available in concentrated or compacted form such as stain removers, freshners, wrinkle releasers, starch, and static eliminators. As a result, there is only a concentration/compaction requirement for laundry detergent and softening products proposed. The requirements are expressed as a dose per kg of dry, soiled laundry. The dose is expected to be that used for “medium” or “average” loads – not a large or heavily soiled load. For household products the industry convention for dosing tends to be about 2.7 kg (6 pounds) of laundry, which is aligned with market surveys49. While institutional loads are notably larger, the dose can be calculated based on the pound of laundry basis.

Product Stewardship Excellence: Manufacturers of laundry care products have made significant advances in reducing the environmental burden of their products from formulating them with fewer 45 Odabasi, M. 2008. Halogenated Volatile Organic Compounds from the Use of Chlorine-Bleach- Containing Household Products”, Environmental Science & Technology 42, 1445-1451, (2008). http://pubs.acs.org/journals/esthag/ 47 Van Hoof, G., D. Schowankek, T. Feijtel, G. Boeiji, P. Masscheleyn. 2003. Comparative life-cycle assessment of laundry detergent formulations in the UK: part II time trend analysis and wash equivalent comparison (1988-2001). Tenside Surfactants Detergents. 40 (5): 276-287. 48 Saouter, E., G. van Hoof, T. Feijetel, J.W. Owens. 2002. The effect of compact formulations on the environmental profile of Northern European granular laundry detergents: part II life cycle assessment. International Journal of Life Cycle Assessment. 7 (1): 27-28. 49 ASTM International. 2005. Standard Guide for Controlled Laundering Test Using Naturally Soiled Fabrics and Household Appliances. ASTM D2960.

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ingredients (e.g., high-efficiency formulas), designing them to work effectively with low wash water temperatures, highly concentrating/compacting the products, or using minimal packaging or packaging with post-consumer content, among other advances. This product stewardship excellence will be incorporated with the addition of a criterion that requires performance in one of these areas – providing some flexibility to the manufacturer on what they advance in.

Manufacturing Sustainability Requirements The foundational criteria for manufacturing have been included in the Proposed Standard, with no exceptions or changes, including:

• Good Manufacturing Practices • Energy, Water, Air, and Waste • Distribution • Social Responsibility

Packaging Sustainability Requirements The foundational criteria for packaging have been included in the Proposed Standard:

• Concentrated Product Packaging • Disposable Wipes • Heavy Metal Restrictions • Other Restrictions

Exceptions to Foundational Criteria Disposable Wipes: This foundational criterion requires that disposable wipes be based on renewable material and include the state of the art amount of recycled content. This criterion is being revised from the foundational criteria (and would apply to other standards that include it: GS-52 and GS-53). The revision clarifies that wipes as well as towelettes and sheets are included and also that this criterion applies to single-use products (all of which were implied in the original version of the criterion so the revision is simply a clarification). Reusable products do not have to meet this criterion. For laundry care products there are both single-use sheets and reusable sheets. The single-use sheets can be made from cellulose (e.g., “paper”) or other renewable/biodegradable material. The reusable sheets are usually from synthetic polymers like polyester to provide the lasting durability needed for multiple uses. Additional Criteria Primary Package: Primary packaging can be notably reduced through concentration and compaction50. This is the primary means of reducing the environmental burden from packaging (and is already addressed in the Proposed Standard), followed by use of recycled content. In a product packaging survey conducted by Green Seal, 65% of the household, liquid laundry detergent brands surveyed had at least 25% post-consumer content and nearly all of the solid laundry detergent brands surveyed had 35% post-consumer content. While institutional product packages generally do not include post-consumer content (usually due to U.S. Department of Transportation testing requirements that lead to more rigid package needs) they conserve the use of new packaging material by using large containers that deliver

50 Cole, H. 1994. Super-Clean and Super-Green: The Environmental Case for Concentrated Liquid Laundry Detergents. Washington, DC.

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more product per weight of package51. Additional measures to reduce the use of new packaging material for the product have been adopted widely in the industry and thus are expected in more sustainable products. As a result, the primary package must utilize one of these means of reducing the use of new packaging material.

Secondary Packaging: Secondary packaging was generally found to not be used or needed in this product category, so it will be prohibited. Aerosol Packaging: Aerosol packaging is used for some product types including starch, anti-static products, and anti-wrinkle products. These packages are permitted, but must be recyclable and deliver the product in a manner that does not compromise human health (e.g., safe particle size).

Training and Labeling Requirements The following foundational criteria for packaging have been included in the Proposed Standard, with no exceptions or changes:

• Antimicrobial Claims • Plastic Labeling • Organic Claims • Natural and Biobased Claims • Ingredient Line • Consumer and User Communication • Fragrance and Allergen Labeling

Exceptions to Foundational Criteria Statement of Basis for Certification: To ensure compliance with the U.S. Federal Trade Commission’s guidance on environmental marketing claims Green Seal requires that a statement of the basis for certification is included with the Green Seal certification mark. The statement is customized for each standard to ensure that it accurately represents the claim (that is made through the use of the mark). This customized statement for laundry care products is included in the Proposed Standard. Additional Criteria Training Requirements for Institutional Use Products: Training requirements for institutional use products are included to ensure proper use of the products. This is critical for highly concentrated products for safety reasons and for FIFRA-registered products due to the potential for an increase in bacterial resistance to these products. The training requirements also include applicable step-by-step instructions for the proper dilution/dosing and use, consequences of improper use or improper dilution/dosing, disposal of the product and package, and relevant use or maintenance of equipment, as well as recommended personal protection equipment for each stage of the product or equipment’s use. Product manufacturers shall make the appropriate product and/or equipment training information, including safety data sheets (SDSs) and technical data sheets, available electronically as well as in hard copy. Label Language: The label will also be required to clearly explain to the user ways they can help reduce the environmental impact of doing laundry with proper dilution and dosing (for different soil loads, size loads, and water hardness), running full loads, using the coldest water temperature possible, and proper package disposal. To help ensure that professional staff at institutions understands this guidance, institutional products will need to also include the guidance in another language or by using

51 AISE. 2000. Industrial & Institutional Sector Environmental dossier on Professional laundry. http://www.aise.eu/downloads/AISE_pro_laundry_dossier.pdf

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pictures/icons. Institutional products will also need to communicate the pH of the product (on the safety data sheet) so the facility can take appropriate safety measures.

Additional Considerations The original sources of the ingredients in these products have been shown to contribute to the environmental burden. Palm oil-based ingredients, for example, tend to have a high environmental burden from the requirements and current production practices for the crop. However, at this point it has been determined that Green Seal will not include requirements for sustainable raw material sourcing due to the limitations in the market for such materials.