Public Awareness

Greenwashing and CBC #7: Simple Green All-Purpose Cleaner

Written by ‘Curious Chemical Engineer’ at the Just Curious Blog – to see more, visit http://curiouschemeng.blogspot.com/2012/10/greenwashing-and-cbc-7-simple-green-all.html

Continuing from last week with #7 on the CBC Marketplace “Lousy Labels” greenwashing list is Simple Green All-Purpose Cleaner…  Click here to read more.

A MESSAGE ABOUT 2-BUTOXYETHANOL
AND SIMPLE GREEN® PRODUCTS:

They Are Not The Same

We appreciate the opportunity to present you with some facts that belie the chemical-scare and “green-washing” stories that have been published about our product…  Click here to read more.

Is Simple Green Non-Toxic?

“Greenwashing.” This has been a recently published opinion of us and our product Simple Green. While we respect the rights of folks to have and share their opinions, we also appreciate the opportunity to respond and share some facts on this issue…  Click here to read more.

California Transparency in Supply Chains
Act of 2010 (S.B. 657):

Sunshine Makers, Inc., doing business as Simple Green®, believe in the importance of labor and human rights…  Click here to read more.

SWINE FLU FACTS:

The US Centers for Disease Control has complied the most thorough and factual information about the current Swine Flu outbreak…  Click here to read more.

MRSA STRIKES HOUSE OF REPRESENTATIVES GYM

“WASHINGTON - The gym that is used as a workout and recreational facility by some of Washington’s most powerful and influential people has been invaded by Methicillin-resistant Staphylococcus aureus (MRSA), according to InjuryBoard.com…”  Click here to read more.

MRSA – INFORMATION & SUGGESTIONS
FOR FACILITIES MAINTENANCE

Methicillin-resistant Staphylococcus aureus (MRSA) is a type of bacteria that is not easily treated with common antibiotics. MRSA can cause skin infections that may look like spider bites, infected turf burns, impetigo, boils or abscesses. It is spread by touching the infection/drainage or by touching surfaces that have come in contact with the infection/drainage…”  Click here to read more.

Greenwashing and CBC #7: Simple Green All-Purpose Cleaner

Written by ‘Curious Chemical Engineer’ at the Just Curious Blog – to see more, visit http://curiouschemeng.blogspot.com/2012/10/greenwashing-and-cbc-7-simple-green-all.html

Continuing from last week with #7 on the CBC Marketplace “Lousy Labels” greenwashing list is Simple Green All-Purpose Cleaner.

As I mentioned last week, Marketplace is a 22 minute show and they did a 10-product countdown, giving them approximately 2 minutes per product, so they had to leave a lot of information out.

So, first things first: the Simple Green MSDS.

The ingredients of Simple Green All-Purpose Cleaner are:

• Ingredients
• CAS Number
• Percent Range
• Water
• 7732-18-5
• ≥78%
• 2-butoxyethanol
• 111-76-2
• ≤5%
• Ethoxylated Alcohol
• 68439-46-3
• ≤5%
• Tetrapotassium Pyrophosphate
• 7320-34-5
• ≤5%
• Sodium Citrate
• 68-04-2
• ≤5%
• Fragrance
• Proprietary Mixture
• ≤1%
• Colorant
• Proprietary Mixture
• ≤1%

2-butoxyethanol is a general-purpose solvent that’s good at lifting stuff that isn’t water soluble, while itself being water soluble.

Ethoxylated Alcohol is a detergent and emulsifier. Not sure which of its roles it’s supposed to be here for, or maybe it’s both.

Tetrapotassium pyrophosphate is an emulsifier as well.

Sodium citrate is probably a buffering agent, used to keep the pH stable. Itrsquo;s also used in food as a preservative, but since this isnrsquo;t a food, it’s probably being used for its pH effect.

The fragrance and colorant I can’t say anything about because ’s proprietary, so they probably wouldn’t tell me even if I asked. Apparently the smell is supposed to be sassafras. I don’t think I’ve ever smelled real sassafras, so I don’t know how accurate it is.

The Simple Green product claims of interest to somebody looking for greenwashing are: “An environmentally-sensitive non-toxic cleaner/degreaser […] non-toxic and biodegradable.”

CBC Marketplace says that Simple Green contains a toxic substance, the 2-butoxyethanol, which is listed by Environment Canada as a toxic health hazard that can damage red blood cells, and therefore the “non-toxic” claim is greenwashing.

Naturally I go see what EC has to say about this, and I found both the fact sheet and the regulation (plus a later update to the regulation) on 2-butoxyethanol. (Note: the fact sheet was written before the work was complete on the regulation, and has not been updated since to judge by the “regulation is expected to be released” date years in the past.)

So the fact sheet says, “Based on investigations in experimental animals, the risk assessment report concluded [in 2003] that chronic exposure to 2-BE could cause alterations in blood that are associated with hemolytic anemia.” In the regulation that was developed, the limit for “any other non-aerosol cleaner” is 6%. The Simple Green MSDS says the 2-butoxyethanol concentration is less than 5%, and the company statement said it was 3.8%. So, well within what Environment Canada said was a safe concentration for indoor household use.

Just how toxic is 2-butoxyethanol, though? The assessment report that EC got has quite an extensive section on toxicity testing, which I’ll try my best to summarize here.

Short term effects in all the animals tested started with reduced red blood cell count, with rats the most sensitive showing effects at oral doses of 100mg/kg body weight per day for a few days, but mice much less sensitive as they started to show effects at 500mg/kg per day. These effects reversed themselves once the dose was stopped and the body cleared itself of 2-butoxyethanol. To be pessimistic, we’ll take the rat dose as being the dose at which the red blood cell count starts to be affected, and use an average adult human body weight of 62kg. This works out to 0.1g * 62kg = 6.2 grams swallowed to get a decrease in red blood cells, the first of the symptoms. Since Simple Green is 3.8% 2-butoxyethanol, you’d have to drink 6.2g/0.038 = 163g of the cleaning solution to get that dose. Note that this is pessimistic; the rats were by far the most sensitive of the animals tested, and test-tube trials of samples provided by humans and rats showed that human samples were also much less sensitive than rat samples. If human response is closer to the mouse response, you’d have to drink five times more to get a dose that would start to affect your red blood cells. You’d have to drink more again to get into changes in the internal organs.

Long term effects were basically the same, starting with low red blood cell count. Again, with rats being the most sensitive, the oral dose that caused female rats (but not males—it took about double the dose for male rats) was 82mg/kg per day over thirteen weeks. For the same “average person” of 62kg, this is 0.082g * 62kg = 5.1 grams pure or 5.1/0.038 = 134g of the cleaning solution every day for three months to get that dose. As above, this is the dose at which female rats start showing symptoms, and the other animals including humans are less sensitive.

Since this product is for cleaning and one generally doesn’t drink cleaning solutions, the more likely way to get a dose of any size is either by inhaling vapour or by absorbing through the skin. The dose at which the first symptoms appeared was again in female rats, breathing air containing 31ppm of 2-butoxyethanol for 14 weeks. For male rats this was four times higher, and again, rats were the most sensitive. The US OSHA has set an exposure limit for workers of 50ppm for people working with the stuff for 8 hours per day, 40 hours per week. This is higher than what female rats living in it 24/7 showed effects at, but lower than what caused the first effects in all the other test animals exposed 24/7.

The actual maximum concentrations in the air during cleaning (and other uses) was measured and found to be well below the 8-hour exposure limit (page 166) for all tested applications except silkscreening and applying varnish. The concentrations of 2-butoxyethanol for the cleaning solutions most likely to be used in the home are below 3.8% (0.3% for the floor cleaning example), but Simple Green does say it’s concentrated and that it should be diluted for most uses. Looks like a 1:10 dilution (about 0.3-0.4%) is a reasonable floor scrubbing solution, and exposes you to an average non-detectable and maximum 1/5th of the 8-hour exposure limit, flagged as an outlier. There was no information on ventilation in that table, so the 1/5th outlier value could very well be a small room with the door closed and no ventilation. The same document indicates that studies on humans showed eye irritation at 113ppm and headache at 100ppm, double the 50ppm 8-hour exposure limit (page 172) and 50 times more than the maximum exposure during floor washing. Red blood cell effects were not measurable at 195ppm, nearly double the concentration at which you get a headache. The same page indicates that in humans, effects on the blood are only seen in people who drank 30-60g of 2-butoxyethanol—or the equivalent of 789g of Simple Green. I can’t imagine that would taste very good.

After looking at the toxicity data, it sounds like this stuff is quite safe even in its concentrated form, but if you have a pet rat that tends to chew through things it shouldn’t, you might want to keep it safely separated from the bottle so it doesn’t eat a hole in it and get a Simple Green bath.

It seems to me that the “non-toxic” claim that Simple Green makes about its formulation is true. I have only looked at the one ingredient that CBC Marketplace said was toxic, thus assuming they couldn’t find anything about the other ingredients to get scared about and so they weren’t toxic. As far as the "biodegradable" claim, many of the references I linked above also mentioned that 2-butoxyethanol degrades within a couple of days in air or water, so that would also be true.

Regarding the CBC Marketplace claims that 2-butoxyethanol is a toxic ingredient, yes, pure 2-butoxyethanol is toxic. However, they completely miss the concept of a dose response.

To use a different chemical as an example, oxalic acid vapour causes irritation above 1-2 mg/m3, where the 50ppm limit for 2-butoxyethanol is 242mg/m3 and irritation starts at about double that. The LD50 for oral oxalic acid in rats is 375mg/kg which is in the range of first symptoms for 2-butoxyethanol (100-ish for rats, 500-ish for mice), nowhere near killing them.

The reason I mention oxalic acid? Well, it’s substantially more toxic than 2-butoxyethanol, and yet at a low dose, we eat it regularly. There are many healthy foods that contain oxalic acid, some up to a couple of percent. 2-butoxyethanol at 3.8% concentrated Simple Green solution vs. the orders of magnitude more toxic oxalic acid at 0.5-2% in swiss chard, spinach, rhubarb, parsley…

Oxalic acid—it’s what’s for dinner.

Obviously I’m not advocating drinking Simple Green. It’s not food. But even getting a splash in your mouth isn’t going to make you sick. (Although it might taste bad.)

My bottom line? I think next time I need to buy some cleaners, I may buy some Simple Green to see if it cleans as well as they say it does. It’s definitely less toxic than the bleach-based cleaners currently in my cupboard. I’m getting more and more disappointed in CBC Marketplace as this show goes along.

Sources and background data for the statements made here are linked in the original post at http://curiouschemeng.blogspot.com/2012/10/greenwashing-and-cbc-7-simple-green-all.html.

Back to top

Is Simple Green Non-Toxic?

“Greenwashing.” This has been a recently published opinion of us and our product Simple Green. While we respect the rights of folks to have and share their opinions, we also appreciate the opportunity to respond and share some facts on this issue.

For over 35 years at Sunshine Makers, Inc., we have defined “green” as the support of our non-toxic and biodegradable credentials with independent laboratory test data that classifies the product as such within accepted scientific, legal, and regulatory standards. We have sought to be as “green” as possible while providing good value to the consumer in the form of a dilutable concentrate and a product that safely cleans what we say it will clean. Through the years we have innovated better, more sustainable packaging and ingredient choices. We have always manufactured and sold our products in accordance with the laws that govern the markets in which we sell.

The term non-toxic is on our label because independent laboratory testing of our finished formulation places the product into that classification within CPSC, OSHA and EPA regulatory structures. These government agencies have reviewed our data and confirmed the appropriateness of that term for use on our product label. The same is true for the term biodegradable. Again, Simple Green has been tested by independent scientific laboratories utilizing globally acceptable testing standards and has been classified “readily biodegradable,” which is the highest classification of biodegradability.

It has recently been charged that our product contains a “secret blend of alcohol ethoxylates” and inferred that perhaps the one we use is banned in Europe. This is not the case. We use Ethoxylated Alcohol CAS# 68439-46-3. This surfactant is not banned anywhere in the world, is listed on our MSDS, and the MSDS is posted on our web site where everyone has full access to the information.

We are accused of being green-washers without any scientific or legal basis for that accusation, and without any dialogue from our accuser. In today’s fast-paced media whirl, it is almost impossible to undo the damage caused by accusations of this sort. However, we can assure you that when given the opportunity to uphold our claims within the regulatory or legal world, we have always been able to do so.

If you would like to review the test data supporting our credentials, please send us a request by clicking https://secure.simplegreen.com/about_us_contact_us.php. Please also use that link for asking any questions you might have about this issue. We welcome the opportunity to provide information that shows that, based on factual data, we are not green-washers.

Sincerely,
Carol Chapin
Vice President, Research & Development
18-year company veteran and proud user of Simple Green products in my home.
800-228-0709
cchapin@simplegreen.com

Back to top

Open Letter Regarding:

California Transparency in Supply Chains Act of 2010 (S.B. 657)

Sunshine Makers, Inc., doing business as Simple Green®, believe in the importance of labor and human rights. As Sunshine Makers, it has been our mission to exclusively manufacture Simple Green® products sourced and made in the USA. We strive to be a socially responsible company dedicated to being a market leader, providing high quality, environmentally safer cleaning products. As a company policy, we do not knowingly employ slaves or trafficked persons. As of January 2012, the employ of slaves or trafficked persons and or the participation in human trafficking were expressly added as prohibitions to our company code of ethics.

Sunshine Makers has employed the following procedures with respect to our business relationships with vendors, partners, and other third parties with whom we conduct business to prevent slavery and human trafficking. All of the following policies went into effect January 1, 2012.

• We have sought to include provisions in our contracts with third party manufacturing to insure their compliance with SB 657; as well as, requiring their affirmation that they do not employ slaves or trafficked persons.
• We have included statements within our manufacturing guidelines regarding compliance with SB 657. We further require all third party manufacturers to affirm that any component material used in the final production of Simple Green products comply with the laws regarding slavery and human trafficking and the penalties for non-compliance.
• We plan on including training for all those management personnel involved in the potential hire of services provided to Sunshine Makers on slavery and human trafficking. This training shall include the company’s position on slavery and human trafficking; as well as, the procedures associated for violation of said company policy.

Sunshine Makers will not actively engage in the verification or audit procedures of our suppliers. The steps outlined above will be the extent of our voluntary compliance with SB 657. These compliance procedures will be monitored in accordance with our own internal policies.

Respectfully,
Sunshine Makers, Inc.
Simple Green

Back to top

SWINE FLU FACTS:

The US Centers for Disease Control has complied the most thorough and factual information about the current Swine Flu outbreak. http://www.cdc.gov/swineflu/key_facts.htm

The Swine Influenza is identified as an Influenza A H1N1 virus. Among other cautionary actions, the CDC recommends cleaning and disinfecting hard surfaces in homes and areas where known cases of Swine Flu have occurred. The CDC does not recommend any specific products. However, it is important to use an EPA-registered disinfectant. Simple Green d Pro 3 is EPA-registered to kill Influenza A, H3N2. Simple Green d Pro 5 is EPA-registered to kill Influenza A H1N1, and Avian Influenza H3N2 & H5N1.

The CDC recommendations for precautionary actions and care of a swine flu infected person in the home can be found at http://www.cdc.gov/swineflu/guidance_homecare.htm

MRSA STRIKES HOUSE OF REPRESENTATIVES GYM

From Cleaning Maintenance Management Online
Thursday, April 16, 2009
WASHINGTON - The gym that is used as a workout and recreational facility by some of Washington’s most powerful and influential people has been invaded by Methicillin-resistant Staphylococcus aureus (MRSA), according to InjuryBoard.com.

As a precautionary measure, the House of Representatives gym has been thoroughly disinfected with Simple Green D Pro 3 disinfectant and anyone who frequents the facility has been provided with literature about the infection, the story stated.

The House Chief Administrative Officer said: “A House employee has reportedly contracted Methicillin-resistant Staphylococcus Aureus (MRSA). That House employee is also a member of the House Staff Fitness Center (HSFC).”

Some lawmakers often sleep in their offices and use the gym facilities to shower, the story noted.

It remains unknown how or where the employee contracted the infection, the story added.

Simple Green d Pro 3 has a current EPA-stamped label that authorizes use for killing MRSA. This label is federally registered, and is currently going through full States registration - once all are complete, new labels will go onto product and it will start to replace the prior label in the marketplace. Therefore, product exists in the marketplace that is not labeled for MRSA, but the product as it is currently sold has been tested and verified effective against MRSA. This information was presented to the decision makers at this gym. The BRAND name is Simple Green, (product name is d Pro 3) but there are no “green claims” made for this product - that is against the law. If anyone has questions about our product or its applicability to this very serious situation, please call 800-228-0709, or visit our web site at www.simplegreen.com Although we strive to create the most environmentally responsible cleaners possible, we take public health VERY seriously, and do not play around with the claims for killing things such as MRSA. —The Simple Green Technical & Regulatory Department.

Back to top

MRSA – INFORMATION & SUGGESTIONS
FOR FACILITIES MAINTENANCE

Methicillin-resistant Staphylococcus aureus (MRSA) is a type of bacteria that is not easily treated with common antibiotics. MRSA can cause skin infections that may look like spider bites, infected turf burns, impetigo, boils or abscesses. It is spread by touching the infection/drainage or by touching surfaces that have come in contact with the infection/drainage.

MRSA can stay alive on surfaces for weeks, even months. Frequent hand washing is the best way to prevent MRSA. Cleaning and disinfecting surfaces that may have come in contact with the MRSA bacteria is necessary to keep the environment healthy.

Cleaning not only makes facilities look nice, it also helps make a facility or community a healthy and safe place. Removing “dirt” we can see by cleaning is the first step. Once the dirt we can see is removed, disinfect, or remove germs, by treating surfaces with an EPA-registered disinfectant. Germs (bacteria and viruses) are removed and killed during routine cleaning and disinfecting activities. Allergens (mold, pollen, dust mites and other irritants) are removed during cleaning activities like vacuuming, sweeping and mopping.

Please keep in mind that proper use of cleaners and disinfectants is of the utmost importance. This not only insures safety but the best performance of the cleaner and germ killing efficacy of the disinfectant. Following label instructions on disinfectants is mandatory (per Federal EPA regulations).

General Consideration When Using Disinfectants

1. Check the product label to ensure that the disinfectant is suitable for the type of surface being treated (e.g., vinyl, cloth, plastic, or wood).
2. Check that the product label specifies Staphylococcus aureus.
3. Ensure that the disinfectant is prepared to the proper use concentration and that this working solution remains on the surface for the recommended contact time.
4. Unused working solutions of disinfectant can be poured down the drain. Disposable wipe cloths can be discarded as a routine solid waste.

Except when sanitizers and disinfectants are required for health reasons, cleaning products should be nontoxic and biodegradable (able to break down quickly in the environment). You can do this by using Simple Green® All-Purpose Cleaner, Crystal Simple Green®, or Simple Green Clean Building® All-Purpose Cleaner, which is also Green Seal Certified.

Simple Green d Pro 5® (a quaternary ammonium compound) is an EPA Registered Disinfectant and Sanitizer. Simple Green d Pro 5® offers a high level of active ingredient which provides killing efficacy against a large list of virulent pathogens, including MRSA. It is a concentrated cleaner, disinfectant and sanitizer that, when used according to directions, proves to be absolutely effective on the bacterial, viral and fungal threats that can invade our lives.

The following pages contain guidelines for janitorial and maintenance staff as well as general safety information to protect individuals in community settings.

The key to safely and effectively cleaning and disinfecting is to educate maintenance staff and personnel on proper technique. The following recommendations may refer to policies that are already in place, as well as policies that should be developed or adopted.

GENERAL GUIDANCE

1. Hard surfaces and equipment such as floors, light switches, door handles, hand-rails, tables and desks should be cleaned routinely and disinfected daily.
2. In an office setting, phones, keyboards, desks and vending machines should be routinely cleaned and disinfected daily when more that one person will come into contact with the surface.
3. If during a sporting event there is a release of bodily fluids (blood, pus or drainage) cleaning and disinfecting should be completed before the activity is allowed to continue.

PERSONAL HYGIENE

1. Wash hands using liquid soap and water upon entering and exiting the premises and before and after any hands on contact with other persons. Alternatively, an alcohol based hand rub can be used according to label instructions. Visibly soiled hands should be washed with soap and water rather that an alcohol based hand rub.
2. Dry hands with disposable paper towels or blowers (e.g. avoid sharing towels).
3. Keep skin lesions (e.g., boils, insect bites, open sores, or cuts) covered with a clean, dry dressing.
4. Limit sharing of personal items (e.g., towels, clothing, or soap).
5. Use a barrier (e.g., a towel or a layer of clothing between the skin and shared equipment*.
6. Shower if there has been substantial skin on skin contact with another person.

SHARED EQUIPMENT

1. Use a towel or clothing to act as a barrier between surfaces of shared equipment and bare skin.
2. Wipe surfaces of equipment before and after use, especially if the surface has become wet with sweat.
3. Schedule regular cleanings for sports equipment: balls (football, basketballs, baseballs, softballs, and volleyballs), racket grips, bats, gloves, pads, etc.
4. Clean and sanitize sports equipment that comes in direct contact with the skin of players, such as wrestling headgear, football helmets and fencing equipment (including wires) after each use.

ATHLETIC AREAS

1. All hard surfaces that may come in contact with body fluids should be cleaned¹ and disinfected² daily with an EPA-approved disinfectant, including benches, weights, workout machines, etc.
2. All floors/wall padding in athletic settings should be washed daily (if room is used).
3. Locker rooms, including any shower areas should be cleaned daily, if used.
4. If soap is furnished, it should be accessible from a wall dispenser.
5. Ensure that athletic areas, locker rooms and restrooms all have separate cleaning mops and buckets, and that all mops (washable micro-fiber heads or disposable mop cloths preferred) and buckets are cleaned and sanitized after each use.
6. Use “dedicated” mop heads to clean mat surfaces. Wash these mop heads on a regular basis. Disposable mop heads are an appropriate alternative.
7. Clean and sanitize mats before and after practice and matches. When mats are rolled up, all sides of mats should be cleaned and dry before they are rolled up.

LOCKER ROOMS/SHOWER ROOMS/STEAM ROOMS & SAUNAS

1. Use a towel or clothing to act as a barrier between benches and bare skin.
2. Allow steam rooms/saunas to dry at least once a day (this will help minimize the development of a bacterial bio-film).
3. Clean and disinfect frequently touched surfaces daily. Sanitizing shower doors, walls, fixtures and floor is recommended after each use.

LAUNDRY

1. Wash shared linens (e.g., towels, sheets, blankets, or uniforms) in detergent and water at 160° F for at least 25 minutes.
2. Use laundry additives according to the manufacturer’s instructions.
3. Use a mechanical dryer on hot temperature cycle (i.e., avoid air drying).
4. Distribute towels, uniforms, etc. only when they are completely dry.

Facility staff should be instructed in and encouraged to:

1. Make spray bottles of disinfectant that are correctly diluted and mixed daily.
2. Clean shared equipment and hard surfaces daily to remove soil.
3. Disinfect shared equipment and hard surfaces with an EPA registered disinfectant.
4. Check with equipment manufacturers for recommendations on the appropriate maintenance of their products.
5. Repair or dispose of equipment and furniture with damaged surfaces that cannot be adequately cleaned.
6. Clean and disinfect large surfaces (e.g., floors and tabletops) daily.

Please refer to the following links for more information about MRSA:

http://www2a.cdc.gov/podcasts/player.asp?f=6936Back to top

A Message About 2-Butoxyethanol and Simple Green Products:

They Are Not The Same

We appreciate the opportunity to present you with some facts that belie the chemical-scare and “green-washing” stories that have been published about our product.

We hope that you will review the actual scientific evidence on our product as a whole, and not condemn it for containing a small fraction of an ingredient that is not carcinogenic, nor harmful to human health or the environment as found in our product and when used for the purpose intended and according to label instructions.

Scientific fact asserts that it is incorrect to assign qualities and characteristics to a mixture based solely on one fraction of that mixture. Scientific fact also asserts that toxicity is dose and exposure related. Sunshine Makers, Inc., the makers of Simple Green brand products, does not sell 100% 2-butoxyethanol, or 50%, or 25%, or even 5%. In fact, we do not sell any product that contains more than 3.8% 2-butoxyethanol to the Household Consumer marketplace.

We are offended by being characterized as green-washers and our product as toxic, when the scientific test data on our finished formula shows otherwise.

Over the many years (35+) we have been in business, we have had independent laboratories such as the Research Triangle Institute, Duke University Biological Laboratories, US Testing Labs, and many others conduct a host of testing on our product as a whole to confirm that the complete formula is non-toxic in accordance with the definition of that term by the Occupational Safety & Health Administration, Consumer Product Safety Commission, and experts in the legal and toxicology fields. We have not paid them to manipulate data or give us the results we prefer. We have paid these labs to perform globally accepted standardized tests on our product. Please see a small group of representative tests attached below.

As scientists continue to evaluate the health and safety aspects of 2-butoxyethanol, result has been a downgrading of the level of toxicity classification given to this chemical. Over the years, the US Environmental Protection Agency has repeatedly reviewed the numerous and varied scientific studies conducted by global research laboratories. They utilize the vast public record of research studies to classify chemicals with regard to their safety, or lack thereof. Here are 2005 and 2010 assessment summaries of 2-butoxyethanol:

EPA 600/R-04/123
February, 2005
Final
An Evaluation of the Human Carcinogenic Potential of Ethylene Glycol Butyl Ether
National Center for Environmental Assessment Office of Research and Development U.S. Environmental Protection Agency
The U.S. Environmental Protection Agency (EPA) IRIS (Integrated Risk Information System) assessment (U.S. EPA, 1999a) concluded that, in accordance with the proposed Guidelines for Carcinogen Risk Assessment (U.S. EPA, 1996), the human carcinogenicity of EGBE “cannot be determined at this time, but suggestive evidence exists from rodent studies.” Under the pre-existing EPA guidelines (U.S. EPA, 1986), EGBE was judged to be a “possible human carcinogen.” These findings by EPA and NTP prompted investigators, largely supported by the Glycol Ethers Panel of the American Chemistry Council, to design research projects aimed at determining the mode of action for the formation of the forestomach and liver tumors observed in mice.

EPA/635/R-08/006F
March 2010
www.epa.gov/iris
TOXICOLOGICAL REVIEW OF
ETHYLENE GLYCOL MONOBUTYL ETHER (EGBE) (CAS No. 111-76-2)
In Support of Summary Information on the Integrated Risk Information System (IRIS)
U.S. Environmental Protection Agency
Washington, DC
Under the Guidelines for Carcinogen Risk Assessment (U.S. EPA, 2005, 086237), EGBE is deemed “not likely to be carcinogenic to humans” at environmental concentrations below or equivalent to the RfD and RfC, based on laboratory animal evidence, mode-of-action information, and limited human study information.

Also see, EPA Delisting of EGBE.pdf

Some people have linked our product to Corexit, the dispersant used on the BP oil spill. Likening Simple Green to Corexit is not a scientifically accurate comparison. Simple Green contains less than 4% of 2-butoxyethanol, while, according to their Material Safety Data Sheet, Corexit contains 30 – 60%. There is an enormous difference in the toxicity characteristics between those two levels of dilution — similar to the toxicity level of ingesting two aspirin, versus ingesting an entire jumbo-sized bottle of aspirin.

It has been erroneously reported that 2-butoxyethanol has been banned in the UK or in Europe. In fact, we lawfully sell Simple Green, containing 2-butoxyethanol, in Europe and all of our ingredients have been registered with the European agency that is registering and reviewing chemicals to establish a more thorough chemical inventory called REACH. To date, 2-butoxyethanol has not been added to the growing “SVHC” Substances of Very High Concern list that the REACH scientists are forming.

It is irresponsible pseudo-science to assign the qualities and characteristics of one ingredient to our entire mixture. If that was sound science, you would not eat, drink, put on your skin, bathe with, medicate with, or otherwise utilize many, many, many products that are in the marketplace today. Dose- or exposure-related toxicology is the science behind prescribing correct volumes of ingredients in medicines, nutritional supplements, health and hygiene products, and, yes, even cleaning products. [Conversely, even if 2-butoxyethanol was found to be completely non-toxic, we would not base the classification of our product as a whole solely on that one ingredient.] Sunshine Makers, Inc., the makers of Simple Green products, has always been involved in reviewing and furthering the science of toxicology, and our position as a leader in environmental cleaning products has been upheld by correct science.

Thank you for the opportunity to present you with a more complete picture of the science of single-substances versus mixtures, and the relation of toxicity to dosage/exposure.

Sincerely,

Carol E. Chapin
Vice President, Research & Development
Sunshine Makers, Inc. / SIMPLE GREEN

Further reading:

Back to top