How to Get the EPA DfE Label

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.

There are two qualified third-party profilers for DfE: NSF, International and ToxServices, LLC.  Contact either entity directly to get started.

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:

  1. detailed structure
  2. physical-chemical properties
  3. human health and environmental toxicology
  4. 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:

  1. the DfE Standard for Solvents
  2. the DfE Standard for Surfactants
  3. 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:

Hope this was informative.  You may email me privately with your thoughts.

Green Chemistry Status in California and All US States

Green Chemistry simply means: using chemistry to reduce or eliminate the use and generation of hazardous materials. Below, we’ve provided a table itemizing which states have stages of green chemistry laws implemented.  Just scroll down.  We all need an overview sometimes.  You can download the Green Chemistry Status pdf version here.

The California Green Chemistry Initiative may be a great idea, but it started an environmental regulatory trend whereby the state regulates chemicals in manufactured products. It applies to goods made or sold in the state. The green chemistry initiatives are similar to, in particular, DfE or Design for Environment and REACH. Often, Green Chemistry focuses on children’s products. This sparks the public interest, makes legislation easier to pass, and let’s face it, it appears children are more vulnerable and susceptible to the maleffects of toxic substances, largely because of toxic attacks on youth in critical developmental stages.

Would it be ideal to have Green Chemistry be some kind of standard at the federal level? Absolutely. Manufacturers, associations, regulatory bodies and the public agree on that. In theory. But then you get the politics, infighting, lobbying, special interest groups on both the left and right — and we’re back to state and local regulations. Of course these are all different, in different stages of implementation. This spells disaster for manufacturers trying to abide by the law.

To solve the problem, we’ve created an up to date Status Table that shows the status of Green Chemistry laws, state by state.

If you have trouble seeing the table below, view and print a high-resolution pdf version. Data are current as of December 2010.

Reuters recently ran an article that pointed out:

“In addition to the health and environmental safety of these greener chemicals, green chemistry brings a competitive advantage to companies:

1. Less risk of product recalls and potential damage to company reputation
2. Cost savings gained when hazardous materials are removed to reduce the costs associated with handling, transportation, disposal and compliance of hazardous materials
3. Improved chances of greater stakeholder engagement from customers, employees, managers, and investors are achieved when a company demonstrates initiatives to reduce their negative impact on the environment
4. Cost savings from greater efficiencies in manufacturing process.”