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 fore-stomach 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:
Acute Toxicity Study
Aquatic Toxicity Study
Dermal Irritation Study
Dermal Toxicity Study
EPA Delisting Of EGBE
Eye Irritation Study
Inhalation Toxicity Study
Microbial Study
Oral Toxicity Study
Sincerely,

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