Beta Montemayor, Director, Environmental Science and Regulation at CCTFA presented as one of five panelists on "Retailer "Sustainability" Initiatives - A Background and Discussion of Potential Implications for Consumer Product Regulation" at Consumer Health Products Canada (CHP Canada) and The Canadian Cosmetic, Toiletry and Fragrance Association (CCTFA)'s 2014 Health & Beauty Conference in Milton, Ontario on September 19th, 2014.

1. Leading Canadian Trade Association for the Personal Care Products Industry
© Copyright 2014 (all rights reserved)
Retailer ‘Product Sustainability’ Initiatives
A Discussion of Potential Implications for Consumer Product Regulation
A Science Perspective
CHP Canada/CCTFA Health & Beauty Conference 2014
JW Marriott The Rosseau Muskoka Resort
September 19, 2014

2. © Copyright 2014 (all rights reserved)
Disclaimer
Slide 2
All information shared during this presentation are the expressed opinions of the presenter and all related presentation materials are the property of the Canadian Cosmetic, Toiletry and Fragrance Association (CCTFA). This information is shared for the purpose of this specific speaking engagement and should not be made public or circulated without prior approval and written consent from the presenter and the CCTFA. Information as presented should not be relied upon as legal advice and companies are advised to consult with legal counsel to verify the relevance and applicability of any information provided.

3. © Copyright 2014 (all rights reserved)
Outline
Slide 3
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Ingredient campaigns under the “sustainability” umbrella – ‘Let’s call a spade a spade’
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The ‘real’ picture –why the sole focus on personal care?
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The quest for ‘green’ –not necessarily safer
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Undermining sound scientific regulatory decision‐making – the Canadian CMP at risk

4. © Copyright 2014 (all rights reserved)
What’s In a Word?
Slide 4

5. © Copyright 2014 (all rights reserved)
‘Product Sustainability’ Fiction
Slide 5
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Beauty and Personal Care Products Sustainability Summit
Reality…
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Ingredient campaigns hiding under the ‘product sustainability’ umbrella
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Not at all about sustainability performance, rather largely about managing so called ‘toxics’ (the pressure group agenda)
“To improve sustainability performance in the personal care and beauty industry”
Forum for the Future (2014)

6. © Copyright 2014 (all rights reserved)
‘Product Sustainability’ Fiction [cont.]
Slide 6
“CALLING A SPADE A SPADE”
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If these initiatives are really about “sustainability”
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Carbon footprint
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Energy management
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Ethical sourcing
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Sustainable development
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Resource conservation
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Waste management
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etc.
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In addition to…
Substance/Product stewardship(green chemistry)

7. © Copyright 2014 (all rights reserved)
‘Product Sustainability’ Fiction [cont.]
Slide 7
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Substance/product stewardship and the management of ‘toxics’ should be one, relatively small component to an overall “sustainability” (environmental) model
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Sound management of chemicals and responsible product stewardship are integral to the personal care business (producing a ‘toxic’ product would not be in the interest of industry)
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If one wanted to make a “sustainable” difference; focus should perhaps be on other facets
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Well intentioned, but misguided focus

8. © Copyright 2014 (all rights reserved)
‘Sustainable Product’ Standard†
Slide 8
Criteria
Points
ScoringDeterminants
Ingredients
50
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0 points (one or more ingredients on designated hazards lists*)
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Max.of 25 points (no ingredients on hazards list but ‘high’ generic hazards [e.g. Fragrance, etc.])
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Max. of 40 points (no ingredients on hazards list but ‘low’ generic hazards [e.g. enzyme, etc.])
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50 points (no ingredients on designated lists and no generic ingredients)
Transparency
20
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20 points (if complete list of ingredients are available on pack and/or website; purposes of ingredients are provided; no generic ingredients)
Animal Testing
5
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5 points (third‐party certification prohibiting animal testing in development or production)
Packaging
20
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20 points (recyclable by a ‘substantial majority’ of consumers; primary packaging is comprised at leastof 25 –35% of post‐consumer and/or post‐industrial materials; includeshow 2 recycle labelling on pack)
WaterQuality
5
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5 points (noingredients considered to be hazardous to aquatic environment**)
* Prop 65; ECHA SVHCs; EU Endocrine Priority List; US EPA PBTs; Chemicals of High Concern to Children, Washington Department of Ecology)
** ECHA GHS (acute/chronic hazards)
† Powered by Underwriters Laboratories (UL) Good Guide™Purview Platform [TARGET’s MODEL]
Human Health
Environment & Community

9. © Copyright 2014 (all rights reserved)
‘Sustainable Product’ Standard [cont.]
Slide 9
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75 –80% of the score is focused on ingredient management
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Is this an appropriate weighting?
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Other key ‘environmental sustainability’ parameters missing (carbon footprint, resource management, etc.)
Reality…
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Ingredient campaigns hiding under the ‘sustainability’ umbrella
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Not at all about sustainability performance, rather largely about managing so called ‘toxics’ (the pressure group agenda)

10. © Copyright 2014 (all rights reserved)
The ‘Real’ Picture in Perspective
Slide 10
‘Sustainable Product Standard’
We took it for a TEST DRIVE

11. © Copyright 2014 (all rights reserved)
The ‘Real’ Picture in Perspective [cont.]
Slide 11
Product ‘A’
Aqua, sugars (fructose, glucose, sucrose), fibre, glutamic acid, aspartic acid, leucine, arginine, alanine, valine, glycine, proline, isoleucine, serine, threonine, phenylalanine, lysine, methionine, tyrosine, histidine, cystine, tryptophan, linoleic acid, linolenic acid, oleic acid, palmitic acid, stearic acid, palmitoleic acid, ash, phytosterols, oxalic acid, ascorbic acid, tocopherols, thiamin, anthocyanins, ethyl ethanoate, 2‐methyl butyraldehyde, pentanal, methylbutyrate, octene, hexanal, decanal, 3‐carene, limonene, styrene, nonane, ethyl‐3‐methylbutanoate, hydroxylinalool, linalool, terpinyl acetate, caryophyllene, alpha‐terpineol, alpha‐terpinene, 1,8‐cineole, citral, benzaldehyde, benzene‐1,4‐diol, methylparaben, ethanol, pectins, mannitol, and ‘fresh air’ (nitrogen, oxygen, carbon dioxide)

12. © Copyright 2014 (all rights reserved)
The ‘Real’ Picture in Perspective [cont.]
Slide 12
Product ‘A’
Aqua, sugars (fructose, glucose, sucrose), fibre, glutamic acid, aspartic acid, leucine, arginine, alanine, valine, glycine, proline, isoleucine, serine, threonine, phenylalanine, lysine, methionine, tyrosine, histidine, cystine, tryptophan, linoleic acid, linolenic acid, oleic acid, palmitic acid, stearic acid, palmitoleic acid, ash, phytosterols, oxalic acid, ascorbic acid, tocopherols, thiamin, anthocyanins, ethyl ethanoate, 2‐methyl butyraldehyde, pentanal, methylbutyrate, octene, hexanal, decanal, 3‐carene, limonene, styrene, nonane, ethyl‐3‐methylbutanoate, hydroxylinalool, linalool, terpinyl acetate, caryophyllene, alpha‐terpineol, alpha‐terpinene, 1,8‐cineole, citral, benzaldehyde, benzene‐1,4‐diol, methylparaben, ethanol, pectins, mannitol, and ‘fresh air’ (nitrogen, oxygen, carbon dioxide)
SCORE = 5 –10/100

13. © Copyright 2014 (all rights reserved)
The ‘Real’ Picture in Perspective [cont.]
Slide 13
Product ‘B’
Aqua, sodium, magnesium, potassium, acetaldehyde, acrylamide, benzaldehyde, benzene, benzofuran, benzo(a)pyrene, caffeic acid, chlorogenic acids, catechol, benzyl acetate, 1,2,5,6‐dibenanthracene, ethanol, ethylbenzene, formaldehyde, furan, furfural, hydrogen perioxide, benzene‐1,4‐diol, limonene, styrene, toluene, phenols, 4‐methylimidazole, quinic acid, cafestol, kahweol, n‐methylpyridinium, + many more (1,000+) substances

14. © Copyright 2014 (all rights reserved)
The ‘Real’ Picture in Perspective [cont.]
Slide 14
Product ‘B’
Aqua, sodium, magnesium, potassium, acetaldehyde, acrylamide, benzaldehyde, benzene, benzofuran, benzo(a)pyrene, caffeic acid, chlorogenic acids, catechol, benzyl acetate, 1,2,5,6‐dibenanthracene, ethanol, ethylbenzene, formaldehyde, furan, furfural, hydrogen perioxide, benzene‐1,4‐diol, limonene, styrene, toluene, phenols, 4‐methylimidazole, quinic acid, cafestol, kahweol, n‐methylpyridinium,+ many more (1,000+) substances
SCORE = 0 –25/100

15. © Copyright 2014 (all rights reserved)
The ‘Real’ Picture in Perspective [cont.]
Slide 15
SCORES = 0 –25/100
PRODUCT ‘A’
PRODUCT ‘B’
All ‘Natural’ Blueberries
Cup of Java

16. © Copyright 2014 (all rights reserved)
The ‘Real’ Picture in Perspective [cont.]
Slide 16
naphthalene
acenaphthylene
acenaphthene
fluoranthene
fluorene
pyrene
anthracene
benzo[a]anthracene
chrysene
benzo[b]fluoranthene
benzo[k]fluoranthene
benzo[a]pyrene
Dibenz(a,h)anthracene
Benzo[g,h,i]perylene
Indeno[1,2,3-c,d]pyrene
Polyaromatic Hydrocarbons (PAHs)
Household Generator

17. © Copyright 2014 (all rights reserved)
The ‘Real’ Picture in Perspective [cont.]
Slide 17
WHY ARE THEY LIMITED TO PERSONAL CARE? (singling out)
If such initiatives are truly about‘product sustainability’

18. © Copyright 2014 (all rights reserved)
Green Overboard–More ‘Real’ Perspective
Slide 18
‘GOING GREEN’= Natural
curare
tetrodotoxin
digitalis
SAFER???

19. © Copyright 2014 (all rights reserved)
The ‘Real’ Picture in Perspective [cont.]
Slide 19
Titanium Dioxide (TiO2)
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IARC 2B (possibly carcinogenic to humans)
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Proposition 65 List
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Mineral sunscreen ingredient
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Ingredient and transparency criteria (products developed with human health in mind)
BEGS THE QUESTION
HOW APPROPRIATE and/or PRACTICAL IS THE‘PRODUCT SUSTAINABILITY’ STANDARD?

20. © Copyright 2014 (all rights reserved)
Hazard vs. Risk
Slide 20

21. © Copyright 2014 (all rights reserved)
Science‐Based Regulatory Decision Making
Slide 21
Chemical Management in Canada
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Chemical Management Plan (CMP)
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Comprehensive assessment of existing substances in Canadian commerce
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Comprehensive program to manage the introduction of new substances to Canadian commerce
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Science‐and risk‐based approach
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Independent arbitrator(Environment/Health Canada)

22. © Copyright 2014 (all rights reserved)
Science‐Based Regulatory Decision Making [cont.]
Slide 22
Retailer ‘Product Sustainability’ Initiatives
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Undermines the science‐and risk‐based approach implemented by Government of Canada
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Undermines the credibility of one of the world‐leading chemical management programs
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Forced substitution strategies that do not necessarily lead to safer more ‘sustainable’ products
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Is this really what we want? Need?
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Is this really what the consumers want? Need?
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Segmentation (does it make sense to focus solely on personal care)?

23. © Copyright 2014 (all rights reserved)
Science‐Based Regulatory Decision Making [cont.]
Slide 23
Retailer ‘Product Sustainability’ Initiatives
RETAILERS
IMPACTon private label (house brands) ???

24. © Copyright 2014 (all rights reserved)
‘Product Sustainability’ –Moving Forward
Slide 24
OPPORTUNITY FOR ENGAGEMENT
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Industry does not object to sustainability initiatives
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In fact, sustainability and environmental and social responsibility are fundamental tenets of the CCTFA’s strategic plan
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Appropriately focused
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Designed to address more appropriate ‘sustainability’ endpoints
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Not centred around an unfounded/unsupported ‘toxics’ model that ultimately does not deliver ‘greener’ or ‘safer’ products
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How can we collaborate with retailers to deliver meaningful sustainability solutions that truly make an impact on society (while respecting science and the sound management of chemicals)?

25. © Copyright 2014 (all rights reserved)
Closing Thoughts
Slide 25
SILOXANES (D5) Board of Review
‘TOXIC TEN’
‘DIRTY DOZEN’
‘MEAN FIFTEEN’
Minister of Environment Adopts Conclusions
Independent Panel of International Renown Toxicologists
Siloxane D5 does not pose a danger to human health or the environment

26. © Copyright 2014 (all rights reserved)
Challenge Moving Forward
Slide 26

27. © Copyright 2014 (all rights reserved)
Thank You
Retailer ‘Product Sustainability’ Initiatives: A Discussion of Potential Implications for Consumer Product Regulation A Science Perspective
Beta Montemayor
Canadian Cosmetic, Toiletry and Fragrance Association (CCTFA)
bmontemayor@cctfa.ca
(905) 890‐5161 ext. 239
CHP Canada/CCTFA Health & Beauty Conference 2014(September 19, 2014)