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The Soap and Detergent Association

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					                     The Soap and Detergent Association

                                                                Ernie Rosenberg
                                                                President and Chief Executive Officer
            July 28, 2003                                       Direct: (202) 662-2505
                                                                E-mail: erosenberg@sdahq.org



            Mr. Steven A. Seeker
            President, U.S. National Committee of the IEC
            Cooper Power Systems
            P.O. Box 1640 (53197-1640)
            2300 Badger Drive
            Waukesha, WI 53188-5951

                    RE:     Proposed Modification to IEC 60335-2-5: Particular Requirements
                            for Dishwashers [61/2397/DC], International Electrotechnical
                            Commission Technical Committee No. 61: Safety of Household and
                            Similar Electrical Appliances

            Dear Mr. Seeker:

            The Soap and Detergent Association (SDA) recently became aware of the attached
            proposal being considered by the International Electrotechnical Commission (IEC) to
            amend its international standards to require that warnings about dishwashing detergents
            be included in the operating instructions for machine dishwashers. SDA urges the U.S.
            National Committee of the IEC to oppose the proposed modification.

            SDA is the non-profit trade association representing manufacturers of household,
            industrial and institutional cleaning products; their ingredients; and finished packaging.
            SDA members produce more than 90% of the cleaning products marketed in the U.S.

            The SDA urges the IEC not to adopt the proposed modification for a number of reasons,
            as follow:

                •   Characterizing dishwasher detergents as “extremely dangerous” is inconsistent
                    with the actual risks posed by these products. Such a classification should be
                    reserved for products that are exceptionally hazardous or poisonous. For
                    example, in the U.S., most machine dishwashing detergents carry the signal word
                    “Caution” on the label. Therefore, the text of the IEC proposal would present the
                    consumer with information inconsistent with current labeling appearing on these
                    products in the U.S., leading to consumer confusion.

                •   Instructions appearing in manuals for dishwashing appliances should be focused
                    on the safe and proper use of the appliance, not the use of the dishwashing
                    detergents. As with any product a consumer uses, the consumer should read the
                    product’s label for information on the hazards and risks associated with that
                    particular product and how to handle and use the product safely. More



1500 K Street, N.W., Suite 300, Washington, DC 20005 ● (202) 347-2900 ● Fax (202) 347-4110 ● www.cl eaning101.com
Mr. Steven A. Seeker
July 28, 2003
Page 2

       importantly, the consumer is more likely to read instructions and cautions on the
       product container rather than to refer to the machine’s manual.

       Even an effort as well intentioned as this proposal before IEC, has the potential to
       misdirect and misinform consumers. By far and away, the most important
       message to communicate to consumers is that they should always read the label of
       a product to use it efficiently and safely.

   •   The proposed warning pre-supposes what the proposed warnings would be
       applicable to dishwasher products around the world today and in the future.
       Dishwashing detergents are stringently regulated in many nations, where the
       criteria for determining the need for warnings statements and, in many cases, the
       actual warning statements themselves are specified. For example, the U.S.
       Consumer Product Safety Commission’s regulations address when warnings are
       to appear on a dishwashing product’s label and the warning statements. In
       addition, the formulation of cleaning products is a dynamic process.
       Formulations vary over time and from one product to another. Only label
       instructions and cautions can be assured of being applicable to a particular
       product.

   •   The proposal includes text that may be inconsistent with the United Nation’s
       Globally Harmonized System for Chemical Hazard Classification and Labeling,
       as applied to products in this category. While elements such as classification
       criteria, hazard symbols and statements, and signal words have been harmonized,
       efforts to harmonize precautionary statements in a manner that would be useful to
       users around the world are still underway. IEC should not adopt a proposal that
       could be inconsistent with this international harmonization effort and should defer
       to the UN committee that is developing harmonized systems.

   •   The language proposed is not consumer friendly. For example, most consumers
       around the world would not understand the implications of a detergent being
       “strongly alkaline.”

   •   Recommending that children be kept away from a dishwasher when the door is
       open and checking that the detergent receptacle is empty after completion of the
       wash cycle are general safe operating instructions and should not be presented as
       warnings related only to the detergents.

SDA would appreciate a thorough consideration of the concerns raised in these
comments. Further, we hope that in the future you can involve us directly in any
proposals related to the cleaning products used with appliances in order to improve the
Mr. Steven A. Seeker
July 28, 2003
Page 3


scientific foundation of IEC’s work. We would welcome any questions your organization has on
our products.

Finally, we would appreciate receiving a response to our comments or discussing them further
with you.

Sincerely,




Ernie Rosenberg

cc:    James Matthews III
       Frank Kitzantides
       Charles Zegers
       Joseph McGuire
       Richard Cripps