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.
Glad you liked the post. You
Glad you liked the post. You raise a great question about PVC, and we will address it in the detail it deserves in an upcoming GreenBiz post (radical transparency means addressing the tough questions). For now, let me say that our baseline commitment regarding PVC is to eliminate the use of all virgin plastic and petrochemicals (including PVC) by 2020 as part of our Mission Zero commitment. While we are currently exploring multiple pathways for our future carpet backing materials, any path we choose will include closing the loop on our products and eliminating the use of virgin PVC (and thus the upstream impacts associated with its production).
Thanks for replying, Mikhail.
Thanks for replying, Mikhail. I appreciate it. A couple of questions for your future post.... Does "elimination of all virgin plastic/virgin PVC" also mean eventual elimination of all PVC even in recycled form? Elimination of upstream impacts are important. But, what about downstream impacts associated with PVC being out there in the world where it's subject to release of dioxins through controlled and uncontrolled incineration, release of degradation byproducts over time, and recycling of the material which isn't very clean either (i.e. release of persistent/bioaccumulative degradation byproducts, erosion of equipment from HCl generation, etc).
I appreciate folks and companies who are intellectually honest and willing to answer the tough questions. It brings credibility to the organization and the people working with in it.
I'm glad to see this article
I'm glad to see this article being written, and the message getting out there about RSL vs. Full Disclosure. This conversation has been going on in some circles and industries for the last 7 years, especially those that chase green certifications like C2C. I think the main points are spot on.
I'm also glad that Interface is sharing more about their commitment to address chemistry. Interface is frequently spoken of with reverence in green circles. However, the one absolutely glaring healthy chemistry issue they face--and have not really spoken out about--is how or if they even plan to get out of PVC. There are just so many toxicity and life cycle issues associated with the creation, use, and end of life of this material that it's hard for me to move past. This should be green chemistry issue #1 for them to optimize, post haste!
Will Interface publicly acknowledge a commitment to eliminate PVC or will the legacy of its use keep them quiet for fear of self-incrimination?