He doesn’t know it yet, but Mikhail’s five year-old son would love Restricted Substances Lists. Trying to make products safer with a checklist of “red-flagged” chemical ingredients bears an eerie similarity to his favorite card game, Go Fish.
Player 1: “Does your product contain any…cadmium?”
Player 2: [looks at cards] “Go Fish!”
Player 1: “Does your product contain any…arsenic?”
Player 2: “Go Fish!”
Player 1: “Well what does it contain?”
Player 2: “Sorry, that’s not how this game works, but you can ask me another chemical if you’d like.”
And this is just what we have seen: longer and more precautionary Restricted Substances Lists, with which manufacturers must comply in order to keep customers. Some “Red Lists” flag entire categories of chemicals like phthalates or antimicrobials, which include thousands of diverse chemicals. This could be a very long game of Go Fish. Worse, when a customer gets to the end of its list, it still might not know what is actually in a product — only what’s not in it.
This sounds like a game in need of a few rule changes. Or maybe just one.
When we teach kids to play Go Fish, we play the first game with our cards face up on the table, which has a rather profound effect on our scenario:
Player 1: “Does your product have any…? Oh wait, I can see all your cards, so I already know what you have!”
Player 2: “Yes, do you have any questions or concerns about what you see?”
Player 1: “We’re not really playing the same game anymore, are we?”
Changing the rules to make transparency the norm is easier said than done, but it is potentially transformative in a way that Restricted Substances Lists are not. A focus on enforcing transparency for all ingredients, rather than cracking down on a handful considered especially bad, creates at least three drivers of toxicity reduction across a much larger range of chemicals:
- Manufacturers may quietly eliminate ingredients already known to be problematic, so as not to be obligated to disclose them.
- Manufacturers will begin to scrutinize ingredients they may not have realized were in their products.
- Customers and advocates will provide feedback on disclosed ingredients, driving product reformulations.