The US Environmental Protection Agency’s program that reviews, recognizes and labels (effectively certifying) best-in-class wet chemical-based formulations and products is known as the Design for Environment or DfE Program. See bottom of this post for an overview of DfE*.
So how does a product qualify for a DfE label? By being made of the safest known ingredients.
If you’d like a DfE label for your product, EPA reviews your formula. They’re looking at each ingredient in a formulation in its distinct functional class, whether surfactant, solvent, etc.
Reviewing your ingredients for DfE label. The reviewers then compare toxicity and environmental fate profiles to identify safest known ingredients for man, beast and world. The safest ones get the DfE label. Sounds simple enough, right? Truth is, many get snagged on the chemical disclosure part of the process, either because of reluctance to disclose chemicals or — surprisingly often — due to lack of organized data on the ingredients in formulas.
As an industry example, EPA’s DfE Program entered into a voluntary partnership with representatives of the electronics industry to evaluate the environmental impacts of tin-lead and lead-free solders. The idea was to address the information gap on the environmental impacts of leaded and lead-free solders. The list of EPA’s lead-free solder partners includes Hewlett-Packard, IBM, Intel and Cookson Electronics.
This type of partnership can work across industries.
Know your DfE entity. For background and context, review EPA documents on the subject such as “When you see the DfE label on a product, what does it mean?” If you’re a cleaning product manufacturer, read over “Standard for Safer Cleaning Products (SSCP)” (PDF) (31pp, 177K) and the Standards for Safer Ingredients to get a sense of program goals, framework, criteria, and to determine if your product may qualify to bear the DfE label. For manufacturers of other products, read DfE’s “Discriminating and Protective Approach to Product Review and Recognition” (PDF) (12pp, 160K) which includes the DfE criteria in matrix format.
(Note, with respect to Step 3, that DfE has not yet developed a component class screen for active ingredients in pesticide products.)
Profile formulation ingredients for DfE. Applications for partnership must include a full disclosure of all ingredients and ingredient profiles.
A profile is a compilation of all hazard information available on a chemical and includes:
- detailed structure
- physical-chemical properties
- human health and environmental toxicology
- regulatory/administrative status
To be able to work with all of the companies that request partnership, DfE retains third-party profilers. Qualified third-party profilers have the expertise and objectivity needed to ensure a quality review, with high confidence in the accuracy and reliability of the profile information. NSF, International and ToxServices, LLC are qualified third-party profilers for DfE.
Assessing ingredients and identifying safer alternatives. After third-party profiling, DfE assesses potential health and environmental effects of each ingredient in your formulation and may identify areas for improvement, safer alternatives, or additional information needs.
In the context of its functional class, DfE evaluates each ingredient in a formulation based on critical health and environmental endpoints.
Functional-class criteria define and more fully explore the safer end of specific ingredient-class continuums. Using the Master Criteria as a guide, the functional-class criteria tailor the health and environmental endpoints in the Master Criteria in a way appropriate to the specific functional class, designate key distinguishing characteristics and adjust thresholds as necessary. Developing the Criteria improves the general understanding of the characteristics of safer ingredients in the class and helps identify green-chemistry opportunities and successes.
The DfE functional class context allows DfE to view ingredients as part of a continuum of improved ingredient choices. Functional Class standards define and more fully explore the green end of specific ingredient-class continuums. DfE has issued three functional-class standards:
- the DfE Standard for Solvents
- the DfE Standard for Surfactants
- the DfE Standard for Fragrances (Human Health)
and is currently developing standards for fragrances (environmental toxicity and fate) and additional functional-use classes in partnership with broad stakeholder workgroups. Additionally, there are specific environmental toxicity and fate standards for ingredients used in direct release products (products that are used outside and do not go through sewage treatment).
|Flowchart courtesy of EPA’s Design for Environment program or DfE|
DfE is along the lines of Green Chemistry — focusing on full, positive material declaration for safer products throughout their lifecycle and beyond.
*The Design for the Environment (DfE) label is an EPA effort to enable consumers to quickly identify and choose products that can help protect the environment and are safer for families. The label indicates that the DfE scientific review team has screened each ingredient for potential human health and environmental effects and that—based on currently available information, EPA predictive models, and expert judgment—the product contains only those ingredients that pose the least concern among chemicals in their class.
EPA’s Design for the Environment Program (DfE) has allowed use of the logo on over 2000 products. These products are formulated from the safest possible ingredients and EPA says they have collectively reduced the use of “chemicals of concern” by hundreds of millions of pounds.
The label has the look, look for the label, the label looks like this:
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