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Radical Industrialists

What's in your product? Learning to love transparency

<p>Changing the rules to make transparency the norm is easier said than done, but it is potentially transformative.</p>

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: 

  1. Manufacturers may quietly eliminate ingredients already known to be problematic, so as not to be obligated to disclose them.  
  2. Manufacturers will begin to scrutinize ingredients they may not have realized were in their products.
  3. Customers and advocates will provide feedback on disclosed ingredients, driving product reformulations.

This is the kind of transformation Red List advocates — environmentalists, health professionals, and others — want, but what about industry? Why would we seek to accelerate the potentially painful and costly transformation required by radical transparency?

In an era where social media can be more of an influence on chemical phase-outs than the regulatory agencies, corporate credibility with customers and citizen stakeholders has never been more important. If the locus of power is shifting, then it’s better to have the public applying pressure based on solid data your company supplied, rather than on Internet rumors. Additionally, companies willing to be transparent about their current challenges can take advantage of the world of “open source” innovation by collaborating with stakeholders.

Finally, as product transparency becomes the norm, the marketplace can evolve past vague and greenwashed claims, and the confusing tangle of green certifications, allowing comparable product data to rule the day. 

The headlong plunge into radical transparency has been at times an uncomfortable journey for Interface. The path to having 90 percent of our products covered by third-party-certified Environmental Product Declarations and fully disclosed in the Healthy Building Network’s Pharos Project has included:

  • cultural challenges: moving past reflexive discomfort around disclosing anything related to chemicals of concern; 
  • technical challenges: gaining clarity on what is in our products and how to disclose the ingredients without sharing trade secrets; and,  
  • communication challenges: learning to truly value and embrace customers and NGOs that ask tough questions.

While all of these are important hurdles to clear for a company committed to transparency, the importance of communication challenges has been underestimated to date. Ingredients’ disclosure is often a discussion with passionate stakeholders regarding health concerns (quite personal to most people), and, as such, there is little room for missteps on either side if we want to make progress on transparency. If a company is perceived to be flippant about these concerns, then poof — an entire segment of your audience turns their back on you (or, worse, wages a campaign against you). And if a stakeholder wrongly implies a manufacturer is poisoning its customers, then poof — the manufacturer drops voluntary transparency initiatives and returns to business as usual.

Radical transparency goes beyond passive disclosure of data. It requires a commitment to having your data understood by stakeholders, even when communicating something that may look “bad,” such as controversial ingredients or a product’s carbon footprint.

Ultimately, the skills needed to help transparency flourish in the sensitive arena of health and toxicity are the same communication skills needed for any good relationship: communication that builds trust, affinity, mutual understanding, and respect for differences of opinion.

In building these relationships with stakeholders we’re learning that disclosing credible data on your products brings you only up to the starting line; the transformative potential of transparency lies in the open dialogue and collaboration it enables.

When approached this way, chemical Red Lists become a way to start a conversation, not a way to end one. Instead of grumbling about the Red Lists that prohibit some of our ingredients (more about this in a future column), we are proactively engaging stakeholders that Interface had previously avoided. Our commitment to transparency gives us freedom to have truly substantial conversations about our impacts, ingredients, and the decisions we face as we evolve our product formulations. By listening deeply we’ve discovered we are highly aligned with our critics in our long-term goals, and there are exciting opportunities to work together.

Over the past year, we have become an active stakeholder in the Pharos Project, weighing in on suggested improvements and investing time in its success. In addition, we have collaborated with advocates to create the EPD Transparency Brief and to pilot the Health Product Declaration (HPD). We have high hopes that these tools will accelerate transparency to be the new normal in our industry. With more tha 25 other manufacturers having disclosed product ingredients in the HPD Pilot, and EPDs referenced in the latest version of the LEED standard, we are off to a great start.

Red List advocates still may not like some of the cards we’re still holding, but now all our cards are on the table. And we’ll take a challenging conversation about getting to greener chemistry any day over another pointless round of Go Fish.

Image of Periodic Table Playing Cards, available from

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