Triclosan's Dirty Secrets Can Land Your Products in 'Toxic Lockout'

The Right Chemistry

Triclosan's Dirty Secrets Can Land Your Products in 'Toxic Lockout'

In this blogging space in September, I asked, "Should Your Company Wash Its Hands of Triclosan?" I noted that the FDA and EPA will be revisiting regulatory approvals of triclosan in the next few years, the FDA says triclosan doesn't convey health benefits beyond regular soap, and various manufacturers and retailers no longer sell it. I suggested that consumer-facing companies still using triclosan in soaps should consider an exit strategy.

On December 8, 2010, EPA published a notice in the Federal Register (pdf) increasing the timeliness of this question. The EPA solicited public comment on a petition from two NGOs requesting a ban on triclosan for those uses regulated by the EPA. NGOs have filed a similar petition with the FDA requesting action on uses regulated by the agency.

Two companies can be added to the list of those moving from triclosan. Colgate-Palmolive has repositioned its antibacterial dish-cleaning liquid. The orange-colored  "Ultra-Palmolive Antibacterial" available until recently bore an FDA-required drug disclosure label listing triclosan as the active ingredient. The FDA disclosure was required because the dish-cleaning liquid was also labeled a "hand soap," placing its label claims under FDA jurisdiction.

No more. The replacement bottle, claiming to kill "99.9% of bacteria on dishes & kitchen surfaces," bears an EPA-required label for a replacement ingredient -- L-Lactic Acid. The EPA label replaced the FDA label because the new product is marketed solely as a dish liquid, not a hand liquid, placing it under EPA jurisdiction. The Environmental Working Group's "Skin Deep" database www.cosmeticsdatabase.com assigns L-Lactic Acid a "low hazard" rating of 1 and triclosan a "high hazard" rating of 7 on a scale from 1 to 10.

Colgate-Palmolive also is moving from triclosan in its hand soaps. It formerly marketed Softsoap brand antibacterial hand soap containing triclosan, with a label claiming elimination of 99 percent of germs. It is now rolling out a new line of Softsoap hand soaps which merely state that they "wash away bacteria." The back label of the new Softsoap "Kitchen Fresh Hands" bottle reminds purchasers that "The U.S. Centers for Disease Control and Prevention states that keeping hands clean is one of the most important steps we can take. It is best to wash hands with soap and clean running water for 20 seconds."

Colgate-Palmolive's been making the product switches without much fanfare. The market for antibacterial soaps is largely a commodity market, with brands competing on price and those brands containing triclosan falling out of favor with environmentally concerned consumers. Colgate-Palmolive's substitution of L-Lactic Acid in its dish detergent helps differentiate its product in that market from other companies' antibacterial offerings containing triclosan. (Colgate-Palmolive is retaining use of triclosan in its Total brand -- a line of therapeutic toothpastes -- because of health benefits demonstrated in clinical trials.)

Companies whose products contain certain out-of-favor chemicals can suffer from "toxic lockout," if retailers exclude them from the marketplace.

The polycarbonate baby bottle containing the chemical Bisphenol-A is the poster child for toxic lockout. Major retailers moved to ban these bottles from their shelves long before bans were enacted by various state legislatures. (The American Chemistry Council, the U.S. chemical industry's trade association, was recently successful in blocking a proposed federal ban, though the European Union is moving forward with one.)

Colgate-Palmolive is positioning itself well to avoid potential toxic lockout from Staples, which has begun scrutinizing chemicals in the products it sells as part of a major sustainability initiative. Staples is the world's largest office products company, with sales of $24 billion and operations in 27 countries. It has been ranked as the second largest worldwide e-commerce retailer after Amazon.com and is ranked 101 in the Fortune 500. Its B2B trade, serving roughly 4 out of 5 Fortune 500 companies, dwarfs its familiar retail operations.

Last October, Staples announced a new sustainability strategy for products and packaging, characterizing it as a "Race to the Top" challenge for its key suppliers. The strategy was unveiled at a "sustainability summit" for the company's 25 largest suppliers.  The strategy's initial priority is packaging, but also includes collaboratively developed scorecards for both products and packaging.

Staples has shared with its suppliers a list of about two dozen "bad actor" chemicals. Staples is not banning the chemicals, per se, but has signaled it wants to begin a conversation about their future use. Three of the chemicals -- permethrin, propoxur, and nonylphenol ethoxylates -- were previously targeted for elimination by Walmart's Chemical Intensive Products program (pdf). Polyvinyl chloride is also on the list, having previously been targeted by Staples; by 2009, the company had eliminated PVC from all Staples brand packaging in North America. BPA is also listed, amidst rapidly rising concern about its presence in the thermal paper used to print cashier receipts. Staples and other companies are participating in a multi-stakeholder study of thermal paper alternatives launched by EPA's Design for the Environment program.

Triclosan is on Staples' list. Staples' website offers for sale a range of antibacterial hand soaps and dish cleaning liquids, some containing triclosan. Staples' 25 largest suppliers do not provide soaps and dish cleaning liquids, but eventually Staples will expand its program to more suppliers and more products. At that time, companies supplying Staples with antibacterial soaps containing triclosan may face toxic lockout.

Image CC licensed by Flickr user El Tekolote.