Danica Lavoie | Analysis Assignment #1 | Daniel Pottage 300561197Kudrot-E Elahi- 300473523 |

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Due Date: September 28th 2011
Revised Due Date: October 3rd 2011

BUSN226 - Marking Rubric – Assignment #1
Your name: ___________________________________________________ Rubric attached to front of assignment | /1 | Cover page and page numbering | /4 | Introduction | /5 | Four summaries (if article not different from other group members, summary will not be marked) | /20 | MLA reference provided at end of each summary | /8 | Integrated RefWorks bibliography | /8 | Original articles attached (each article must be different from other group members, otherwise, it will NOT be marked) | /4 | Late? | | Total out of 50 | /50 |

Introduction The industry that my group is working on is the cleaning products industry. In specific I am talking about Colgate-Palmolive which is a globally diverse corporation that is involved in many different aspects of business including a personal care division, an oral care division and a home care division. I will be analyzing a product that is included under the home care division, Ajax, a multi-purpose cleaner used in many different cleaning processes both residential and industrial. The main competitor to Ajax is a product called comet that is very similar to Ajax in that it is available in many different forms and scents and the company that produces it is called prestige Brands and they purchased the product in 2005 from the main competitor of Colgate-Palmolive, Proctor and gamble. Both Colgate-Palmolive and Proctor and gamble are members of an association called the American cleaning institute which oversees the representing producers of household, industrial, and institutional cleaning products, their ingredients and finished packaging; chemical producers; and chemical distributors to the cleaning product industry.
Summaries
Article 1
The first article that I have found for this assignment is called “The filth element: Why we're getting dirtier; we’re buying fewer cleaning products and finally getting our hands dirty. Bring on the squalor, says Rhiannon Harries.” The first part of this article really stood out to me because it had some interesting trends in the cleaning products industry that I did not know about including declining sales in the North American market and increasing sales in the European market. While the article cannot say exactly what the cause of the loss of sales is, they guess that because the trend has continued down to be a sign that this is not an economic trend but more of changing social factors, “Careering along the recessionary curve, it's tempting to diagnose our every move as a cultural symptom of economic illness... . But Mintel's 2011 report on the household-cleaning products market in the US concluded that four years of decline suggest something more significant than a recession-driven downturn.” This would lead me to believe that even though sales are slow in developed economies it would be the developing nations that are keeping profits at the same level. Also in this article they mention that items used to clean between daily showers, like dry shampoos and hand cleansers are faring quite well in most markets, especially the European market. Another factor that may be contributing to the decline in the sale of cleaning products is that while 80% of people surveyed said they value a clean home, only half of the respondents did more than clean as they go and less than one third confess it is the last thing that they wish to do in their free time. One factor that most people do not take into consideration when thinking about the decline in sales is that for 40 years the social factors made it necessary to have clean homes but as we get into the 21st century we have less of a dependence on cleaning and higher rates of autoimmune disorders including asthma and allergies. Some scientists attribute this to having homes and environments around children to clean which is making their immune systems weaker thus increasing the amount of allergies and asthma cases, “The "hygiene hypothesis" raises the possibility that our increasingly sterile environment is related to rising rates of allergies, asthma and autoimmune disorders in the Western world.” The final thought that this article leaves with the reader is that it might not be necessary to have your house and office spotless constantly but that it may be more beneficial to clean less and try to stop proving that cleaner is better.
"The Filth Element: Why we’re Getting Dirtier; we’re Buying Fewer Cleaning Products and Finally Getting our Hands Dirty. Bring on the Squalor, Says Rhiannon Harries." Independent.co.uk September 4 2011. Web.
Article 2
The second article that I have found for my research is one that is about Colgate-Palmolive Company and a recent decision that the company has made to keep triclosan in its crest toothpaste products. The problem with this decision is that it has angered many of their customers because the FDA is conducting research into the health effects this product may have on consumers. Most people believe that this choice was made by the board of directors just to keep the profits continuing at their current pace because this brand is estimated to be worth about one billion dollars. According to this article the company may have another reason to keep this ingredient in their product which is the increasing market share of their competition in key segments that they dominate. One of the reasons that this has so many consumers, regulators and legislative bodies are upset it’s that although Colgate has opted to remove triclosan from its dish soaps but not from its toothpastes, “It's part of an effort to fight off inroads by Procter & Gamble Co.'s Crest ProHealth, which makes similar gingivitis-fighting claims based on use of a form of fluoride instead.”. One of the more interesting points in this article is that the FDA has already conducted studies on this ingredient and deemed it safe for public consumption in small doses in consumer goods products, also in 1997 they did another study to determine if triclosan was effective at fighting gingivitis and found that it was effective and also gave Colgate permission to use it in their Total toothpaste brand. “The Food and Drug Administration approved use of triclosan as safe and effective for prevention of gingivitis in Colgate Total in 1997, and that hasn't changed. The pesticide and fungicide has been approved since 1972 for use in low doses as an antibacterial ingredient in a wide range of other products.” The most disturbing fact that I uncovered in this article is that 75% of Americans studied had at least some amount of triclosan in their urine and this has been linked to many different medical issues, “recent studies have linked triclosan to disruption of endocrine systems of rats-including thyroid function and production of sperm, testosterone and estrogen. The chemical can be found in the urine of 75% of Americans, according to the Centers for Disease Control.” I find this very disturbing considering the government body that was created to help keep consumers safe is letting companies use products that they are just now finding the problems with. Most companies that have been using this ingredient in their products have stopped using it or are working on a re worked formula that will triclosan taken out of the picture, most of these products were dish soaps while a few were consumer goods like toothpaste and deodorant. In 2009 the European Union conducted a study into the uses of triclosan in cleaning and consumer goods products and they decided to that in small doses this ingredient was safe to use.
NEFF, JACK. "Colgate Keeps Triclosan in its $1B Total Brand." Advertising Age 82.4 (2011): 5-. Web.
Article 3
The third article that I managed to find for this project was about chemical product testing on animals and that this is stills an issue for companies that use chemicals in their products. In recent years it has become common place for companies to have to demonstrate safe use and levels of chemical components in products they wish to market. As more and more products are being released in to the cleaning product market it is requiring much more regulation to ensure that these products are safe for consumer use. Although animal testing is believed to be declining in recent years, it would seem that the opposite is true, “Figures released by the Home Office last week show that 3.7 million 'procedures' involving individual animals were carried out in 2010 Ñ a million more than in 2000.” Many of the companies that are involved in animal testing do not even end up with a choice due to new legislation introduced in the European union last year that requires every component of a cleaning product to be tested and a dossier must be made up to describe effects, physical and psychological, if any exist. Also the more a chemical is used in products the more in-depth the research needs to be. One of the reasons so many people are upset over this is that many of the chemicals have been available on the market for years and they were deemed safe until this year and now the onus is on the producing company to prove its product is safe for sale. In the case of Colgate-Palmolive they were required to test their Ajax brand cleaner and put together a dossier to submit to the REACH program. REACH stands for Registration, Evaluation, Authorization and Restriction of Chemical Substances and was designed in 2010 to address rising concerns about unregulated cleaning products. Many of the products that have to undergo testing have been in the market place for over a decade but are only now being checked to ensure safety. Many activists believe that using animals to test products already deemed to be safe is just needless and estimates have put the number of animals killed in testing be as high as 8 million, “The RSPCA, a calm head in the middle of a heated debate, told me this week that its experts predict an animal death toll of around eight million as a result of REACH. And when unborn foetuses carried by those animals are taken into account, that figure could rise to 50 million.” Many consumers, companies and activists are unhappy with the new laws regarding the testing of chemicals but the lack the resources or the means to do anything about it.
"Why 8 Million Animals Face Death to Test Your Toothpaste and Washing Liquid." DAILY MAIL (London) July 29 2011. Web.
Article 4
This article is all about the industry that represents cleaning product companies and manufacturers, the American Cleaning Institute. This industry was formally called the soap and detergent association and has been around since 1926; there main responsibilities include overseeing the production and sale of cleaning products and the benefits as well as dangers of cleaning products. The ACI has partnered up with the FDA to come up with a set of regulations and criteria that companies would have to meet to be able to say they have a green or environmentally friendly product. Many of the products out right now are using different marketing claims to sell their products to environmentally friendly consumers even though they know they are misleading the consumer with what they say or advertise. The reason that this is able to take place right now is that there is no central body that oversees the green labelling of products and so companies can apply to various programs to get different green certifications and half of those are not even run by government organizations. Another factor that is upsetting the ACI and the FDA is that companies are claiming to offset carbon output with certain products and they are not mentioning that the saving will not be realized for years or that they were required by the law to do so. Under the new regulations you would only be able to make claims of carbon offset in cases where the saving would be realized in less than 2 years and in cases where it is not legally required to do so. Many companies are anxiously awaiting the results of the inquiry into green labelling because they want to have very black and white rules about what they are allowed to do and say and what they will get in trouble for saying or producing. Currently the only Government department that has a program in effect to judge the effectiveness of environmentally friendly products is the EPA (Environmental Protection Agency), “The DfE voluntary initiative allows manufacturers that meet set criteria to use the DfE label, which "enables consumers to quickly identify and choose products that can help protect the environment and are safer for families," the EPA says.” One of the main goals of the new program is increased regulations on packaging instructions and ingredients lists. Every product must either have the ingredients listed on the side of the container, on the website of the manufacturer, distributor or importer; via a toll-free telephone number; or through other non-electronic means. The ACI is also releasing its first ever sustainability report which will give details on the innovations taking place at the ACI as well as member companies and organizations. So of the ideas that are being used by various companies including: "Some firms are focusing on concentrated detergents, some on reducing packaging, others on cold water detergents, and others are using animal and vegetable oils as their main feedstock’s,". Due to the state of the regulation around enviromentlay friendly products the ACI is committed to working with other organizations and companies to be able to work out rules and regulations that everyone in the industry can agree on as well as supporting global integration or regulations and governing bodies.
D'AMICO, ESTHER. "ACI Focuses on Clear Green Labelling." ICIS Chemical Business 279.4 (2011): 32-3. Web.

Works Cited
D'AMICO, ESTHER. "ACI Focuses on Clear Green Labelling." ICIS Chemical Business 279.4 (2011): 32-3. Web.
"The Filth Element: Why we'Re Getting Dirtier; we'Re Buying Fewer Cleaning Products and Finally Getting our Hands Dirty. Bring on the Squalor, Says Rhiannon Harries." Independent.co.uk September 4 2011. Web.
NEFF, JACK. "Colgate Keeps Triclosan in its $1B Total Brand." Advertising Age 82.4 (2011): 5-. Web.
"Why 8 Million Animals Face Death to Test Your Toothpaste and Washing Liquid." DAILY MAIL (London) July 29 2011. Web.

The filth element: Why we're getting dirtier;
We're buying fewer cleaning products and finally getting our hands dirty. Bring on the squalor, says Rhiannon Harries

SECTION: HEALTHY LIVING

LENGTH: 1008 words
For several weeks last year, I shared my kitchen toaster with a tiny mouse. I wasn't thrilled by the situation, but I put my faith in 150°C of germ-killing heat action, lay awake thinking about more pressing problems and, evidently, lived to tell the tale. Merely reading about such slatternly ways is probably enough to have the hygiene freaks among you reaching for your hand sanitizer. But before you judge, squeaky-cleaners, beware. For despite your precautions, your antiviral tissues and your twice-daily showers, it's you that may be the dying breed. As Mary Douglas wrote in that sociology classic Purity and Danger, dirt exists in the eye of the beholder.
Some alterations in our habits speak directly of this trend. We simply aren't spending as much on cleaning as before, which the giants of the consumer-product industry have witnessed to their chagrin, in the UK and throughout Western Europe and North America. Although Reckitt Benckiser, whose brands include Dettol and Clearasil, posted better than expected half-year profits in July, it was the surging demand for household and personal care in emerging markets that put a sheen on poor growth in developed economies such as ours.
On the flipside, products that effectively bridge the gap between less-than-daily head-to-toe bathing sessions are faring well. For instance, British sales of dry shampoo, long considered a fusty 1960s throwback, are buoyant. In the men's market, Unilever has just ploughed £5m into promoting its latest 48-hour deodorant to the Lynx range (as if reeking of it for 24 weren't enough).
Careering along the recessionary curve, it's tempting to diagnose our every move as a cultural symptom of economic illness. Since most of us now classify ourselves poorer in terms of both cash and time, it follows that investing in an arsenal of cleaning products, or even making it out in clean socks every other day, are simply beyond us. But Mintel's 2011 report on the household-cleaning products market in the US concluded that four years of decline suggest something more significant than a recession-driven downturn. And here in the UK, its research reveals that although 80 per cent of us say we value a clean home, almost half admit we're unable to do more than clean up as we go along and a third confess that cleaning is the last thing they feel like doing in their free time. We may like the idea of a spotless home, but when it comes to the crunch, it's not top of our priorities. What's more, in areas not immediately connected to the business of hygiene, we're actively choosing, indeed paying, to get a little dirty.
Head to many British parks at the weekend and you'll witness legions of "military fitness" devotees forgoing air-conditioned, sanitary gyms in order to perform their push-ups on damp grass. Although not as bold as barefoot-running, it takes faith in the pooper-scooping practices of one's fellow man to crawl, commando-style, across Clapham Common. As for festivals, where once upon a time three days of baby-wipe strip washes, knee-deep mud and portable "facilities" were once confined to an "alternative" scene, who wouldn't now cough up a couple of hundred quid to get grubby in a field for a weekend?
It's worth noting that since 2005, Persil, Britain's top laundry brand, has run with the slogan "Dirt is good", emphasising creativity in getting messy. The approach was hailed by some industry insiders as insanity for a sector that traditionally trades on a "whiter than white" promise, but by others as genius. The Unilever brand has stuck by its dirt-friendly core philosophy, suggesting it was ahead of the game in identifying the changing mood. Katherine Ashenburg, the author of Clean: An Unsanitised History of Washing, agrees that an attitudinal shift is unfolding that runs deeper than our shrinking finances: "I think we're washing less for health reasons in particular - as supposedly we are washing away all kinds of good bacteria and making our skin dry out - as well as for environmental reasons."
The idea that our war on microbes might mean a Pyrrhic victory for our health dates back to the 1980s. The "hygiene hypothesis" raises the possibility that our increasingly sterile environment is related to rising rates of allergies, asthma and autoimmune disorders in the Western world. It remains a controversial piece of science, but one that advertisers have perhaps ignored to their peril. Revealingly, the growing backlash appears strongest among women, the historical prime targets of a cleanliness message that pressed antibacterials on nervous new mums, "intimate" sprays on paranoid single gals and a raft of cleansing and purifying beauty products on everyone.
Log on to Mumsnet and you'll find plenty of competitive slummy mummy-ness, where a floor you can eat your dinner off is no longer as much a badge of honour as letting your kids eat dinner off the floor, whatever its state. If it seems a victory for feminism, however, it's worth considering a different kind of pressure at work: the prissy 1950s housewife template might be out, but could it have been replaced by a more subtle form of self-presentation? As certain female starlets know only too well, dirt and sex go hand in hand. Edgier types such as Kate Moss have long harnessed rock'n'roll dishevelment to great effect, but even nation's sweetheart Cat Deeley, star of Pantene's latest haircare range no less, confesses that when she's not working she doesn't bother washing her hair.
Still, as ideals go, it's one that most of us can feel confident of achieving. And to those of you wedded to your chemical cleaners and "worn once" machine cycle, consider the following. In a New York Times article last year, "The Great Unwashed", Americans from all walks of life extolled the virtues of a pared-down hygiene regime - dubbed "European-style". Maybe we're right to give up trying so hard to prove otherwise.

Colgate keeps triclosan in its $1B Total brand
But marketer replaced pesticide/fungicide in dish detergent amid consumer, regulatory scrutiny
Colgate-Palmolive Co. in recent months has begun removing triclosan from dish detergent amid growing consumer, regulatory and legislative scrutiny of the antibacterial ingredient. But it's still the key active ingredient in Colgate Total Toothpaste, a billion-dollar-plus global brand.
Even as Colgate last year was rolling out a reformulated version of Palmolive antibacterial dish detergent with lactic acid in place of triclosan, it was significantly stepping up advertising from Y&R, New York, touting the germ-fighting power of Total with triclosan. It's part of an effort to fight off inroads by Procter & Gamble Co.'s Crest ProHealth, which makes similar gingivitis-fighting claims based on use of a form of fluoride instead.
The Food and Drug Administration approved use of triclosan as safe and effective for prevention of gingivitis in Colgate Total in 1997, and that hasn't changed. The pesticide and fungicide has been approved since 1972 for use in low doses as an antibacterial ingredient in a wide range of other products.
But recent studies have linked triclosan to disruption of endocrine systems of rats-including thyroid function and production of sperm, testosterone and estrogen. The chemical can be found in the urine of 75% of Americans, according to the Centers for Disease Control.
In response to such data, the FDA last year launched a review of triclosan's safety as an ingredient in consumer products, results of which it expects to report this spring, possibly along with proposed regulations. The FDA noted last spring that while triclosan has been found clinically effective in preventing gingivitis, it hasn't been found to work any better than regular soap and water for handwashing.
The moves by Colgate and rival Reckitt Benckiser to remove triclosan from some consumer products came to light late last month when Rep. Ed Markey, D-Mass., who has led a charge for regulatory re-examination of triclosan, released letters he'd received from several consumer marketers.
RB and Unilever said they sell some professional handwash products with triclosan, but either had or were discontinuing use in consumer products. Procter & Gamble Co. and Henkel (maker of Dial) continue to use the ingredient in some dish and hand soaps, respectively.
All pointed to determinations by the FDA and authorities in the European Union finding triclosan safe to use in consumer products, and Henkel noted 2008 research showing triclosan does kill germs better than washing with soap alone.
Even so, there's a notable shift away from triclosan in product formulations.
An RB spokeswoman said in a statement the company will launch a triclosan-free Clearasil face wash this year. "Reckitt Benckiser restricts the use of triclosan to licensed medicinal, over-the-counter drug, cosmetic and toiletry products where it is necessary for specific therapeutic activity," she said.
A Colgate spokesman in an email explained the shift away from triclosan for Palmolive Ultra Antibacterial dish soap as "an improved formula" that's the only dish liquid approved to kill 99.9% of bacteria on dishes in seconds.
In a May letter to Mr. Markey, Colgate Senior VP-General Counsel Andrew Hendry said the formulation changes "reflect the ongoing preferences of Colgate-Palmolive's consumers and other constituents" but reaffirmed the safety and efficacy of Total and anti-bacterial versions of Softsoap, which also continue to contain triclosan.
Colgate is supporting Total with stepped-up advertising, he said, via a global relaunch that started in November in the U.S. focusing on its ability to provide 12-hour protection against gingivitis-causing plaque. Gingivitis can lead to periodontal disease, which in turn has been linked to heart disease, stroke and diabetes, he said, adding that more than 75 peer-reviewed clinical studies affirm the safety and effectiveness of Total-more than any other toothpaste.
Total is the crown jewel of Colgate brands, likely accounting for more than $250 million in sales in the U.S. alone, said a consultant in the oral-care industry. He sees more regulatory scrutiny of triclosan as "a potential disaster" for Colgate, but said it's unlikely the FDA will take a tougher stance on it than the EU did after a 2009 review.
WITH AND WITHOUT: Palmolive was reformulated without triclosan; Colgate and some varieties of Softsoap still have it.

WHY 8 MILLION ANIMALS FACE DEATH TO TEST YOUR TOOTHPASTE AND WASHING LIQUID
DAILY MAIL (London)

July 29, 2011 Friday

LENGTH: 1927 words
STEVE BOGGAN
Clad in her customary white coat, the scientist carefully pulls the latex gloves up over her wrists and walks slowly towards the cage. Reaching in, she seizes one of the rabbits, cowering near the back and clamps it into a testing harness.
Taking it over to a sanitised laboratory bench, Dr Tamsin Decker supervises as solution is squirted into the defenceless animal's eyes. She has done this many times before Ñ and will watch as it's done again until the rabbit shows some side-effects: pain, irritation, bleeding perhaps, and eventually, possibly, blindness.
For what cause must the animal endure such a wretched, tortured existence? Once upon a time, Dr Decker would have imagined it was to find a cure for cancer, or, at the very least, to test a compound which would relieve suffering.
But now the young woman knows that she is verifying the safety of a chemical contained in toothpaste Ñ a well-established brand leader that she had used to brush her teeth that very morning.
'I felt numb Ñ no, guilty,' she admits afterwards. 'It isn't as if the end justified the means. We weren't researching some cancer cure here. We were testing a well-known chemical that has been used in household products for more than 100 years.'
On other days, Dr Decker might be required to inject mice, birds or rats with toxins to see how long it takes them to die, or to record what happens to their foetuses.
Contrary to popular belief, scientific testing on animals is not a thing of the past, nor is it in decline.
Figures released by the Home Office last week show that 3.7 million 'procedures' involving individual animals were carried out in 2010 Ñ a million more than in 2000.
And evidence is emerging that large numbers of animals are dying needlessly, simply because of a new directive from Brussels which demands that 30,000 chemicals are tested.
The project, entitled the Registration, Evaluation, Authorisation and Restriction of Chemical substances Ñ or REACH Ñ has at its heart a noble desire to safeguard the environment and limit our exposure to hazardous substances.
But, as a Daily Mail investigation has uncovered, many of these chemicals are already found in household products which we have been using for generations Ñ brands such as Colgate toothpaste, Ajax cleaner, Gillette shaving foam and Fairy washing-up liquid.
Yet, as a consequence of the European Commission diktat, animal welfare groups claim that millions of creatures will die needlessly to test chemicals in products which have already been deemed safe.
Not only that, the European regulations are so far-reaching that it is slowly becoming impossible for consumers to buy 'ethical' products whose ingredients have not been tested on animals.
'I'm from the generation that was determined to do as little harm as we could to animals, and we have come a long way in finding alternative testing methods,' says Dr Decker. 'But for some tests you can only use animals Ñ and many of us think that we shouldn't be using them to test chemicals that we already feel are safe.'
Decker is not her real name, and we cannot disclose exactly what she was testing for fear of identifying her employers. In addition, scientists are being gagged by their employers, who don't want to be seen to be complaining about REACH in case it makes them look unwilling to do their bit for the environment.
REACH was launched in 2007 and required companies to produce dossiers on all the chemicals in the products that they manufactured, including evidence of their safety Ñ no matter how long they had been in production. The more of the chemical they produced, the more detailed the evidence required.
After lobbying from animal welfare groups such as the RSPCA, which predicted wholesale destruction of animals, companies were encouraged to share information to prevent unnecessary testing, and to find alternatives to animal testing wherever possible.
Earlier this month, the European Chemicals Agency (ECHA), which oversees the REACH project, published its first progress report which said that of almost 25,000 dossiers that had been submitted by companies on chemicals that they used, 'only' 1,849 had involved new animal test results.
Geert Dancet, the ECHA's executive director, argued that this was good news. 'This report clearly shows that companies have shared data or made extensive use of alternative [testing] methods available so as to avoid the need to test chemicals on animals, which is positive,' he said.
However, when animal welfare scientists trawled through the long and minutely-detailed report, they came to the conclusion that even though only a small proportion of the data on chemicals had been garnered from animal testing, no fewer than 87 per cent of the animals in those tests had died.
Assuming internationally accepted models for animal studies had been observed, the British Union for the Abolition of Vivisection (BUAV) claims this amounts to more than 231,000 pointless deaths.
'It is a completely unnecessary waste of life,' says Dr Katy Taylor, BUAV's senior scientific adviser.
Among these 'unnecessary' tests were 188 studies on eye irritation carried out on rabbits; 336 skin sensitisation studies on guinea pigs or mice; 254 short-term toxicity tests on fish; and 33 genetic toxicity tests on mice. The number of animals in each study is thought to range from one to 500.
Dr Taylor argues that instead of testing animals to destruction, there are computer models that can predict reactions, while chemicals can be tested on cell cultures and artificially grown skin in the lab.
Under REACH, where companies do need to test on animals, they must first announce their intentions to the European Chemicals Agency to see if any other company or academic centre has already carried out such tests. If no one has, then they are given a licence to test.
So, does this mean that you are buying products with ingredients that have been freshly tested on animals? Probably, yes. I looked at just eight chemicals that had been tested on animals under REACH, and they led to some nasty surprises.
Even though animal testing on cosmetics was banned in the UK in 1997 and across Europe in 2009, I found that Colgate toothpaste and Gillette shaving foam contained ingredients that were tested on animals only recently.
This is no poor reflection on these companies, as they may have played no direct part in the testing.
In Colgate's case, calcium carbonate Ñ a substance used for hundreds of years and found naturally in rocks, eggshells and pearls Ñ had to be tested under REACH. In the case of Gillette, the substance was triethanolamine, a compound used for generations in household cleaners, polishers, paints, inks and detergents. Again, this doesn't mean that Gillette commissioned testing on the substance. It just raises questions over why the new testing on animals was necessary at all.
I also found recently tested ingredients in Persil 2in1 With Comfort (triethanolamine); Ajax cleanser with bleach (pentasodium triphosphate and calcium carbonate); Turtle Wax leather cleaner & conditioner (triethanolamine); and Fairy Liquid Green Apple & Lime Blossom (geraniol, a fragrance).
So I asked Wim De Coen, head of unit evaluation at the European Chemicals Agency, why animals are dying to test such apparently commonplace and harmless ingredients. 'REACH comes historically from the realisation that substances were on the European market that consumers and the environment were exposed to daily, but very little information was known about them,' he told me.
'The intention is to protect consumers and the environment from these substances. So manufacturers and importers must now demonstrate their safety.'
Asked whether he understands the frustration felt by some scientists over testing ingredients already agreed to be 'safe', he says: 'If you look at it from a lab or single company's point of view, to their way of thinking it may be frustrating, but to the broader benefit of all of us there is much to be gained by collecting the information. Animal testing is the last resort.'
I asked Unilever, Procter & Gamble, Colgate and the Turtle Wax Corporations, manufacturers of the affected items, how they felt about their ingredients being tested under REACH.
Only Procter & Gamble replied, saying it tests on animals only where required to by law and when all other options have been exhausted.
Diplomatically, it pointed out that it has spent £275 million developing alternatives to animal testing, but it didn't address my direct questioning about the frustrations of animal testing under REACH.
However, I was able to gain an insight into how the chemical companies view the legislation through the eyes of a scientific consultant who advises them on how to comply with it. Fearful of speaking out openly against the European Chemicals Agency, he refused to be named, but branded REACH 'an expensive nuisance'.
'Companies have been producing some products for more than 50 years without any harmful side-effects, and then they have to provide data under REACH,' my source told me.
'My clients don't want to carry out these tests on animals, but they have no choice. They are time-consuming and they can be staggeringly expensive Ñ as much as one million euros over two or three years. It's a huge responsibility that's been put on the shoulders of the chemical industry.'
According to Andrew Butler, founder of Lush, the ethical cosmetics company, it is a responsibility that is spilling over into the retail sector and undermining the founding principles of his business
'Since our inception, it has been our aim that none of our customers' money goes to any company involved in any animal testing whatsoever,' he tells me.
'Thanks to REACH, it's impossible to buy ingredients from anyone who hasn't been involved in animal testing. Every manufacturer is being forced into a position where they are having to pay directly or indirectly for those tests.
'We have to rethink our policy and come up with a way of campaigning against animal testing in the light of REACH. But it isn't going to be easy.'
No one is denying that the aims of REACH are admirable, and that it could provide a vital resource in safeguarding the environment and the health of all Europeans. At present, however, it is the health of millions of animals that is exercising campaigners.
'We want chemicals that are safe for people and our environment, just like everyone else, but animal tests are not required to achieve this goal,' says Alistair Currie, policy adviser at People for the Ethical Treatment of Animals (PETA). 'There are lots of ways that companies can avoid using animals: the scandal is that those testing alternatives aren't being used.
'Fine words in the legislation about using animals as a last resort are meaningless if companies ignore them. Unless companies are compelled to exploit every opportunity to use alternatives to animal testing, there will be millions of completely avoidable deaths in the future.'
Millions? Surely that's an exaggeration.
Sadly, no. The RSPCA, a calm head in the middle of a heated debate, told me this week that its experts predict an animal death toll of around eight million as a result of REACH. And when unborn foetuses carried by those animals are taken into account, that figure could rise to 50 million.
As Dr Decker says: 'You might understand it if there was a cure for cancer at the end of all the suffering. There won't be Ñ but at least you'll be safe in the knowledge that your Fairy Liquid won't do you any harm.'
But perhaps your grandmother could have told you that.

ACI focuses on clear green labeling
American Cleaning Institute CEO Ernie Rosenberg seeks to cut through the chaos and help send an unambiguous message to consumers
The proliferation of seals and certifications touting the environmental benefits of products has grown in recent years as marketers aim to capture the environmentally conscious consumer's attention. But some claims are too generic, confusing or even misleading consumers into believing that one product is, across the board, environmentally preferable to another. This problem has attracted the attention of regulators and is a major concern for trade body the American Cleaning Institute (ACI).
"It's chaos out there in the market because there are so many different programs with so many different criteria," says Ernie Rosenberg, ACI president and CEO. A claim may relate to only one particular aspect of a product, but that fact might not be apparent to consumers, he says.
The Federal Trade Commission (FTC) has set out to address the confusion with proposed revisions to its Green Guides, which aim to steer marketers into qualifying their green product claims. The revised guides advise against making general claims that a product is environmentally friendly or eco friendly because "such claims are likely to suggest that the product has specific and far-reaching environmental benefits," the agency says.
The FTC also cautions against using "unqualified" seals and certifications, or those that do not specify the basis for the certification. How consumers perceive claims such as degradable, compostable and "free of a particular substance is also questionable. For example, the commission says: "If a marketer claims that a product that is thrown in the trash is 'degradable,' it should decompose in a 'reasonably short period of time' -- no more than one year."
Additions to the guides include the use of "renewable materials" and "renewable energy" claims, which consumers may interpret differently from how marketers intend, the FTC says. For example, the guides caution marketers against using unqualified renewable energy claims "if the power used to manufacture any part of the product was derived from fossil fuels."
Carbon offset claims are another addition to the revised guides. Marketers are urged to disclose if greenhouse gas emission reductions that are being offset by a consumer's purchase will not occur within two years. They are also advised to avoid advertising an offset if the activity that produces it is already required by law.
The commission is now reviewing public comments on the proposed revision's.
"The FTC is saying that if you make a general claim, you have to specify which aspect of the product's performance or content is underpinning the claim," says Rosenberg. "The guides will help bring some order to this by making the claims relate to what are the real benefits to these products."
SEEKING CLARITY
The ACI supports the FTC's efforts to clear up dubious claims, but has asked it to clarify the final guidelines "so companies know what they do and do not need to do" when making claims. "Our companies would like to see a very clear roadmap of what is OK and what is not," says Rosenberg.
"This is very important to us because it is the first -- perhaps the only -- thing that will really impose discipline on the claims that are being made. This is the first effort that addresses the validity of these claims."
At present, the Environmental Protection Agency (EPA's) Design for the Environment (DfE) is the only government program that certifies products as being environmentally preferable, says Rosenberg. The DfE voluntary initiative allows manufacturers that meet set criteria to use the DfE label, which "enables consumers to quickly identify and choose products that can help protect the environment and are safer for families," the EPA says.
Last year, the ACI shared a victory with the US-based Consumer Specialty Products Association and the Canadian Consumer Specialty Products Association when the EPA developed product ingredient communication criteria under D£E that is similar to the trade groups' own initiative. Launched last January, the trade groups' initiative gives member companies the option to list ingredients on product labels; on the websites of the manufacturer, distributor or importer; via a toll-free telephone number; or through other non-electronic means.
TSCA REFORM A PRIORITY
Meanwhile, reform of the EPA's Toxic Substances Control Act (TSCA) remains one of the ACI's top priorities. "We still want to see the TSCA modernized," says Rosenberg. "This has been a top priority for us in 2009 and 2010." A modernized TSCA would boost public confidence in responsible management and regulation of chemicals, he adds.
Several areas under the TSCA are of particular concern, including the EPA's request to limit the number of confidential business information (CBI) claims for ingredients, says Rosenberg. The ACI seeks protection of "legitimate" CBI claims because many CBI claims involve proprietary ingredients, he adds.
Companies spend a lot of time and money on product innovations that involve proprietary information, which should be protected from competitors, says Rosenberg. Without this, companies risk the release of proprietary information or trade secrets in areas where they have spent heavily, such as green chemistry and sustainability.
"You can have greener products. You can release all the information about the product that the companies consider confidential. You can't have both," he adds.
Rosenberg says the protection of confidential business information "is popping up in a number of places," including under California's Green Chemistry Initiative. This initiative focuses on consumer product ingredients and, when possible, substituting safer alternatives.
California is the eleventh-largest economy in the world and its regulations could have consequences for manufacturers nationwide, says Rosenberg. "We are spending a lot of effort to make sure the California provisions are risk-based and aren't just blacklists for certain chemicals."
A key component of the initiative is the California Department of Toxic Substances Control (DTSC's) proposed regulations for Safer Consumer Product Alternatives. These would create a process for prioritizing chemicals of concern and encourage safer alternatives.
The ACI is part of the Green Chemistry Alliance (GCA) trade group association, which is calling for the DTSC to remain focused on a science-based system of chemical management. The DTSC revised its proposed regulations last year, but problems remain, according to the GCA.
"One of the largest continuing problems is a failure to enunciate more clearly the criteria and process for consistently and systematically identifying and prioritizing chemicals of concern and priority products," the GCA told the agency in a recent letter. "Instead of a process, the regulations focus on three product categories for a five-year period, after which time all restraint is lifted."
Other areas the ACI is focusing on this year include its first sustainability report, which will cover the activities of the institute and its member firms. "Our big issues are chemical management and sustainability," says Rosenberg, "and industry has not always been given a lot of credit, especially for the latter." The sustainability report may help fix that by high-lighting, for example, various ways that companies are saving energy, water, and other resources, he adds.
The report will include aggregated sustainability metrics data from some member firms, which might be used as future benchmarks for industry, the ACI says. The report is due to be available to the public on the institute's website this spring.
SUSTAINABILITY AND INNOVATION
Sustainability also plays a role in many recent product innovations. "Some firms are focusing on concentrated detergents, some on reducing packaging, others on cold water detergents, and others are using animal and vegetable oils as their main feedstocks," says Rosenberg.
"Everybody has different things they're working on. That's why developing sustainability programs that cut across all companies is difficult. On a practical level, it makes sense to focus on metrics that can be applied across the board, such as energy and water reduction."
Although demand for more sustainable products is coming largely from big-box retailers and some consumer groups, says Rosenberg, "it is not really clear how much of a real difference it is making… yet." He adds: "We are seeing some indications of 'green fatigue' -- people are getting tired. Market share growth in the 'green product' category, based on some studies and anecdotal evidence, has been slow."
Even so, more cold water detergents and higher-efficiency detergents and machines are expected to hit the market in coming years. Phosphates were removed from home dishwashing detergents last July, and research and development (R&D) is underway to make them more efficient.
Surfactants are also getting a lot of R&D dollars. Rosenberg says product development areas include "surfactants that work well in cold water cleaners, work well in concentrated formulas, and surfactants that are increasingly biodegradable." But these are not the only area of innovation work. Rosenberg says "a lot of work" is being done to develop more environmentally friendly ingredients and reduce waste overall.
"It's chaos out there in the market because there are so many different programs with so many different criteria"
ERNIE ROSENBERG