School Cleaning Product Choice: Research into Options

Citizens for A Safe Learning Environment (CASLE)
November, 2000

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Executive Summary

School Product Choice: Research into Options

Citizens for A Safe Learning Environment (CASLE)
November, 2000

This report is based on research done for a Nova Scotia school board Product Evaluation Committee which had the overall mandate of developing a procedure(s) for choosing least-toxic, effective, cost-effective products for use in the schools through a pilot project of selecting an all-purpose cleaner. The project encountered significant problems and ended in the selection of a product that contained an APEO (endocrine disruptor), an unidentified dye, and, if the performance tests can be relied upon, appeared to perform comparable tasks at a higher dilution and consequently higher cost than others in the competition.

CASLE representatives on the committee consequently researched and wrote the following reports in an attempt to guide the process back to reliability. The committee’s project was never completed, but we offer this information in hopes that it will enable others to progress further and faster toward the goal of choosing least-toxic, effective, cost-effective products for use in our province’s schools.

Enclosed are:
A) Presentation to Product Evaluation Committee, November, 1998. This section outlines problems inherent in some “self-designed” or “in-house” performance tests.

Two examples,(1) the dilutions used by company representatives were not the dilutions recommended by the manufacturer, thus skewing the results. Committee members were not aware of the recommended dilutions (2) scouring pads, unclean equipment, faulty timing, and other test design flaws rendered the results questionable.

B) Information on Chemicals and the Evaluation Process, February 1999 (updated Oct. 2000). An international search was done for ECOchoice/Ecolabelling programs. Advice from the Swedish Secretariat on ecolabelling sent us back to Canada for some of the world’s best programs.
Safe product selection is a specialty. Please read the entire report for issues and details covered, such as APEOs, dyes, formaldehyde, formaldehyde mimickers, shortcomings of WHMIS, and more.

Other materials included with this report:

• VOCs and Odors; Key Factors in Selecting “Green” Building Materials? C. Coombes
• Guidelines for Material and Product Evaluation, Bernd Seifert
• ECOLOGO information package
• Envirodesic Certification Program information package
• Waterloo Ecoclassroom standards and cleaning materials, 1991-1996.
• Annapolis Valley and South Shore, Nova Scotia good product specifications
• Hormone Disruptors fact sheet, Canadian Institute for Child Health
• Is This Your Child’s World, D. Rapp, page 178-181 and Chapter 12
• Also included are copies of the article Maintenance Chemicals in Schools
• an article on WHMIS strengths & weaknesses
• The Healthy School Handbook, US NEA, Chapter 7
• Environmental Assessment and Specification of Green Building Materials, L.M. Froeschle
• Annapolis Valley Regional School Board Painting Authorization Form
• Reply from The Standards Council of Canada re: labs in Atlantic Canada
• The Gippers Guide to Environmental purchasing
• Soap products may be killing Atlantic Salmon article
• Environmentally Responsible procurement, NS Dept of Finance

* Also listed are some leads that merit follow-up.

Some Observations from this report are:

1. Evaluation of products for ecotoxicity or human health protection is a specialty. Not all testing labs are equally informed or accredited.
2. Working from a list of “ingredients to be avoided” risks missing products with negative synergistic possibilities and toxin mimickers. Relying on accredited labs is more sure and inclusive.
3. Several evaluation labs were examined. Some had limited or no expertise in product choice/chemical makeup re: human health/earth health. Some have a clear specialty in protecting Mother Earth, while others focus on human health:
   – ECOLOGO’ s primary interest in protecting Mother Earth, but also human health.
   – ENVIRODESIC’s primary focus on human health but also mother earth.
   – ORTECH’s primary focus on human health but also mother earth.
   – ECOLOGO and ENVIRODESIC/ORTECH have speakers available, as would most companies/services.
4. Nearly all sources contacted recommended that testing be part of the tender process, paid for by the applicants. Some areas in Canada are already taking the guesswork out by doing this.
5. In-house performance testing tends to be unreliable. Standardized comparative tests for performance are also available through the accredited labs and can be part of the tender requirements paid for by applicants.
6. Choose the least toxic product capable of doing the job (cost effectiveness & performance taken into account) and use Safe Work practices to avoid exposing staff and students in cases where some hazard exists. (ie: floor waxing, gym floor refinishing, painting.)– Citizens for A Safe Learning Environment

Research into Options for School Product Choice

Citizens for A Safe Learning Environment (CASLE)

Information on Chemicals and Evaluation Processes
February 1999 (updated October, 2000)

Task: As part of the _____________School Board Product Evaluation Committee (PEC), to look into some of the chemicals contained in the final six applicants for choice of All-Purpose Cleaner for use in all schools in the region. This task led into the specialized field of product evaluation for ecotoxicity and human health.

Some readers may want to jump to the Sources and Conclusions sections at the end of this report, but we encourage you to also read the following account of the process of discovery that came from this specific task for the HRSB PEC.

The November 26, ’98 report from (a local chemical testing company) to the PEC was used because this was all the product information available as PEC members were not given copies of the applicant product’s MSDS. Our task was to examine the only chemicals mentioned in the document:

In product #1:

1) Alkyl-phenyl-ethoxylates (APEO)

2) Diazo dye family, blue dye. (The committee had requested the blue dye name and materials information from the supplier, but were given the dye family name only and a letter stating it is a safe material)

In product # 2,3,4 &5:

3)Ethoxylated Fatty Acid.

In product # 6:

4) Sodium dodecylbenzene sulphonate

5) tetrapotassium pyrophosphate
In addition, MSDS are often not all-inclusive, so more information was needed on:

6) preservatives/formaldehyde & other possible materials not listed on MSDS

Who Was Contacted?

• A local chemical testing company employed by the school board
• Annapolis Valley and South Shore Boards
• Swedish General Secretariat
• New Jersey Department of Health Hazardous Substance List
• Environment Canada, TerraChoice, ECOLOGO
• Waterloo Region District School Board- ECOCLASSROOMS and materials evaluation
• ENVIRODESIC Certification Program
• ORTECH, an Ontario Government Lab
• US EPA Special Review & Reregistration Division
• US Department of Health & Human Services, Washington
• The International Agency for Research on Cancer, list of cancer causing agents
• another Maritime testing company
• Standards Council of Canada (SCC)
• website of the U.S. Dye Manufacturers Operating Committee of ETAD 

Others leads to be followed up in the future:

• CMHC
• The Cutter Corporation
• The Research Triangle Institute, Human Studies Department.
• World Wildlife Federation for information on Endocrine Disruptors
• The Merck Index, MSDS on chemicals
• Health Hazard Information
• Metro Toronto School Board’s central purchasing department 

Information obtained on the materials:

1) Alkyl-phenyl-ethoxylates
* comments from ECOLOGO: APEO are considered endocrine inhibitors (can change male fish to female fish). APEO would disqualify the product from carrying the EcoLogo.
* comments from ORTECH: ORTECH would also identify hormone disruptors/endocrine inhibitors in products, for elimination.

2) Sodium dodecylbenzene sulphonate
* ECOLOGO: “It is a common surfactant that has been used for many years in a wide range of detergent products. A surfactant that does not contain a benzene group for example a linear alkyl ethoxylate would have a better biodegradation rate.”

3) tetrapotassium pyrophosphate
* ECOLOGO: “Phosphates enhance cleaning action and make for a more effective product, but cause algal growth in rivers. “Ecologo allows up to 5% phosphorous in commercial cleaners.

4) Ethoxylated Fatty Acid.
* ECOLOGO: No information.
* New Jersey HSL: Not on hazardous product list.

5) Diazo dye family, blue dye.
* ECOLOGO: “I have heard recently that diazodyes are a problem but I have no hard evidence and I am not sure what their effects are.” Would require further study.
* ORTECH: looks for dyes in products. Dyes avoided.
* U.S. Dye Manufacturing Committee website: “Many dyes have not received extensive health-effects testing and exposure limit recommendations are not available for most dyes. It is prudent, therefore,to minimize dye exposure at all times.”

6) preservatives/formaldehyde & other possible materials not listed on MSDS
* ECOLOGO: See guidelines. Suggests a company provide a statement that the product is not formulated or manufactured with formaldehyde or formaldehyde producing products, or a long list of others such as Polychlorinated Phenols.
* ORTECH: know what to test for, including dyes, hormone disruptors, skin irritants and more, but may also get full disclosurebecause the company pays for analysis: “If you tell us what to look for, itwill cost less.”

Other School Districts:

* Annapolis Valley & South Shore: APEOs banned in their joint guidelines

* Waterloo Region District School Board:
(1) Engaged a company to evaluate products. Put the onus on manufacturers in the tender requirements. (Suggested ORTECH)

(2) looked at cleaning programs using Integrated Cleaning Program from the Healthy School Handbook. ie: assess needs, use least toxic possible for the job, use isolation techniques for occasions when more toxic materials are essential, upgrade training. (See HealthySchool Handbook, chapter 7)

Services/Companies:

(1) Interview with the testing company used by the school board:
– Did you look for ingredients not listed on the MSDS? No
– Did they check for formaldehyde? No.
– Did they check for preservatives? No. Not asked to look for that. Did do a metal scan.
– materials below 1%, would they be seen by the testing used? the infrared test? No, said they would see some things but wouldn’t see everything. They picked some of the general tests and ran them.
– One company in the final selection group refused full disclosure.
– Was the blue dye examined? “Have the dyes been known to cause problems before?” The testing company is willing to look further into the dye if the PEC wants. Would need thename of the dye. (The company refused disclosure when the PEC asked. Supplied only the family name, Diazo, and a statement reassuring that it is a safe dye.)
– Were endocrine Disruptors looked for? No.
The question begs to be asked why an under equipped company was selected for the school board’s use on this kind of specialized project?

(2) ORTECH and ENVIRODESIC CERTIFICATION PROGRAMS:
* Waterloo Region District School Board referred us to ORTECH which in turn referred us to the Envirodesic Certification Program. ORTECH does full evaluation of materials from Environmental Health perspective and for Ecotoxicity and performance.

* The Envirodesic Certification Program” is designed for maximum Indoor Air Quality”. Have a sequence for committees to go through to choose least toxic products, including field testing.
Many least toxic products have already been identified.
The Envirodesic Certification Program has the Ontario Lung Association stamp of approval.

ORTECH and Envirodesic have worked together to design a protocol to choose building materials and cleaning materials. Most information is in the private domain, not public – is the property of the purchaser, but sent us excerpts for our use.

Metro Toronto School Board’s central purchasing department reported specifying tender applications must be tested by ORTECH using their standards. For example, applying companies submitted photocopy machines for emission evaluation. Evaluation is paid for by the applying companies.

(3) ECOLOGO:
The Swedish General Secretariat for information on international Ecolabelling programs directed us to TerraChoice (Ecologo program), Federal Department of the Environment, Canada.

TerraChoice manages the Environmental Choice Program for Environment Canada ECOlogo. Their function is to identify and certify products that are less damaging to the environment.

“Finding the safest and least environmentally damaging products is always a challenge and exactly why the Environmental Choice Program (ECP) was created. Any product that carries the EcoLogo (three doves in the form of a maple leaf) must meet a related set of environmental criteria. We verify the information through a site audit of the manufacturing facility and an evaluation of the product itself. When relevant and credible test data (such as those from an accredited laboratory)are not available, certification does not proceed until all requirements are met.”

In the area of general purpose cleaning products, certification criteria include:

• must not be formulated with certain ingredients including NTA, EDTA (ethylene diaminetetra-acetic or dintrilotetra-acetic acid or related salts) halogenated organic solvents, butoxy-ethanol, noVOCs in excess of 10% by weight or any proven or probable carcinogens
• must be readily biodegradable, not toxic to aquatic life nor accumulate in the tissue of living organisms
• must meet performance requirement relevant to the purpose of the product (ie: it must work)
• must not require labeling as poisonous under the Hazardous Products Act.

Other cleaning products may have different or additional requirements.
(SEE FULL GUIDELINES)

Most criteria relate to “mother earth”, only some are directly health related and others are indirectly related.

Evaluation cost can be $2,500. Applicants provide product to labs for essentially 4 tests:
(a) CGSB (Canadian General Standards Board) performance test 2.11-94, Method 23.
(b) OECD (Organization for Economic Cooperation and Development) biodegradation test, and
(c) a set of three aquatic toxicity tests.
The labs then provide Ecologo with copies of the results. Costs from various labs differ.

Ecologo Suggests Possible Options:
(1) Specify applicants must “meet ECOLOGO specifications” or
(2) “have Environmental Choice certification”. ie: Ask suppliers to obtain Environmental Choice certification or ask them to have the 4 tests run at their expense at a lab of your choosing, or
(3) Use the Ecologo program to select a product now as we already have a number who have passed the process. (Examples of products carrying Ecologo are Alex Milne associates, Enviro-Solutions Ltd., Frank T. Ross & Sons Ltd., Bebbington Chemicals, Lord & Partners Ltd,and Royalpak Inc.)

The Ontario Government, the Cities of Toronto,Vancouver, and Calgary specify “must meet Ecologo requirements or be Ecologocertified” as do the Annapolis Valley and South Shore school boards in N.S.
(Toronto School board rep said Ecologo falls short re: human health issues, while protecting Mother Earth well, but is better than most & may be adequate.)

(4) another local Maritime building evaluation company:
Does not do chemical laboratory analysis. (Advises on-site using similar guidelines to those in the Healthy School Handbook:Minimizing chemical exposure through controls and safe work practices, including timing, and choosing least-toxic options re: high dilution / no scents / no masking scents, etc. Dyes are of questionable benefit. This company has done extensive work in the Chignecto Board, including custodial and maintenance staff training/upgrading programs on the newer least-toxic options.)

(5) The Standards Council of Canada replied (to the inquiry for a list of Maritime laboratories that are accredited to do tests for ecotoxicity, performance, and human toxicity). They reported
that they did not find any matches in their search for local labs accredited for using the CAN/CGSB 2.11 Method 20.3 and the OECD guidelines, also PCE-33 guideline for all-purpose cleaners. They suggested we contact the ECOLOGO program for information.

Other Materials/Sources:
Other materials included with the original report were:

• VOCs and Odors; Key Factors in Selecting “Green” Building Materials? C. Coombes
• Guidelines for Material and Product Evaluation, Bernd Seifert
• ECOLOGO information package
• Envirodesic Certification Program information package
• Waterloo Ecoclassroom standards and cleaning materials, 1991-1996.
• Annapolis Valley and South Shore product specifications
• Hormone Disruptors fact sheet, Canadian Institute on Child Health
• lists of restricted and prohibited chemicals from the HRSB Wellness Manual.
• Is This Your Child’s World, D. Rapp, page 178-181and Chapter 12
• Also included are copies of Maintenance Chemicals in Schools
• an article on WHMIS strengths & weaknesses
• The Healthy School Handbook, US NEA, Chapter 7
• Environmental Assessment and Specification of Green Building Materials, L.M. Froeschle
• Annapolis Valley Regional School Board Painting Authorization Form
• Reply from The Standards Council of Canada re:labs in Atlantic Canada
• The Gippers Guide to Environmental purchasing
• Soap products may be killing Atlantic Salmon article
• Environmentally Responsible procurement, NS Dept of Finance

CONCLUSIONS:

1. Evaluation of products for ecotoxicity or human health protection is a specialty. Not all testing labs are equally informed or accredited.

2. Working from a list of “ingredients to be avoided” risks missing products with negative synergistic possibilities and toxin mimickers. Relying on accredited labs is more sure and inclusive.

3. Several evaluation labs were examined. Some had limited or no expertise in product choice/chemical makeup re: human health/earth health. Some have a clear specialty in protecting Mother Earth, while others focus on human health:

• ECOLOGO’ s primary interest in protecting Mother Earth, but also human health.
• ENVIRODESIC’s primary focus on human health but also mother earth.
• ORTECH’s primary focus on human health but also mother earth.
• ECOLOGO and ENVIRODESIC/ORTECH have speakers available.

4. Nearly all sources contacted recommended that evaluation/testing by an environmental choice specialist be part of the tender process, paid for by the applicants. Some areas in Canada are already taking the guesswork out by doing this.

5. Standardized comparative tests for performance are also available through the accredited labs
and can be part of the tender requirements paid for by applicants. This avoids the need for the questionable practice of unstandardized in-house performance testing.

6. Choose the least toxic product capable of doing the job (cost effectiveness & performance taken into account) and use Safe Work practices to avoid exposing staff and students in cases where some hazard exists. (ie: floor waxing, gym floor refinishing, painting.)

Respectfully Submitted,
CASLE

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Presentation To the Product Evaluation Committee November 26, 1998

As you know, the work of our committee is very important because the process we come up with for choosing a least toxic general purpose cleaner will form the basis for choosing many more products for usein our school system. It always takes more effort the first time through something, and there is usually plenty to be learned. We wrote this account of the process so far in hopes that the committee could use it to discuss improvements.

During the In-House performance tests we were very surprised to see one of the products (and possibly two) containing dye. Somehow this slipped by both the testing company and our committee during the screening process we used to find the short list of least toxic alternatives. Discovering the dye indicates that we may have to rethink the process somewhat at this point. Dyes can be of concern, and the committee has asked for more information. Perhaps we should have made it clearer in the list of criteria that there could be concerns over not just fragrances, but over other specific substances such as dyes, formaldehyde, formaldehyde mimickers, other preservatives, APEOs and other questionable materials (including natural substances such as citrus).

We would like to have had copies of the various communications/test results (We have the one of Oct. 1998 from the testing company) Committee members need to receive copies of documents with enough lead time for examining them thoroughly so as to bring thoughtful and useful comments to the next meeting. For example, a single copy of the first evaluation papers from the testing company was only passed around at a meeting for each to read quickly while the meeting progressed in the meantime. It was difficult to adequately examine the document, and obviously we all failed to realize this might turn out to be a mistake in our process.

Having minutes kept of meetings may also help, not just for clear decision making, but for reference at times like this when we are trying to determine what we might do better. (Also, it may help to document our process so that it can be clearly demonstrated that we have done a fair and thorough job.)

It is good that we now have determined a quorum number, as the meeting where we had important decisions to make regarding the procedures for testing the short list products was attended by only three of us.

Another possible procedural flaw may be the fact that we did not compare the testing capabilities of more than one testing company, although the committee had clearly decided to seek an evaluation of two or preferably three testing companies. Would another company have picked up on the dye, APEOs or other materials, and recognized them as potentially undesirable ingredients?

A further question has come up: Did the testing company seek any preservatives such as formaldehyde or formaldehyde-forming compounds that are often used at levels below 1% or even .1% and so need not be reported on MSDS’s? Did it seek other materials exempt from being listed on MSDS’s for a variety of reasons, or was the MSDS the only source of ingredient information? (It would be good to note at this point in more detail what ingredients were found when the company went to the cleaning companies the second time for more information.)

At this point we think the committee might best go back through all of the documentation and try to determine problem areas. This is discouraging, as we need to move forward and bring our decision to a close as soon as possible. Nevertheless, if we don’t identify flaws in the process at this point, we can not rely on the end result being all it should be.

Another idea: Perhaps we should contact Health Canada and learn the methods they use to choose products that are awarded the ECOlogo. They are specialists/scientists who may have tips we may never have thought of ourselves.

COMMENTS ON OUR IN-HOUSE TEST FOR CLEANING EFFECTIVENESS:

First time through is often a learning experience, so what are some of the things we learned this time?

Clearly specifying a method in the future would help, such as:

– Predetermine clear and standardized instructions to each salesperson. (ie: we realize some of the “dirt” is solvent based and may not come off, but we are providing an equal test to all participants. Look at the table and recommend how you would use your product to get it as clean as possible …or as clean as possible within the time limit if that is the method we specify.)

– Separate, clean equipment for each test (buckets, clean rags, squirt bottles, etc.). For example, the scouring pad was the same one used in each test. A clean pad should have been used for
each product.

– Also, if the first salesperson had not used a scouring pad we may not have used the scouring pad at all, as the following participants did not bring pads. Only the first one did, and because they did we were forced to use pads for all in order to keep the test as equal as possible. Perhaps we should retest without the complicating factor of a scouring pad; ie: to test the cleaning power of the product rather than the complicating factor of the scouring capabilities of the pad.

– Decide the water temperature that will be used for all (the one most likely to be used in the schools)

– Plan the variety of surfaces that need testing, such as painted walls, wood, waxed floor, sinks, school bus…(One salesman pointed out that a major area to be cleaned is floors and” you’re not going to see that with this desk.”)

– Will the rag be pre-wet with water or be dry? (pre-wetting with water will dilute the cleaner, but perhaps that is the way it will be used in the schools…?)

– Will the rag be wet in the cleaning fluid and wrung out, or be sprayed on the surface? (Environmental Health Experts discourage atomizing because it makes airborne droplets that can be inhaled. Squirting may be better.) For example, at the end of the Eastern Paper test the rag was rinsed in the bucket and more scrubbing was done with the wet rag only, so that test may not have been equal to the others.

– Predetermine how often to allow reapplication of the liquid, or count what is done and take it into account.

– Will a “soaking” time be allowed? Note if one is recommended and take it into account in the decision-making. ie: A less toxic cleaner may work as well as a more toxic cleaner if a soak time is done. (In our method we allowed a soak for some and not for others. Did we take this into account when judging? How long a soak time is too long re: wage time lost?)

– Predetermine if we will be allowing a particular length of time to do the job, or if we will keep track of the length of time it takes to complete the job to the point where no more “dirt” can be removed. (In our test we started with one method and switched to the other. Also, we could have used a stopwatch. My watch was useless, and the secondhand on the watch I used was out of sync with the other hands.)

– Have a control surface where we use only water to see if the products are any better than water alone.

– Possibly seek professional researcher’s advice about how to conduct a fair test between a 20% solution and a 1% solution. (See the attached table entitled “In-House test Ranking According to Success in Cleaning and Percent Solution” where cleaning success appears to be related to dilution rate.)

– Possibly retest all cleaners at full strength, but eliminating the drying time between the earlier cleaning period where we used the lower ratio, and the later test where we used the full strength.

Some other factors to look at next:

Are the containers recyclable, refillable or reusable?
Do labels come off?
Does label ink run?
Business references
Product references
cost analysis
availability/service
automatic dilution equipment
other

We all know that the first time we do something we tend to learn a lot. This has been no exception. We hope these thoughts help our committee produce the best results as soon as possible, and we look forward to the committee’s discussion.

Respectfully Submitted,
CASLE Representatives

 

 

 

In-House test Ranking According to Success in Cleaning and Percent Solution:

Best to Worst Performance

Effectiveness re: residues left on desks:

Note that there were testing irregularities which could account for the differences.

For example, why is it that a 20% solution (1 part product to 5 parts water) was chosen for testing product Bk when its manufacturer recommends a 1 to 32 dilution for heavy duty cleaning? This is a solution 6 times stronger than the manufacturer recommends for heavy dutycleaning. See Presentation To the Product Evaluation Committee, November26, 1998 for more irregularities.

– Citizens for A Safe Learning Environment