About EWG’s Guide to Healthy Cleaning

Environmental Working Group’s mission is to use the power of information to protect human health and the environment. EWG’s Guide to Healthy Cleaning gives you practical solutions to protect yourself and your family from everyday exposures to potentially harmful chemicals. U.S. law allows manufacturers of cleaning products to use almost any ingredient they wish, including known carcinogens and substances that can harm fetal and infant development. And the government doesn’t review the safety of products before they’re sold. To fill those gaps, EWG’s staff scientists compared the ingredients listed on cleaning product labels, websites and worker safety documents with the information available in the top government, industry and academic toxicity databases and the scientific literature on health and environmental problems tied to cleaning products. They used that information to create EWG’s Guide to Healthy Cleaning, which provides you with easy-to-navigate hazard ratings for a wide range of cleaners and ingredients.

Quick Facts on EWG’s Guide to Healthy Cleaning

EWG’s Guide to Healthy Cleaning contains information and hazard assessments for 2,109 products, 197 brands and more than 1,000 ingredients.

Finding Ingredient Information Isn’t Easy

For consumers, the easiest way to find out what’s in their cleaning products is to check the labels. But what happens when the label information consists only of directions, warning messages and, at best, just a few ingredients, vaguely described?

When EWG set out to assess more than 2,000 cleaning products, its researchers discovered that it took hard work to find out what potentially toxic chemicals were in them. Unlike manufacturers of cosmetics and personal care products, companies that make cleaning products are not required to list the ingredients they put in their formulations on the package, bottle or box. This lack of disclosure can make it almost impossible for consumers to find the healthiest products.

EWG’s research team took multiple steps to get the most up-to-date and accurate ingredient information, which typically required scouring more than one source. And for the majority of the products in EWG’s Guide to Healthy Cleaning, there was no way to get a complete list of every ingredient. The industry says that’s because the details of its formulations are proprietary trade secrets, and it insists that the products are safe based on testing data that is not available to the public.

Here are the sources we used to compile the ingredient information in EWG’s Guide to Healthy Cleaning:

Labels. EWG examined more than 1,000 package labels and found that the ingredient information for 48 percent listed three or fewer ingredients on the label.

EWG examined more than 1,000 package labels and found that the ingredient information for 48 percent listed three or fewer ingredients on the label. Product websites and ingredient disclosure documents. Most manufacturers provide some ingredient information on their official websites. EWG visited almost 200 brand websites to supplement the sparse package label data. Some online ingredient lists appeared to be specific and complete, but others provided a minimum of often-vague information, such as identifying only broad chemical classes (eg. “alcohol ethoxylates”) or functional classes (eg. “preservatives”). The degree of complete and specific identification of ingredients varied from company to company and product to product.

Most manufacturers provide some ingredient information on their official websites. EWG visited almost 200 brand websites to supplement the sparse package label data. Some online ingredient lists appeared to be specific and complete, but others provided a minimum of often-vague information, such as identifying only broad chemical classes (eg. “alcohol ethoxylates”) or functional classes (eg. “preservatives”). The degree of complete and specific identification of ingredients varied from company to company and product to product. Material Safety Data Sheets. The federal Occupational Safety and Health Administration requires companies to furnish Material Safety Data Sheets to alert their workers to potentially harmful substances in the workplace. Since cleaners are widely used by custodial staffs, OSHA also requires that cleaning products sold for professional use be accompanied by MSDSs. Many manufacturers post these documents on their websites, too, though in some cases EWG contacted companies to get copies. These documents are not provided to consumers, even when they buy products identical to those used by custodial staff.



Although hazardous ingredients are usually listed in a specific ingredients section on an MSDS sheet, they sometimes appear in a section titled “Regulatory Information” at the end of the document because of state regulations that apply to some specific chemicals and ingredients, typically byproducts or contaminants. In some cases, EWG found harmful chemicals listed in these sections that did not appear anywhere else.

Cleaning Product and Ingredient Data Sources

Below we describe the information sources and the methodology we use to construct EWG’s Guide to Healthy Cleaning’s linked datasets of ingredients, products, brands and companies.

The core of EWG’s Guide to Healthy Cleaning is an interactive product database that contains ingredients in more than 2,000 products. EWG obtained detailed information on these products from manufacturers’ websites, online retailers and product packaging. Information was first amassed in the winter of 2011-2012 and is updated regularly. Visits to stores during the summer of 2012 provided additional information on the labels associated with some new product formulations now available to consumers. In most cases the information includes a brand name, product name, directions for use, warnings, ingredients and package/advertising text.

EWG staff carefully evaluated every product in EWG’s Guide to Healthy Cleaning to identify the product type, its composition and use instructions (including precautions to protect skin and eyes) and product marketing claims.

EWG categorized each product into one or more of 70+ product categories (e.g., all-purpose cleaner, oxygen bleach, dish detergent). For ease of navigation, these product categories were organized into nine major groups.

EWG identified how each product is typically used. Many hazard recommendations associated with chemicals depend on a product’s use and/or composition. For instance, chemicals that are hazardous when inhaled are problematic in products that are sprayed. For each product, EWG recorded:

Directions for use, including whether the product is meant to be diluted, left on surfaces, wiped off or rinsed off.

Manufacturer’s warnings concerning accidental exposure, such as recommendations to wear gloves or goggles or avoid eye contact.

The form of the product: solid, liquid, liquid spray, aerosol, wipe etc.

Information indicating potential for toxicity, such as pH and levels of volatile organic compounds (VOCs) released during use.

EWG’s Guide to Healthy Cleaning currently features products sold under 197 brand names manufactured by dozens of companies, including brand and company relationships identified primarily through online research.

Because many consumers care about animal testing, EWG’s Guide to Healthy Cleaning also provides the manufacturer’s position on animal testing as obtained from listings assembled by People for the Ethical Treatment of Animals’ (PETA) and Leaping Bunny. We periodically update our database to reflect these organizations' most current listings.

EWG’s Guide to Healthy Cleaning currently contains information on more than 1,000 ingredients used in cleaning products, culled from labels, manufacturer websites, worker safety documents and from the scientific and industry literature. We assigned a standardized name to each ingredient, often using the International Nomenclature for Cosmetic Ingredients (INCI) standard, with some exceptions where alternate names are more easily recognized by consumers or widely used by industry. Each ingredient name is associated with a unique ingredient identification number in the database.

EWG parsed (electronically separated) individual ingredients from the ingredient lists on company websites and on product labels where available. The parsing tools we designed do not yet take into account every variation in labeling and likely will never be able to account for the wide range of errors in spacing and delimiting on ingredient labels. Because of these factors, EWG staff members carefully reviewed parsed ingredient lists and manually corrected ingredients that were not accurately separated, routinely updating the parsing program to improve accuracy prior to a manual review.

Some company websites make freely available worker safety documents called Material Safety Data Sheets (MSDSs). The Occupational Safety and Health Administration (OSHA) requires companies to provide these sheets to workers who may be exposed to hazardous chemicals on the job. MSDSs may contain ingredient information not found elsewhere, including the Chemical Abstract Service (CAS) identification numbers for certain ingredients and a range of their relative percentages in products. EWG manually extracted information on products and ingredients from each MSDS; to avoid errors in manual data entry, two EWG staff extracted information from each MSDS, and a third staff member re-examined and corrected double-entered data that did not match. Product names on MSDSs often do not correspond perfectly with the names on labels, requiring additional review to match each document with the correct product.

Each ingredient was assigned a unique name and identification number in the ingredient database in a multi-step process that involved resolving chemical synonyms and names that were misspelled or did not follow standard industry naming conventions:

When ingredient names on product labels or company entries exactly matched the spelling of one of our core database ingredients or its synonyms, we assigned that ingredient the existing chemical name and identification number from our ingredient database.

When ingredient names did not exactly match an existing ingredient name, we determined whether the new name was a misspelling of an ingredient in our core database. We processed the new ingredient with a program that identifies possible name matches, first through a match of Chemical Abstract Service (CAS) identification numbers when available, and then through a custom, chemical-name spell checker. Finally, through a manual review of these tentative matches, we either matched the new ingredient with one already in our database or we determined that it was a new, unique ingredient and assigned it a new ingredient identification number.

EWG stored information where available on the function of each ingredient – for instance, whether it is used as a surfactant or a preservative. EWG also recorded information from labels about ingredients that a product does not contain.

Many manufacturers choose to describe the ingredients in their products only by their broad chemical class, such as “alcohol ethoxylate,” or by their functional class, such as “preservative,” rather than identifying specific chemical ingredients. EWG staff constructed “substance groups” that correspond to the major chemical or functional classes found in cleaning supplies. Individual ingredients were assigned to groups based on extensive review of government and industry documents.

Toxicity Datasets

EWG created a core, integrated database of health and environmental assessments for chemicals and chemical classes by pooling data from 15 databases and sources created by government agencies, industry panels, academic institutions or other credible bodies. EWG used these datasets to assess potential health and environmental hazards for cleaning product ingredients and evaluated how the toxicity information in these datasets should be applied. The toxicity data sources used were:

European Union’s (EU) Globally Harmonized System of Classification and Labelling of Chemicals hazard and toxicity classifications.

Association of Occupational and Environmental Clinic’s Exposure Code List for asthma-causing substances.

California’s Proposition 65 list of chemicals known to the state to cause cancer or reproductive or developmental toxicity

International Agency for Research on Cancer Monographs on the Evaluation of Carcinogenic Risks to Humans

European Union’s Cosmetics Directive list of allergens

National Toxicology Program’s 12th Report on Carcinogens

European Commission’s priority list of endocrine-disrupting chemicals

US Environmental Protection Agency’s (EPA) Integrated Risk Information System (IRIS) classification of carcinogens

The National Institute for Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards

American Conference of Governmental Industrial Hygienists’ (ACGIH) Threshold Limit Value (TLV) Basis

EPA’s High Production Volume (HPV) risk- and hazard-based prioritizations

EU’s Ecolabel Detergents Ingredients Database

EPA’s Fathead Minnow Acute Toxicity Database

U.S. Food and Drug Administration’s (FDA) Priority-based Assessment of Food Additive (PAFA) database

Compilation of botanical composition information

For many substances in EWG’s Guide to Healthy Cleaning, we supplemented information from these datasets with additional toxicity information collected from credible scientific sources and peer-reviewed research. EWG scientists reviewed each piece of manually entered information and determined how it could be applied to the appropriate substance. Finally, EWG staff constructed a dataset describing U.S. and foreign regulations as to the presence or concentration of specific chemicals of concern in cleaning products.

EWG staff cross-linked the chemicals in our ingredient database with the compounds in the toxicity datasets we compiled. These pairs form the basis for the ratings shown in EWG’s Guide to Healthy Cleaning.

For an initial estimate of the chemical pairings between these two groups of databases, we linked chemicals when names matched perfectly between data sources: when Chemical Abstract Service (CAS) numbers matched; when they were available from our in-house CAS database; or when strings of letters matched between ingredients. We then did manual reviews for many pairings to assess the validity of the match between an ingredient and a health or environmental assessment, storing data on hazards that apply only to a particular route of exposure, for instance, for use in the scoring. Where appropriate, toxicity assessments were linked to chemical groups, allowing the assessments to be extended to each member of the group.

Product and Ingredient Ratings

Using the extensive data collected and organized on product attributes, ingredients and toxicity, EWG created a scoring system to give consumers the best information available to make informed, healthy choices. The system analyzes toxicity and hazard information relevant to human health and the environment and gives cleaners a letter grade corresponding to how well or poorly they rate. First, available information on the toxicity or hazards of substances in cleaning products was collected and organized. In this process, EWG considered the credibility of the data source, the comprehensiveness of the information and the severity of the health and environmental effects associated with the substances under evaluation. This information was combined using EWG-developed scoring algorithms to produce a hazard score for each ingredient in the database. Finally, the scores for each substance in a product were combined to give an overall ingredient hazard score for that cleaner.

A final score for a product was then calculated. First, the overall ingredient hazard score was combined with a “disclosure” score. Disclosure is the amount of information the manufacturer provides to consumers about the ingredients in a product. A poor disclosure score indicates that the company provides little to no information on what substances are in a product; a good score indicates that the company provides more complete and specific information. EWG scientists developed specific criteria and algorithms to generate the disclosure score. After the ingredient hazard and disclosure scores were combined, additional modifications were sometimes made to the score based on specific criteria. For example, a product with a very low or high pH (and therefore corrosive), or that violated a regulation, received additional demerits.

The final product score for a cleaner was then translated into a letter grade. A letter grade of “A” indicates very low hazard to health and the environment with robust disclosure of ingredients, while a grade of “F” signifies that the product is highly hazardous or provides little to no ingredient disclosure. A “C” score indicates an average cleaner that poses no overt hazards and provides some disclosure of ingredients. A complete technical description of the structure, definitions, and algorithms used by the EWG scoring system follows.

About EWG Verified

Consumers Want To Know What They’re Buying. Consumer demand is driving manufacturers to make home cleaning products safer. And so manufacturers in turn are increasingly being transparent about what ingredients they’re using in their products. A cleaning product with the EWG VERIFIED™ mark means it has met the highest standards created in the interest of public health.

At EWG, we believe all cleaning products should:

Be free of EWG’s ingredients of concern that harm health and the environment.

Disclose their ingredients to consumers.

Meet stringent air quality standards.

Cleaning should mean clean – not polluting your home with toxic chemicals. The EWG VERIFIED™ mark Avoids EWG's ingredients of concern Products cannot contain any ingredients on EWG's "Unacceptable" list, meaning ingredients with health, ecotoxicity and/or contamination concern. Provides full transparency Must meet EWG’s standards for ingredient disclosure on the label, provide full transparency to EWG, including fragrance ingredients. Uses good manufacturing practices Product manufacturers must develop and follow current good manufacturing practices to further ensure the safety of their products. EWG VERIFIED™ goes beyond labels, driving companies toward full transparency. The EWG VERIFIED: For Your Health™ mark means the product goes above and beyond its green rating from EWG, disclosing more about its formulations and manufacturing processes, and ingredients that are seldom listed on product labels. Scoring Definitions and Structure Finding – A conclusion associated with a peer-reviewed study, agency-determined categorization or data point contained in a data set. Example 1 – Dataset: EPA cancer determinations for chemicals. Finding: EPA determination for benzene = A1; known human carcinogen. Example 2 – Peer-reviewed study. Finding: Doe et al. found that boric acid is an endocrine-disrupting compound. Endpoint – An effect or specific parameter associated with a finding. Endpoints include asthma, reproductive toxicity and chronic aquatic toxicity. EWG assigns an endpoint to each finding. EWG calculates separate hazard scores for each endpoint. Endpoint group – EWG assigns each endpoint to one or more endpoint groups organized by biological system (health) or an ecological aspect (environment). An example of an endpoint group would be “cancer,” which is a collection of the endpoints for specific types of cancer (e.g. colon cancer, breast cancer, lung cancer). Likewise, the endpoint group “dermal toxicity/disease” would include endpoints such as “skin irritation,” “skin corrosion,” “dermatitis,” etc. After EWG calculates separate scores for each endpoint we then calculate a single, consolidated score for the endpoint group. Scoring subcategories – EWG assigns each endpoint group to one scoring subcategory. An example is the “hazard” subcategory, which includes the endpoint groups of various health hazards (e.g. cancer, endocrine disruption, respiratory toxicity). The subcategory “risk-based values” includes numeric values for acute toxicity parameters, such as LD50 (the lethal dose effective for 50 percent of the test population). Scoring category – EWG assigns each endpoint group, separated by scoring subcategory, to a broad scoring category, either health or environment. EWG calculates an overall substance score as a function of each relevant scoring category. EWG assigns weights to scoring categories to set their relative contribution to the overall score of a substance or product. Example of a tiered structure for scoring categories, subcategories, endpoint groups, and endpoints: Health (scoring category) Hazard (scoring subcategory) Developmental, endocrine and reproductive toxicity (endpoint group) Damage to fertility (endpoint)

Scoring a Substance Step 1: Information collection

Scientific datasets, peer-reviewed literature and other information sources are collected and reviewed to identify specific findings relevant to health and the environment that are applicable to substances in the database. Findings include determinations that a substance causes or may cause specific diseases such as breast cancer or asthma, which are considered endpoints. A finding may also indicate that a substance does not pose a risk to human health or the environment. Step 2: Assessing the data and assigning numeric values

Each finding is assigned to an endpoint that dictates what question is being evaluated, i.e. does this substance cause asthma? EWG then evaluates what each finding says about the safety or hazardousness of a substance and assigns it appropriate scoring values. The values depend on:

Strength of association – A numeric value assigned to each finding that reflects how strongly that finding is associated with a particular endpoint, such as asthma. The strength of association values and their corresponding definitions are listed below. Strength of association Definition -10 No association, confirmed -5 Limited evidence of no association 0 Unknown (no data or conflicting data) 5 Limited evidence of an association 8 Likely/probable association 10 Confirmed association Example: The US Environmental Protection Agency finds that benzene is a known human carcinogen. EWG assigns this finding a strength of association of 10 = Confirmed association. Scope of assessment – A categorization determined by the credibility and comprehensiveness of the data. A finding or determination from a comprehensive agency assessment, such as a National Toxicology Program (NTP) report on carcinogenicity, will be given a higher value than a finding generated from a single peer-reviewed study. EWG assigns a “scope tier” to each finding as defined in the table below. Scope of dataset or study Nature of data considered or generated in the dataset or study Who evaluated or generated the data (authors)? Form of documentation Examples Scope tier 6 Absolute, comprehensive weight-of-the-evidence assessment based on data sufficient for complete understanding and certainty or scientific fact. Finding from a completely authoritative scientific body or known as fact. Full, publicly available documentation of data collection, methods, and conclusions. Oxygen is a gas at standard temperature and pressure. Scope tier 5 Comprehensive, weight-of-the-evidence evaluation of available scientific information. Data is relevant to a broad issue. Authoritative government agency or permanent, non-governmental body with accepted, comparable authoritative standing. Full, publicly available documentation of data collection, methods, and conclusions. Findings may be based on specific criteria. IARC1 Monographs on the Evaluation of Carcinogenic Risks to Humans, the UNECE2 Globally Harmonized System of Classification and Labelling of Chemicals. Scope tier 4 Weight-of-the-evidence evaluation of available scientific information. May be limited to evaluation of data relevant to one aspect of a broader issue. Authoritative body of experts, including standing and ad-hoc government and industry advisory panels Full, publicly available documentation of data, methods, and conclusions. Findings may be based on specific criteria. An EPA3 committee report on endocrine disrupting chemicals. A JECFA4 toxicological evaluation of a food additive. Scope tier 3 Weight-of-the-evidence evaluation of available scientific information on a limited subject. Qualified expert(s). Independently evaluated and published in a peer-reviewed journal. Findings may be based on specific criteria. A review article on neurotoxic compounds that evaluates a significant body of information from a variety of data sources. A CIR5 panel final report on a class of fragrance chemicals. Scope tier 2 Evaluation of credible scientific data on a limited or single subject. Qualified expert(s). Independently evaluated and published in a peer-reviewed journal, or authored by a credible source. A published scientific study on the reproductive toxicity of a particular substance. Scope tier 1 A finding generated from screening-level testing or a method less rigorous than alternate tests that more closely approximate real-world conditions. Qualified expert(s). Findings reported by a credible source, such as a government agency. Screening-level studies including in-vitro testing and reports of a single data point. 1 International Agency for Research on Cancer

2 United Nations Economic Commission for Europe

3 US Environmental Protection Agency

4 Joint FAO/WHO Expert Committee on Food Additives

5 Cosmetic Ingredient Review Example: The US Environmental Protection Agency finding that benzene is a known human carcinogen was determined by a rigorous, comprehensive review of all available data on all routes of exposure, and makes their review process publically available. EWG assigns this finding to scope tier 5. Severity – EWG assigns a numeric weight called severity to each endpoint, which is intended to reflect the relative impact of each endpoint on health, the environment and other factors considered in EWG’s ratings. Severity values are scaled in high, moderate and low categories according to their relative effects. Low values typically indicate safer, more desirable attributes. High – Includes endpoints associated with: Systemic diseases that can be significantly debilitating or fatal, including cancer and asthma. Conditions that can cause multi-generational impacts, including endocrine disruption, developmental effects, and reproductive problems. Permanent damage to the skin, such as that caused by caustic substances. Classification of high acute or chronic toxicity based on a numeric value, such as a very low No Observable Effect Level (NOEL).

Moderate – Includes endpoints associated with: Significant but reversible physical discomfort, including respiratory or skin irritation. Dermal and respiratory allergies. Classification of moderate acute or chronic toxicity based on a numeric value, such as a mid-range NOEL.

Low – Includes endpoints associated with: Little to no potential for ecological toxicity, such as ready biodegradability. Little to no potential for adverse effects to human health, such as an EPA Group E designation (evidence of non-carcinogenicity for humans). Classification of low acute or chronic toxicity based on a numeric value, such as a high NOEL.

Uncertainty (u) – A value that EWG assigns to each finding, from among the categories below, that reflects the extent of uncertainty encompassed by a particular finding. EWG uses this parameter to reflect cases in which uncertainty is greater than what is typical for data within a given tier. Uncertainty may reflect data collection gaps and method limitations. The assigned uncertainty values (u) are defined below: Default – typical or unassessed certainty: u = 1.0

Limited uncertainty – exceeding typical: u = 0.5

No data: u = 0 Example: Uncertainty. A review paper reports that a substance is not associated with reproductive toxicity and provides limited data to support that claim. Several independent, peer-reviewed studies that show the substance is associated with reproductive toxicity are not mentioned in the review. The finding that the substance is not a reproductive toxicant may be therefore assigned a Limited uncertainty value of 0.5. Route r(route) – An attribute that EWG assigns to each finding relevant to the route of exposure. The likelihood of exposure to substance in a household cleaning product depends on the product type and form. This attribute is only utilized when performing calculations at the product level. This factor is intended to down-weight exposures that are unanticipated with consumer use. Score modification based on product route is relevant to the following scenarios: Example: Exposure route. For aerosol products, the likelihood of exposure through inhalation is greater than the likelihood of exposure through ingestion. Therefore endpoints specific to inhalation will drive the hazard score for that product. The assigned route values r(route) are defined as: Default: Relevant route of exposure: r(route) = 1.0

Unlikely route of exposure: r(route) = 0.5

No anticipated exposure: r(route) = 0 Misuse m(misuse) – An attribute that EWG assigns to each finding from among the categories below, indicating that the hazard is relevant only in cases of misuse. This attribute is only utilized when doing calculations at the product level. EWG uses this parameter to down-weight hazard information that would be applicable only in unlikely or unanticipated use scenarios, including accidental ingestion or intentional inhalation. Score modification based on product misuse is relevant to the following scenario: Example: Type of misuse. Some health effects would only occur if the product were intentionally misused, such as coma or death resulting from inhaling a propellant. This can be accounted for by using the misuse modification. The assigned misuse values m(misuse) are defined as: Default: Proper usage: m(misuse) = 1.0

Accidental misuse: m(misuse) = 0.5

Intentional misuse (exposure would only occur if the product were purposefully misused): m(misuse) = 0

Calculating a score for a single endpoint. EWG combines the findings from multiple datasets and makes a determination about the overall strength of association, positive or negative, between a substance and a particular health or environmental endpoint. This determination is based on:

The weight of the evidence. The overall strength of association between a hazard and a substance will be driven by the amount of evidence that supports that association. Resolving conflicting data. If there are conflicting findings, for example if one agency determines that a substance is a known endocrine disruptor and another finds it does not have enough data to make a determination, EWG will take a precautionary position and assign a value that reflects some association of hazard.

Algorithms for consolidating findings for a single endpoint. The numerical score for a single endpoint for a single substance in the database must account for many findings that vary in their strength of association, scope of assessment, and uncertainty. The goal is to determine an overall strength of association for a given endpoint, considering all findings for that endpoint. The result will be an aggregate strength of association value ranging between -10 and +10. A +10 score indicates that a substance is definitively associated with an endpoint (such as a substance known to be a carcinogen), while a -10 score indicates that a substance is definitively not associated with an endpoint (such as a substance that is known to be non-carcinogenic).

Step 3: Consolidating findings at each scope of assessment tier

EWG calculates a separate score for each scope of assessment tier. Each tier score incorporates all findings that fall within that tier. The tier score represents a weighted average of the strength of association for the findings at a given tier.

Equation 1

where

where SA = strength of association, u = uncertainty for each finding, severity = severity score, and w is a weighting factor that resolves cases conflicting findings, with some showing an association between a substance and an endpoint and others not. In these cases, the weighting factor serves to emphasize the findings that show an association, reflecting the precautionary principle. The weighting function increases linearly with increased strength of association.

Step 4: Consolidating scope of assessment tier scores into an endpoint score

EWG consolidates tier scores into a single endpoint score using a tier weight and based on the number of studies in each tier. It ranges from -10 to +10.

Equation 2

where TS is the tier score, TW is the tier weight, and Max(TW) is the maximum calculated tier weight, across all tiers, as described in equation 5 below. The sums are performed over all scope of assessment tiers (0 to 6).

Calculating the tier weight is accomplished using the following equation:

Equation 3

where (see table below for values associated with these variables):

TW max is the maximum possible weight for a tier

TW min is the minimum possible weight for a tier

?TW = TW max - TW min

n90 is the number of studies required to reach TW min + 90%(?TW)

nfindings max is the maximum number of findings on a tier that fall at the same strength of association

Scope of assessment tier TW min TW max n90 6 10 10 1 5 9 9.9 2 4 6 9.5 3 3 4 7.5 5 2 2 4.0 10 1 0.5 1.0 15

When multiple findings on a tier come to similar conclusions as represented by the strength of association, those findings taken together have an increased tier weight (TWmax). This reflects the idea that there is a higher level of consensus on the question of how strongly a substance is associated with an endpoint.

Step 5: Calculating the consolidated scores for endpoint groups and categories

Currently we have identified three methods to consolidate hazard scores at different stages in substance scoring (endpoint group or category scoring), which may also be applied when calculating substance group or product scores.

Method 1: Maximum score

The consolidated score is taken as the highest single score from all endpoints, groups, or subcategories.

Equation 4

where S is the score for each endpoint, group, or category being consolidated.

Method 2: Weight of evidence score

The consolidated score is a combination of all severity scores with a weighting factor that emphasizes the findings that show an association, reflecting the practice of precaution when data conflict.

Equation 5

where S is the score from each endpoint, group, or category being consolidated; S neg are scores < 0; S max is the maximum score; the sum of logs are limited to scores > 1; and wea is a weight of evidence adjustment given by:

Equation 6

where rank is an ordered list of scores ranged 0-10 ranked from highest (10) to lowest (0).

Method 3: Weighted average score

The consolidated score is the weighted average of the elements being collected. In this method, each sub-element must be assigned a weighting factor between 0 and 1.

Equation 7

where S is the score from the sub-element and weight is assigned for each sub-element.

Determining the endpoint group score. Each “endpoint group score” is calculated from all the endpoints within that group by using Method 2: Weight of evidence score.

Determining the category score. Different endpoints associated with the substance are combined to determine an overall category score for either “health” or “environment.” EWG assigns a category score to a substance based on the number of health or environmental endpoints (and their associated hazard). For example, a substance that shows very weak evidence of hazard to human health would receive a fair health category score, while a substance that is a probable carcinogen, a known endocrine disruptor and causes asthma would receive a bad health category score value.

The “health” or “environment” category scores are also calculated using Method 2: Weight of evidence score, where all of the endpoints for that category are combined to yield an overall category score.

Step 6: Combining “health” and “environment” category scores to determine a substance or substance group hazard score

After the health and environment category scores are calculated, they are combined to generate an ingredient’s hazard score.

Equation 8

where (see table below for values associated with these variables):

Hs = Health hazard score

Es = Environment hazard score

Calculating the substance group score for chemical or functional classes containing multiple substances The scores for substance groups are calculated using Method 1: Maximum score. The maximum score reflects the hazards associated with using the most hazardous ingredient that could be described by the non-specific ingredient name.

Step 7: Calculating an ingredient hazard score for a product

The scores for each substance in the product are combined to determine an overall score indicating the hazardousness of the ingredients in a product. If a product contains several ingredients with high hazard scores, the hazard score for that product will also be high. Likewise if the ingredients in a product are generally low hazard, the score will be low. Special considerations will affect the overall hazard score. For example, some substances are more hazardous through specific routes of exposure or in certain concentrations. The types of exposures associated with the product and ingredient concentrations will be factored into the score.

The overall ingredient hazard score for a product is calculated for both health and environment categories by using Method 3: Weight of Evidence.

Equation 1 is modified to reflect a down-grading of health endpoints relating to exposures that are unanticipated with consumer use, using the r(route) attribute associated with each finding. The m(misuse) attribute, if applicable, may also be factored in using the same modified equation:

Modified Equation 1

where m(misuse)*r(route) modifies the equation to account for product misuse and route of exposure

In addition, when appropriate, EWG may not score a product ingredient for acute health effects, such as skin corrosion, if the concentration of that ingredient in the product would not result in the health endpoint. This does not apply to any endpoint relevant to chronic health effects, such as endocrine disruption or cancer. Endpoints that are acute and concentration-dependent would therefore be eliminated from the score for the ingredient in question when calculating the product score.

Example: Sodium hydroxide can cause acute irreversible and severe skin and eye damage in its concentrated form. However, it is also used in diluted amounts in many products to adjust the pH. Therefore, sodium hydroxide should not receive a hazard score for skin or eye corrosion if the concentration used in the product in question would not be sufficient to result in this type of damage.

Step 8: Calculating a product disclosure score

EWG believes consumers have a right to know as much as possible about product ingredients, and that companies should label their products appropriately. Product labels are the best source of health and hazard information available to consumers when they are deciding what to buy. Failing to disclose ingredient information on the label, or using vague words to describe specific ingredients, negatively impacts a product’s score.

Disclosure scoring criteria are consistent with the following principles:

It is preferable to list a specific substance name rather than a descriptive chemical group (e.g., alcohol ethoxylate) or a cleaners-relevant functional group (e.g., “surfactant”).

It is preferable to list a substance function without the substance name than to list nothing at all.

It is preferable to list some information on the label rather than none, even if it is less than other sources list. For example, a product with four ingredients on the label and eight on the company website will score better than a product with no ingredients on the label and eight on the website.

Product must have label information and a website to be scored. If the label is unavailable for analysis we use the average label score for the brand. If no labels are available for a brand, we assume label disclosure falls between none and the level provided on the website.

Assumptions are made about the number of ingredients in cleaning products. If a product label shows fewer than four ingredients, there will be a deduction in disclosure scoring after manual checking to make sure this rule should apply.

EWG encourages manufacturers to make available worker.

Equation 9

where Label Disclosure ranges from 0 to 12, Website Disclosure ranges from 0 to 6, and MSDS Disclosure ranges from 0 to 2. Final scores therefore range from -10 (complete disclosure) to +10 (no disclosure).

Label Disclosure is calculated as follows:

12 points if all ingredients listed are specific substances rather than chemical or functional groups or terms like “fragrance” that can hide a multitude of unlisted chemicals

10 points if more than 75 percent of ingredients listed are specific

6 points if more than 50 percent of ingredients listed are specific

4 points if more than 25 percent of ingredients listed are specific

2 points if any ingredients are listed

score halved if fewer than 4 ingredients

Website Disclosure is calculated as follows:

6 points if all ingredients listed are specific substances rather than chemical or functional groups or terms like “fragrance” that can hide a multitude of unlisted chemicals

5 points if more than 75 percent of ingredients listed are specific

3 if more than 50 percent of ingredients listed are specific

2 if more than 25 percent of ingredients listed are specific

1 if any ingredients are listed

score halved if fewer than 4 ingredients are listed

if no website information is available, half the label score is used.

if a product label has a machine-scannable barcode or QR code that allows consumers to access further ingredient information at point of sale, the website disclosure score is multiplied by 1.5 and it is calculated from a possible nine points.

MSDS Disclosure is calculated as follows:

2 points for an available MSDS

0 when no MSDS is available

1 for an MSDS that lists ingredients not found on label or website

The ingredient disclosure score is then combined with the ingredient hazard score to calculate an initial product score.

Step 9: Combining the ingredient hazard and disclosure scores and calculating a final product score

The overall ingredient hazard score and the disclosure score are combined. The scores are effectively combined using a weighted average where scores indicating hazards or poor disclosure are the driving factors. With good disclosure and a lack of hazard information, an average of the scores is taken.

Equation 10

If the combined ingredient score is < 2:

where (see table below for values associated with these variables):

C s = Combined health and environment hazard score

D s = Disclosure score

If the combined ingredient score is >2:

If the combined ingredient score is greater than 2 than disclosure cannot improve a product’s score, since the ingredients in the product show sufficient hazard to warrant concern and an initial product score of “D”.

Finally, the product score is adjusted based on several criteria to reflect additional hazard concerns or qualities that make the product healthier and more eco-friendly. These criteria may include:

pH. A product with a pH at or below 2.0 or at or above 11.5 gets a less favorable score due to risk of permanent damage to skin or eyes from corrosive properties. Volatile Organic Compounds (VOC) content. VOCs react with nitrogen oxides to form ozone, which has serious health and environmental effects. Products containing more than 50 or 75 percent VOCs receive progressively worse scores since they contribute to the formation of ozone and poor air quality. Regulatory violations. If a product would violate a regulatory standard, such as one set by the state of California or the European Union, its score will be docked to reflect this.

Points are added to or subtracted from the final product score according to specific criteria and constrained between -10 and +10. Scores are translated to letter grades using the following scale:

A = -10 to -6

B = greater than -6 to -2

C = greater than -2 to 2

D = greater than 2 to 6

F = greater than 6 to 10