CARB Consumer Product Survey Limits On Trade Secrets Sought By CTFA
This article was originally published in The Rose Sheet
Executive Summary
The California Air Resources Board's 2001 consumer and commercial products survey should not request unnecessary quantitative or qualitative information on non-volatile ingredients or low vapor-pressure ingredients "that do not have a significant impact on emissions," the Cosmetic, Toiletry and Fragrance Association recommends in June 14 comments
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The California Air Resources Board's 2001 consumer and commercial products survey should not request unnecessary quantitative or qualitative information on non-volatile ingredients or low vapor-pressure ingredients "that do not have a significant impact on emissions," the Cosmetic, Toiletry and Fragrance Association recommends in June 14 comments. Such ingredients "should only be required to be revealed as a gross percentage content without further speciation," CTFA urges. Survey questionnaires are expected to be sent to manufacturers and distributors later this summer. Despite assurances from CARB that confidential information would be protected, the association takes issue with the "broad range" of product content information sought in a draft version of the survey. In addition to questioning the breadth of ingredient data sought, CTFA takes issue with requests for ingredient trade names. Respondents should only be required to disclose the chemical name of relevant ingredients and "not a trade name that identifies it with a particular supplier," the association maintains. Similarly, "the names of suppliers should not be required," CTFA states. Such information "is unlikely to be useful in any case since manufacturers often switch suppliers or obtain ingredients routinely from more than one supplier." Noting CARB staff is said to be considering including in the survey hair and nail products intended for use on animals, CTFA asserts: "these products for animals are entirely different than products intended for human use." To combine animal and human products in the same category "will confuse later analysis of the survey data, preventing any accurate assessment of the 2001 emissions or the reformulation possibilities for either category," the group maintains. The comments reiterate CTFA's objection to several categories included in the draft survey, such as rinse-off hair care products and OTC drugs. CARB staff discussed the categories at a May 30 teleconference with industry (1 (Also see "CARB Survey Of Hair Care Segment Aimed At Exploration Of Novel Formulas" - HBW Insight, 3 Jun, 2002.), p. 3). The staff plans a follow-up teleconference prior to release of the final survey. |