Joint venture methane risk is also a climate opportunity

This blog was co-authored with Meghan Demeter, Program Analyst, EDF

With mounting concern about the state of the climate and increasing speculation about natural gas' role in decarbonizing energy markets, oil and gas companies face growing scrutiny from the public and investors. Some companies are stepping up with pledges to reduce emissions of methane from their worldwide operations.

But there's a catch.  Read more

3 reasons why air pollution should be a top priority for businesses

Leaders from pretty much every country in the world representing current and future customers attended the World Health Organization’s (WHO) inaugural Global Conference on Air Pollution and Health in Geneva last week, along with academics and nongovernmental organizations, but there were no corporate leaders in attendance.

The absence of companies suggests that air pollution isn’t front and center on business leaders’ radars. Here are three reasons why it should be.

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Future fleets: how clean air innovations are driving smarter, healthier cities


When you picture a city bus, an animal control van or a waste management truck, you’re probably not thinking about a high-tech, mobile urban sensing platform, about saving millions of lives, or about the smart city of the future. At least not yet. But a new initiative in Houston is turning public fleets into the rolling eyes and ears of the city, and enabling these vehicles to revolutionize the way air pollution is monitored, measured – and ultimately addressed across the United States.

The information generated by these IoT-enabled “future fleets” is also a key tool in the transformation to fully connected, smarter cities, where hyperlocal data makes streets safer and less congested and where market forces reward urban efficiency, decarbonized electricity, and clean transportation. Picture using connected, clean fleets to improve delivery times, bring residents to work, school and doctor’s appointments, and even pinpoint the location of toxic air pollution threats – all at the same time.

These vehicles are enabling a future where air pollution forecasts eliminate hundreds of thousands of heart attacks, tens of thousands of hospital and ER visits, and an even larger number of missed school and workdays that are caused annually by air pollution. Air pollution also costs the global economy $225 billion dollars every year in lost labor income, but recent studies show that improving air quality – both indoors and outside – could improve worker productivity. Read more

How hyperlocal air pollution monitoring will create smarter, healthier cities

Right outside my window in Washington, DC, there is a hill where trucks accelerate towards the north, and buses idle to pick up tour groups. Even when the air looks clear, it may be hiding an invisible danger. Air pollution kills 4.5 million people a year and costs the world $225 billion a year in economic damages. These global figures mask what can be a highly local, personal risk. Recent studies show that air pollution varies as much as eight times within one city block. We also now know that living by streets with the most elevated pollution can raise the risk of heart attack or death among the elderly by more than 40% – suggesting air pollution is far more dangerous than previously understood.

The good news is we are on the cusp of generating widespread hyperlocal insights into air pollution. Understanding for the first time at a local, personal level where pollution is, where it comes from, and its impacts could shine a spotlight on the problem and increase the urgency and motivation for action. Because the best actions will protect health and mitigate the risk of climate change, local insights can provide the springboard for local, regional, national and even global impact.  Read more

Why businesses and state governments aren’t waiting for federal action on chemicals transparency

As a Trump Administration appointee tries to dismantle EPA’s credibility as a guardian of public health and the environment, other actors have been stepping up. We recently examined retailers leading the way on removing chemicals of concern from the marketplace – but there has also been significant activity from state governments and companies to increase transparency about the chemicals we are exposed to every day and to empower consumers to make informed decisions about their product purchases.

Regulatory steps in the right direction

Government activity has recently focused on cleaning products, for good reason as the contents of these products are typically the biggest mystery for consumers.

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What the sensor technology revolution means for businesses, the planet, and your lungs

A recent study from UPS and GreenBiz revealed that 95 percent of surveyed companies recognize the effect that urbanization – particularly air quality and traffic congestion – will have on business growth and sustainability.

Why? Because poor air quality costs the global economy $225 billion every year in lost labor income, according to the World Bank. Air quality also worsens with congestion, which will likely increase as 2.5 billion more people are expected to live in urban areas by 2050.

It’s no surprise then that less than half of the UPS/GreenBiz study participants feel prepared to address these challenges.

The good news is that cities and businesses can turn their anxiety into action by embracing and utilizing disruptive mobile sensor technologies that collect air quality data.

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Dear CEO: How EPA is critical to protect your customers from harmful chemicals

American businesses benefit tremendously from the robust voluntary and regulatory programs of the U.S. Environmental Protection Agency. These programs are now under threat of massive budget cuts and regulatory roll backs. This blog, focusing on chemical safety, is the latest in a series from EDF + Business highlighting how industry stands to lose from a weakened agency. To prevent these negative consequences, the business community needs to be at the forefront and demand policymakers support the U.S. EPA and its critical mission. 

Recent attacks against EPA for purported regulatory overreach and an anti-business agenda ignore EPA’s crucial work on safer chemicals in the marketplace. EDF + Business works closely with leading companies to address public health and consumer concerns regarding exposure to chemicals. Leading companies rely on smart, science-backed regulations to provide market certainty and protect their industries from bad actors. Threats to underfund and deregulate EPA could jeopardize its continued leadership, which is desperately needed on chemical safety.

In June 2016, the Frank R. Lautenberg Act was signed into law. The Lautenberg Act was the result of a strong bipartisan effort to reform the Toxic Substances Control Act (TSCA) and finally give EPA the means to protect Americans from exposure to toxic chemicals. The Lautenberg Act not only had strong support from both sides of the aisle in Congress, it also had strong support from business: including trade groups like the American Chemistry Council, the Chamber of Commerce and individual companies like BASF and SC Johnson. Why? Because they agreed that empowering EPA to review both new and existing chemicals and make affirmative decisions about their safety – thereby providing a consistent foundation for the safety of chemicals in the marketplace – would not only be good for improving public health, it would be good for business. The EPA’s job is to ensure a clean, healthy environment for all Americans. After years of input and strong bipartisan support, the reformed TSCA gave EPA the necessary tools to protect the public from toxic chemicals.

Business stands to benefit from greater market certainty and consumer confidence under the reformed TSCA. For example, product manufacturers should worry less about investing in the commercialization and usage of a chemical that years later could be found to imperil human health. And if the law meets its expectation, companies may in the long-term have less to fear about the state activity that had picked up when the federal government was not equipped to do its job. This action had been filling the void but led to a patchwork of requirements and regulations that bedeviled companies and left consumers confused about which chemicals in products were safe. The promise of greater market certainty and greater consumer confidence was critical to the Lautenberg Act’s support in Congress. Republican Senate sponsor David Vitter said, “Republicans agree to give EPA a whole lot [of] new additional authority. . . In exchange, that leads to … a common rulebook.”

However, fulfilling the promise of market certainty for industry and greater protection of consumer health depends on a funded and staffed EPA.  If some in industry and their allies in Congress seek to undermine EPA at every turn – whether through budget cuts, anti-regulatory legislation, or stall tactics – they will stymie the promise of the Lautenberg Act and find themselves back at square one. If on the other hand, business, environmentalists, Democrats and Republicans cooperate as they did to get the Lautenberg Act passed – but this time to ensure that EPA is enabled to implement the Lautenberg Act successfully, putting public health first – we could see a new era of chemical safety and innovation in the industry. And finally achieve what business and everyday Americans need.

Effective enforcement of bipartisan legislation is not the only place that the EPA can and must continue to lead. Creating opportunities for business leadership is also important. The innovative Energy Star program, a joint EPA-DOE voluntary energy efficiency program, is a great example of successful collaboration between business and federal agencies.  The EPA is also the architect of another, perhaps lesser known, voluntary corporate leadership program called Safer Choice.

The Safer Choice program is widely used by companies, celebrated by consumer advocacy groups, and helps to reduce the level of exposure to potentially hazardous chemicals. Touted by Consumer Reports as a meaningful tool for shoppers, the Safer Choice program recognizes products whose chemical ingredients are the safest within their function (e.g. solvents). Each product bearing the Safer Choice label – over 2000 today – has been evaluated by EPA scientists to ensure that the product’s ingredients meet the program’s rigorous human health and environmental safety criteria. BASF, Levi Strauss, Clorox, Staples, AkzoNobel, Sun Products are just a few of the 500 companies in the retail supply chain that have made the offering of Safer Choice ingredients or products a key part of their business. Likewise, influential trade associations such as The Worldwide Cleaning Industry Association (ISSA), with over 7000 members, and the Consumer Specialty Products Association (CSPA), with over 250 companies representing $100 billion in sales annually, have recognized and promoted Safer Choice as a program that can give companies a competitive edge in the marketplace. In a recent op-ed, CSPA called for the new EPA Administrator to support Safer Choice because it “has provided tangible, bottom-line results for consumers, businesses and environmental advocates.”

EPA regulatory enforcement to protect health, and voluntary programs that recognize leading companies, benefit all Americans.

Why Food Safety Plans must consider chemical hazards

By: Tom Neltner, J.D.Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant, Environmental Defense Fund

Since September 17, 2016, most facilities storing, processing, or manufacturing food are required to identify and, if necessary, control potential hazards in food under a Preventive Controls Rule promulgated by the Food and Drug Administration (FDA) pursuant to the FDA Food Safety Modernization Act of 2011 (FSMA). Some foods have had similar requirements in place for years. For example, fruit and vegetable juice processors have been required to have a Hazard Analysis and Critical Control Point (HACCP) Plan since the early 2000s.

Record numbers of consumers rate chemicals as their top food safety concern A Food Safety Plan required by FDA is an effective means to respond to this concern and proactively manage risks posed by chemicals instead of reacting to often preventable incidents.

The driving force behind the law and the rules has been reducing the hazard of pathogenic contamination in food. However, the Preventive Controls Rule defines a hazard broadly to include any chemical, whether a contaminant or an additive, that “has the potential to cause illness or injury.”

In this blog, we will explore how the requirements of the Preventive Controls Rule apply to chemical hazards using lead as an example. We chose lead because it is known to cause injury and clearly meets the definition of a hazard. It is well-established that there is no safe level of lead in the blood of children leading to lower IQ and academic achievement, and increases in attention related behaviors. We also know it is all too common in food that toddlers eat. And scientific evidence indicates that much of the lead in food gets into children’s blood.

Four potential sources of lead in the food supply chain

Lead can get into food in different ways including:

  1. Absorption from contaminated soil into the roots, leaves, and, possibly, fruit. Soil may be contaminated from past use of lead arsenate pesticides or air deposition from burning leaded gasoline.
  2. Contact with contaminated soil during production or harvesting. For example, soil may get into a head of lettuce or on an apple that falls to the ground.
  3. Leaching from food handling equipment such as that made from brass or plastic that had lead intentionally added. Until 2014, brass used in drinking water applications could contain up to 8% lead and still be called lead-free. If such brass were used in pumps and valves in food production, leaching of lead into food may occur. Similarly, lead has also been used in PVC plastic as a stabilizer, although it has been phased out in U.S. and Europe. It is important to note that lead is not approved by FDA to be intentionally added to anything that contacts food. If any leaches into food from these sources, the lead would be considered an unapproved food additive. That would render the food adulterated and, therefore, illegal to sell. Note that a supplier’s claim that a material is “food grade” is no guarantee that its use is legal.
  4. Contamination of food or food contact materials during processing such as lead from deteriorated paint in the building.

Elements of a Food Safety Plan

Under the Preventive Controls Rule, most facilities storing, processing or manufacturing food must have a written Food Safety Plan that consists of seven items:

    1. A hazard analysis to identify and evaluate known or reasonably foreseeable hazards;
    2. Preventive controls to ensure hazards are significantly minimized or prevented and food will not be adulterated;
    3. Risk-based supply chain program to protect raw materials and ingredients from hazards;
    4. Plan for recalls should they be necessary;
    5. Procedures to monitor preventive controls to assure they are consistently performed;
    6. Corrective action procedures if preventive controls are not properly implemented; and
    7. Verification procedures to validate that preventive controls are adequate and effective, other procedures are being followed, and plan is reevaluated at least once every three years.

The path forward

The FSMA food safety planning requirements put in place a systematic approach for food manufacturers to prevent food safety problems rather than react when they arise. This includes problems that can result from chemical hazards as well as pathogens. The goal is to ensure that consumers are not exposed to adulterated food, whether because it contains “any poisonous or deleterious substance which may render it injurious to health” or it contains an unapproved food or color additive.A robust food safety plan for lead and other chemicals such as perchlorate would go a long way to protect children and pregnant women from unnecessary exposures to chemicals known to impair brain development, and the businesses from unnecessary risk.

What a Food Safety Plan would say for lead

To comply with the regulations and mitigate risk, the food manufacturer/processor’s written food safety plan is required to identify lead as a hazard if it is reasonably foreseeable that lead could get into food either as a contaminant or from its intentional addition to materials such as brass or plastic used in food handling equipment.

If the plan identifies lead as a hazard, the company must evaluate the risk by assessing (1) the severity of the illness or injury if the hazard were to occur, and (2) the probability that the hazard will occur in the absence of preventive controls. The plan must also develop and implement preventive controls to assure lead levels are significantly minimized or prevented and the food is not adulterated. The controls would likely include:

    1. Setting the maximum amount of lead allowed in the raw materials, food contact substances, ingredients, and final product and establishing a testing program to assure the limits are met. For food products marketed to pregnant woman, infants, and young children, any detectable level of lead poses a health risk. For other foods, a limit such as the 5 ppb set by FDA for bottled water could be used as guidance. Note that the American Academy of Pediatrics recommends 1 ppb for tap water in schools.
    2. A program to manage the risk-based supply chain to prevent lead from getting into the materials suppliers provide. This program would include procedures to ensure that brass, plastic, and other materials that contact food do not contain any added lead that may leach into food. One way to accomplish this is to verify all equipment is certified as compliant with NSF-51 by the National Sanitation Foundation.
    3. Verifying suppliers are following appropriate preventive controls in production and harvest.

Next, the company must identify how the preventive controls would be monitored to spot implementation problems, explain how a recall would be conducted if lead were found to exceed the maximum amount identified in the plan or is present as an unapproved food additive, and describe what corrective action would be taken to prevent future recalls.

Finally, the food manufacturer/processor must reanalyze its Food Safety Plan at least every three years or when:

  1. There is a significant change in the activities conducted at the facility that creates a reasonable potential for a new hazard or creates a significant increase in a previously identified hazard;
  2. The food manufacturer becomes aware of new information about potential hazards associated with the food;
  3. An unanticipated food safety problem occurs; or
  4. The food manufacturer finds the preventive control, combination of preventive controls, or the food safety plan as a whole is ineffective.

The Food Safety Plans are not made publicly available, but they must be made available to FDA on request or during an inspection. Potential downstream buyers and retailers most likely can obtain a copy through their own supply chain management programs.

Target moves up the safer chemicals leadership ladder

Yesterday Target announced a new chemicals policy that applies to all products sold in its stores and to its operations. Does this policy have the capability to transform the marketplace by ushering in safer affordable products? Let’s take a look.

In the new policy, Target announces aspirations and time-bounded goals framed in three major areas: transparency, chemical management, and innovation.

On transparency, Target has surpassed its competitors by committing to gain not only full visibility into the chemicals in final products but also into chemicals used in manufacturing operations. Target also takes a leadership stance by aspiring for this full material disclosure across all product categories. This goal is significant and noteworthy, considering the number and variety of products (and associated manufacturing processes) at the average retail store. Target will first implement this transparency goal in “beauty, baby care, personal care and household cleaning formulated products by 2020”. In one drawback, Target is quiet regarding if and how this enhanced supply chain transparency will translate into greater ingredient transparency to consumers.

In the second area, chemical management, Target vows to implement a hazard-based approach to prioritize chemicals. It announces the use of hazard profiles – which characterize the inherent health and environmental hazards of chemicals – in judging which chemicals get added to Target’s new Restricted Substances Lists (RSLs) and Manufacturing Restricted Substances Lists (MRSLs), for future reduction and/or removal. This approach is critical to fostering safer product design and is in line with the philosophy of the Commons Principles for Alternatives Assessment, guiding principles EDF helped develop.  To kick off this work, Target outlines chemical and product specific goals: removal of PFCs and flame retardants from textiles by 2022 and removal of formaldehyde and formaldehyde donors, phthalates, butyl paraben, propyl paraben, and NPEs from the formulated product categories mentioned above by 2020.

Finally, Target commits to directly support safer chemicals innovation. In doing so, Target has shown its understanding that eliminating hazardous chemicals from the consumer product value chain is half the battle; promoting the development or discovery of safer alternatives and enabling their usability in products is as important. Specifically, Target pledges an investment of up to $5 million in green chemistry innovation by 2022.

Target also pledges to publicly share progress against its new policy on an annual basis. We look forward to this regular engagement of the public and hope it will include quantitative measures of progress.

EDF commends Target for establishing a corporate chemicals policy, making it ambitious, and stipulating time-bound goals in specific product categories. Target continues the emphasis on beauty, home and personal care, and baby products that it initiated in 2013 with its Sustainable Product Index. New to the fold is action on safer textiles. In another welcome development, Target has publicly released a key set of chemicals of concern that it plans to remove from these product categories. Interestingly for formulated products, Target’s starting list of chemicals for removal is very similar to the initial set of high priority chemicals Walmart disclosed in 2016. With the two largest retailers in the U.S. not slowing down on safer chemicals leadership, the future of the marketplace looks healthier.  Will other retailers finally follow suit?

New CSPI report investigates "clean label" foods, offers key recommendations

Slightly more than a third of Americans think “clean-label” products are free from artificial ingredients. About a third think it means organic or natural. And roughly a third of Americans don’t know what clean label means. For retailers, restaurants, and food manufacturers, that creates a challenging landscape – and one with few [1] defined guardrails.

Today, the Center for Science in the Public Interest (CSPI) released a new report, Clean Labels: Public Relations or Public Health?, that assesses efforts by four restaurants – Chipotle Mexican Grill, Noodles & Company, Panera Bread, and Papa John’s – and nine grocers – Ahold Delhaize (Food Lion, Giant Food, Stop and Shop), Aldi, H-E-B, Kroger, Meijer, Supervalu, Target, Wakefern (ShopRite), and Whole Foods  – to deliver what they interpreted a “clean label” product to mean. The report is well worth the read.

EDF agrees with the CSPI report statement that, “[m]ost substances added to food—even ones with long chemical names—are safe… But some are not, and many have been poorly tested. Indeed, the system intended to ensure the safety of ingredients added to food is deeply flawed.”

We also agree with CSPI that, “To the extent that clean label products are healthier than their non-clean label counterparts, because they are made with actual foods instead of cheap chemical imitations, they deserve praise. Still, the absence of artificial ingredients does not make a food healthy, since it could still be loaded with saturated fat, salt, or added sugars and be largely devoid of dietary fiber and nutrients.” For EDF, clean labels also provide no assurance about other unknown and hazardous food additives such as those used in packaging like perchlorate or that enter food during manufacturing and processing like phthalates.

What should make the report of interest to all engaged in the business of food, from those making it to eating it, are the well-substantiated recommendations for addressing food ingredients in clean-label programs. The CSPI report defines and then assesses the suite of best-in-class clean label efforts by supermarkets and restaurants across three major components:  ingredients covered, food and beverage products covered, and transparency. In general, transparency efforts are strongest, coverage across products is weakest, with ingredient reformulation somewhere in the middle.

The report concludes with a trio of target recommendations and action steps, including:

  • Prioritize public health – Clean-label commitments should be accompanied by meaningful improvements to the nutritional quality of the foods and beverages sold.
  • Comprehensive policies – Lists of prohibited ingredients should apply to all products a restaurant makes or sells, including beverages, and supermarkets should expand clean label policies to all of their private-label brands.
  • Transparency – Restaurants should provide complete ingredient and nutrition information for all menu items, both on-site and on their website, and supermarkets should provide this information on their websites.

Given that natural is an artificial, and often erroneous, synonym for healthy, Clean Labels: Public Relations or Public Health? does just what CSPI intended – provides a useful assessment of clean label efforts that give direction and guidance to companies committed to improving the health and safety of the food they make and sell.

For companies seeking to improve their own food offerings, EDF+Business invites you to visit Behind the Label: A Blueprint for Safer Food Additives in the Marketplace. This online resource details best practices for the five pillars of leadership, offers a model policy and case example, as well as tracking corporate efforts in this space.

[1] “Certified organic” is a federally defined and regulated status.