Toward Greener Housekeeping

By Robert W. Powitz, Ph.D., MPH


“It’s not easy being green.
It seems you blend in with so many other ord’nary things.
And people tend to pass you over ‘cause you’re
not standing out like flashy sparkles in the water
or stars in the sky.”*
—Kermit the Frog

When it comes to cleaning and sanitation it seems that the food industry lives by two congruent standards: organic and everything else. Whereas both conventional and organic food companies recognize the potential risk of foodborne illness and the importance of prevention, organic production follows proscribed guidelines that incorporate approved processing aids published in from the U.S. Department of Agriculture (USDA) National Organic Program (NOP) National List. The National List limits the use of most synthetic cleaning chemicals and biocides that are regularly used by the food retail industry. The retail food industry is governed by reasonable practices detailed in the applicable U.S. Food and Drug Administration (FDA)/Public Health Service (PHS) Food Code. The Code focuses on the handling of food and the potential for cross-contamination in retail establishments. Sanitation is used as an important adjunct to proper handling and time-and-temperature controls to prevent food hazards arising from unhygienic personnel practices or environmental conditions in food preparation areas.

However, what is often scientifically correct may be philosphically and politically incorrect when applied to the food industry, or any industry for that matter. Since the appearance of organic foods at my local supermarkets and restaurants, I’ve seen a contradiction arising from the fact that retailers offer organic foods in an environment awash with caustic cleaners and Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)-registered economic poisons such as sanitizers and pesticides—even when used in proper concentration and applied correctly. Indeed, the very idea sometimes makes Kermit’s lament all too real: It’s not always easy being green.

Therefore, from a sanitarian’s perspective, I would like to offer an argument for green cleaning that should be embraced unequivacally by the retailers of organic foods. In fact, it should be a part of everyone’s quest for safety, wholesomeness and environmental stewardship.

Going Green in the Real World
How large is the cleaning chemical market? Kline & Co. estimated that for the year 2000, cleaning chemicals represented $7.6 billion in annual U.S. sales. Of this total, $2.8 billion is spent by food processing; with an additional $1.4 billion by the retail foodservice marketplace. This means that the food industry represents more than half of the total sales of cleaning chemicals in this country. Consider then the influence that we as producers, manufacturers and retailers of organic foods and the food safety professionals in this industry can have by using our sanitation knowledge and buying power and taking extra steps toward applying green cleaning practices and tools in organic food industry operations.

My quest toward the application of green cleaning in the food industry has been prompted by four primary concerns: employee health, public health, environmental stewardship and economics. The axiom that “ecology is uneconomic and economics is unecologic” no longer applies. I’ve heard all the excuses, which can be grouped into one sentence: Eco-friendly products do not work and are more expensive. Not so. Several major manufacturers of cleaning chemicals who are quite familiar to us already offer product lines at a competative cost that feature lower toxicity and significantly greater safety. Granted, those facilities that have made the shift to green cleaning also have had to make some modifications to their cleaning methodology, as well as an investment in education and retraining. However, many report that they have had substantially positive results with no economic loss or disruption to production; in fact, cleaning was as good, if not better than with the old products (as a result of retraining) and employee losses were significantly lowered.

To put a little different spin to this argument, consider the following. First, green cleaning is the right thing to do. Our federal government and many state and local governments have already endorsed a national concensus standard for environmentally friendly cleaning products and are including eco-friendly criteria for purchasing in their request for proposals (RFPs); so have several major hotel chains that depend entirely on the aesthetics of presentation. During my career as a sanitarian, I’ve noticed a decided shift in the public’s perception of environmental health, environmental protection and concern for the quality of life. From organic foods that are making inroads into retail food establishments, to smoke-free indoor environments to bottled water to wearing natural fiber clothes, consumer demand is significantly changing. Our job has certainly evolved along these societal demands. As this trend continues, I foresee any company that uses green cleaning as part of its marketing strategy, certainly can improve its marketshare appreciably.

We know that eco-friendly cleaning helps preserve employee health. Janitorial and cleaning crew complaints of nausea, headaches, eye troubles or skin troubles; often a result of long hours spent spraying and wiping chemicals or performing various housekeeping tasks, ranks quite high with other loss control concerns. To put this risk into perspective, the U.S. Department of Labor ranks hazardous cleaning chemicals among the top hazards of the janitorial industry. Six percent of custodians will be injured by the commercial cleaning products they use this year; 20% of these injuries are serious chemical burns to the eyes and skin. As part of our duties, we sanitarians are quite aware of this phenomenon and are often called upon to make recommendations for changes in cleaning protocols or suggest modifications to sanitation standard operating procedures (SSOPs) in order to minimize cleaning operation-related injuries. Reportedly, the average amount of time lost when a janitor suffers an injury from some form of contact with housekeeping chemicals is 18 hours. Each incident can cost the employer an upward average of $650, that does not necessarily include costs associated with productivity loss and litigation. By conservative estimate, going “green” can save the food industry about $15 million annually due to reduction in medical expenses and lost time wages.

From a regulatory perspective, using green cleaning products can also lower operating costs, because managers have fewer toxic chemicals to track and fewer chemical-related injuries to report. Parenthetically, eco-friendly cleaning products are also not as aggressive on the physical plant, particularly with regard to production equipment and interior finishes.

I strongly believe in the idea that the use of housekeeping products is to make something clean, not caustic, corrosive, contaminated and costly. I therefore see no conflict between the act of cleaning and preventing harm to people and to the environment. According to some estimates, more than one-third of the cleaning products used today to clean offices, hospitals, stores, restaurants and homes contain ingredients that can have a negative impact on public health and the environment. Some of the ingredients found in these products include carcinogens, endocrine disrupters which can alter human hormones, reproductive hazards, chemical sensitizers and allergens; and skin, eye and respiratory irritants or compounds that are toxic to sensitive aquatic and wildlife ecosystems. The average custodian uses conventional cleaning chemicals that contain 50 pounds of hazardous ingredients annually. Using environmentally preferable cleaning products can yield a 40% reduction in hazardous materials, equivalent to 20 pounds per year per custodian.

While the law allows dilution as the solution to pollution, consider the fact that millions of tons of cleaning products are washed down drains every month. For example, what gets washed down the drain in St. Cloud, Minnesota, will eventually wind up as someone’s dinner in New Orleans, Louisiana.

Similarly, Dr. Alice Ottoboni aptly named her plain-language guide to toxicology The Dose Makes the Poison, a must-read for everyone in the food business. She teaches that there is no such thing as a perfectly harmless (cleaning) compound. However, some are decidedly less toxic than others, so why not opt for the safest one? Looking at a broader picture, it almost becomes George Carlin-esque. Consider the following: We readily use chemicals to sanitize food contact surfaces and utensils that must be compliant with 21 CFR 178.1010; this includes registering these chemicals with the U.S. Environmental Protection Agency (EPA) under FIFRA. For all intents and purposes, all sanitizers are lumped in the same class as an economic poison. No argument there: Sanitizers are rightfully regulated in this manner.

However, it is also interesting to note that in disposing of these same chemicals (as well as myriad cleaning compounds used by our industry), they have to be listed as a hazardous waste because they do not meet the non-hazard criteria as defined in 40 CFR Part 261. This means that disposal can actually cost considerably more than purchasing the product in the first place. Why? Because of the potential risk of damage it can do to humans and the environment if improperly handled. What a dichotomy: good to use, bad to dispose! But from a business perspective, this is something to be seriously considered in any cost-benefit analysis.

How to Be Green-er
Currently there are no formal universally-accepted or consensus-based green cleaning standards and this has caused concern among end users, government regulatory agencies and manufacturers alike. Federal agencies are facing renewed pressure to adopt so called “green” cleaning practices and purchase environmentally safe cleaning products. But until this is completed, there are some basic purchasing guidelines to begin the relearning process.

A few years ago, the EPA developed the Environmentally Preferred Purchasing (EPP) program. By Executive Order 13101, the purpose was to guide the purchase of “...products or services that have a lesser or reduced effect on human health and the environment when compared with competing products or services that serve the same purpose....” The aim was to help purchasers compare the environmental attributes of cleaning products and select those that are environmentally preferable. As a result of this initiative, the U.S. General Services Administration (GSA) developed an extensive catalog that lists many products under the category “Cleaning Equipment, Accessories, Janitorial Supplies, Cleaning Chemicals and Sorbents.”

Even if the GSA catalog is not used to make purchasing decisions, specifications can be modified to include the EPA’s EPP criteria to ensure that the safest and most environmentally preferable housekeeping products are used at your facility. This would still allow locally produced chemicals from small businesses and bidding by local vendors. The criteria that should be added to the bid specifications include the following:

Biodegradability. All products should comply with the Organization for Economic Cooperation and Development’s definition of ready biodegradability. That is, 60% to 70% biodegradable within 28 days, for each organic component above 1% in the ready-to-use product.

Nonhazardous Waste. No product should constitute a hazard-ous waste, as defined in 40 CFR Part 261, when disposed of.

Toxicity. All products must show evidence of low toxicity by demonstrating that the oral lethal dose toxicity (LD50) (rat) is greater than 50 milligrams per kilogram; the inhalation lethal concentration (LC50) (rat) is greater than 2 milligrams per liter; and that the dermal toxicity (LD50) (rabbit) is greater than 200 milligrams per kilogram.

Environmental Hazard. No product should contain phenolic compounds, petroleum solvents or heavy metals.

In addition to these criteria, the GSA selected six environmental attributes that are good to consider. While none of these is considered more important than another, it encourages the selection of the most relevant attribute(s) that meet your facility’s needs and balance the available environmental information, along with traditional factors such as price and performance. The following is a brief description of these six “green” attributes:

1. Skin Irritation. Some ready-to-use cleaning products may contain chemicals that can cause skin redness or swelling. If potential skin irritation is a concern, products rated as negligible (none to slight) would be most preferable. If all chemical compounds in the ready-to-use product are less than 5% by weight, there is no inherent risk of skin irritation.

2. Air Pollution Potential. Products may contain volatile organic compounds (VOCs). When these products are used, the VOCs may escape to the indoor environment and cause irritation of the eyes, nose, throat and lungs and to cause asthma attacks. The labels listing the contents and Material Safety Data Sheets (MSDSs) of the ready-to-use products refer to VOCs as the percent by weight. Ideally, ready-to-use products should contain no VOCs. However, if VOCs are present, the lower the number, the more preferable the product.

3. Fragrances. This attribute does not refer to natural odors that are associated with cleaning agents such as a lemon odor in a citrus-based cleaner. It refers instead to fragrances that are added to the formulation to improve its odor or to mask offensive odors. While fragrances added to a formulation have little cleaning value, they may provide important aesthetic benefits. Bear in mind that proper cleaning will generally remove the source of most odors, thereby making fragrance additives unnecessary.

4. Dyes. This attribute refers to dyes that have been added to a formulation to enhance or change the color of the product. While the addition of dyes contributes little to the cleaning value of the product, it may be important for safety reasons. These additives may help end-users differentiate between products and other liquids, such as water. Again, a basic principle of pollution prevention is to avoid unnecessary additives. Dyes present for aesthetic reasons only may not be providing a necessary function.

5. Packaging (Reduced/Recovered Content). A product’s packaging can account for a significant portion of the product’s contribution to municipal solid waste. The EPA’s recommended approach to managing solid waste is to reduce packaging of products and to recycle packaging materials. Both attributes should be considered in purchasing any product including housekeeping chemicals.

6. Product Includes Features to Minimize Exposure to Concentrate. Although packaging a product in concentrated form may result in reduced packaging, it raises the potential that the end-users of the product will be exposed to the concentrate. Exposure to the concentrate may place the end-user at greater health risk than exposure to the ready-to-use product. Therefore, the safest approach is to select chemicals in which the concentrate is part of a system by which chemicals are transferred only among closed containers. This offers less exposure potential. If this is not possible, choose products where the concentrate is premeasured and prepackaged but not designed to be transferred among closed containers.

Because the information on these attributes is intended only for the purpose of relative comparison, it does not substitute for other guidance on safe product usage. The information on environmental attributes should help you decide which products to buy; it does not provide guidance on how to use the products. You should continue to carefully follow on MSDSs, labels and other product-specific information to ensure safe usage.

Ultimately, by using your existing knowledge of the cleaning requirements of your food operation, working with your cleaning chemical suppliers and educating yourself by reading pertinent guidelines and information such as that offered by the GSA, you can influence vendors and users of organic foods, and even modify your own operation to leap-frog over Kermit and find it very easy—and beneficial—to be green.

Forensic sanitarian Robert W. Powitz, Ph.D., MPH, RS, CFSP, is principal consultant and technical director of Old Saybrook, CT-based R.W. Powitz & Associates, a professional corporation of forensic sanitarians who specialize in environmental and public health litigation support services to law firms, insurance companies, governmental agencies and industry. Among his honors, Powitz was the recipient of the NSF/NEHA Walter F. Snyder Award for achievement in attaining environmental quality, and the AAS Davis Calvin Wagner Award for excellence as a sanitarian and advancing public health practice. He is the first to hold the title of Diplomate Laureate in the American Academy of Sanitarians. He can be reached at sanitarian@juno.com.

*From The Sesame Street Book and Record. “Green is” ©1970 Jonico Music, Inc. Lyrics by Joe Rapposo.