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When 'Any' and 'None' Don’t Mean 'Zero'
November 7, 2012
When it comes to the words any and none, it is pretty clear what we mean in casual conversations — like when you tell the server at the restaurant that you don’t want any mayo on your BLT. That is pretty clear. You can easily look when the sandwich arrives to see that there is none.
It becomes less clear what any, none and even zero mean when we start talking in scientific terms. With current analytical techniques, we can now find molecules of just about anything, anywhere, at any time. For example, I was at a conference a few years ago when a researcher was talking about sampling the air in the Arctic for trace amounts of tetrabromobisphenol A (TBBPA). She stated that she had found part per trillion (ppt) levels of the chemical. Now, a part per trillion is one drop of water in 20 Olympic-size swimming pools or one second in 31,710 years. In other words, it is really, really small. And it goes back to what I said earlier that we can now find just about anything, anywhere, at any time with the right testing.
So what does this have to do with zero? Well, when we ask companies to make sure they don’t have any of a given substance in their products, we have to ask for them to define any. Do they mean less than 0.1%, less than one ppt, or less? I heard a story this summer about a carpet manufacturer who had to report the lead in its carpet operations. I wasn’t aware lead was added to carpet; it isn’t, but talc is, and talc is mined from mountainsides and it typically has a few parts per million lead in it as a naturally occurring metal commonly found in these geologic formations. Thus, the carpet manufacturer, who might use a million pounds of talc in its product, would have a few pounds of lead as well. Should you be concerned? No, unless you plan on eating a lot of carpet — and then you may have other more pressing mental issues. Now should the carpet manufacturer be able to say that it doesn’t have any lead in its product? It doesn’t intentionally add lead, but it is there.
A few weeks ago the Federal Trade Commission (FTC) settled a case with Sherwin-Williams and PPG, who they claim misled consumers into believing their paints didn’t have any Volatile Organic Compounds (VOCs). VOCs are carbon-containing compounds that easily evaporate at room temperatures; some can be harmful to human health and the environment. The two companies agreed to settlements with the FTC is requiring them to stop making the allegedly deceptive claim that their Dutch Boy Refresh and Pure Performance interior paints, respectively, contain zero volatile organic compounds. According to the agency, while this may be true for the uncolored base paints, it is not true for tinted paint, which typically has much higher levels of the compounds and which consumers usually buy.
The FTC recently updated their green guides and in the section discussing "free of" claims, they list three conditions that would allow this claim if a product, package or service that contains or uses a trace amount of a substance if: (1) the level of the specified substance is no more than that which would be found as an acknowledged trace contaminant or background level; (2) the substance’s presence does not cause material harm that consumers typically associate with that substance; and (3) the substance has not been added intentionally to the product.
Unfortunately, the more we ratchet down the acceptable levels of none, any and zero, the more you can expect to pay for the product. This is because the testing to determine ppm, ppb or ppt levels of chemicals is very expensive, and chances are they may find some of the unwanted chemicals at this level. Another unintended consequence of our pursuit of zero is that we will discourage the use of recycled materials. Recycled glass, metals, paper and plastics have a history to them that is almost impossible to trace. Thus unintended chemicals have a way of making their way into the recycling stream and contaminating the whole lot. Pretty soon we won’t be able to buy anything, anywhere with none, any or zero of the chemicals we are concerned about. This leads into tomorrow’s article about labeling.
By the way, the researcher that was sampling the air in the Arctic for trace amounts of TBBPA — the ppt levels likely came from the electronics in her own sampling equipment, since that little green circuit board in most of our electronic gadgets has a few parts per million TBBPA left over from the manufacturing process.