You don’t know what’s in your cleaning products

8115464937_bc1a808bfb_zWhat’s in your household cleaning products? Even if you’ve read the label, there’s probably still a lot left off. No law requires a complete list of ingredients on the labels of household cleaning products, unlike food or cosmetics. And what they’re not telling you about could still hurt you.

Many articles online repeat a claim that the government only requires listing “chemicals of known concern.” Try searching for that phrase within government websites, though, and you’ll get almost nothing. There’s one match within the EPA — it uses “chemicals of known concern” to refer to hazardous chemicals stored in large quantities, or extremely hazardous substances. Not exactly a list of which household chemicals need to be labeled…

It turns out that household cleaning products are regulated through two different pathways, under two different federal agencies. Some cleaning products are regulated as pesticides and registered with the EPA. All others are regulated by the Federal Hazardous Substances Act (FHSA), under the jurisdiction of the Consumer Product Safety Commission (CPSC).

Pesticides have to be registered and approved. If a product makes any claims to kill germs or other harmful organisms — which many bleach products do, for example — it’s regulated as a pesticide. The label has to list all active ingredients (those that kill germs) and any hazardous inactive ingredients. There’s also a requirement that the label have a hazard/precaution statement and a signal word: in order from least to most dangerous, those are “Caution,” “Warning,” “Danger,” or “Poison.” (40 CFR 156.10 and 156.64). The product has to be registered with and approved by the EPA, which is looking at the product’s efficacy and safety.

Other hazardous substances don’t have to go through any approval process. If the product isn’t claiming to kill things, there’s much less government oversight. The Federal Hazardous Substances Act requires that any ingredients be listed on the label if they meet one or more of these hazard criteria (16 CFR 1500.3):

  1. Toxic: has the capacity to produce personal injury or illness to humans through ingestion, inhalation, or absorption through any body surface.
  2. Corrosive: causes destruction of living tissue by chemical action on contact.
  3. Irritant: induces a local inflammatory reaction when in contact (immediate, repeated, or prolonged) with living tissue.
  4. Flammable or combustible.
  5. Strong sensitizer: has a significant potential for causing hypersensitivity, which becomes evident on reapplying the same substance.
  6. Generates pressure through decomposition, heat, or other means.

The FHSA also requires that labels state the principal type(s) of hazard(s), and use one of the four signal words (except that here “Caution” and “Warning” are used interchangeably for the lowest level of hazard).

Many known chemicals of concern do not need to be listed on product labels. The FHSA hazardous-substance criteria focus on acute hazards. They don’t address chronic issues like asthma — even though there is very solid evidence showing that exposure to cleaning chemicals can cause or exacerbate asthma. Some chemicals that contribute to asthma are irritants, which are technically classified as hazardous substances (though I suspect that some irritant effects that are too weak to meet FHSA thresholds are still strong enough to contribute to asthma). In contrast, others are allergens and aren’t covered under the FHSA at all. It’s a clear case where chemicals that we know are hurting people simply aren’t covered under the law.

Like so many regulations, this law lets manufacturers assume something is safe until proven hazardous. I expected to find a database of substances that have already been determined to be hazardous — but after calling the CPSC, it turns out there isn’t. Manufacturers are responsible for figuring out hazards on their own. The law has specifics for how to perform testing, but no requirement that manufacturers actually do any testing.

If a manufacturer decides that X isn’t hazardous, they don’t need to list it on the label. Anyone who’s concerned about X won’t even know it’s in there without conducting an independent (and arduous and expensive) chemical analysis

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