Got TEA? – You may need CFATS!

The Department of Homeland Security (DHS) has established Chemical Facility Anti-Terrorism Standards (CFATS) covering sites handling over 300 Chemicals of Interest. http://www.dhs.gov/xlibrary/assets/chemsec_appendixa-chemicalofinterestlist.pdf The listed chemicals were identified in the Federal Register on November 20, 2007. This table lists Minimum Concentrations and Screening Thresholds for addressing Release, Theft and Sabotage concerns for these chemicals. Seven different Security Issues are contained within the list. Triethanolamine (TEA) is listed as a chemical weapons precursor when at a minimum concentration of 80% and a screening threshold quantity of 220 lb.

Triethanolamine is commonly sold in two grades of purity, 99% and 85% (the remainder of the 85% grade is diethanolamine. Both grades are offered in LFG or Low Freeze Grade versions. The LFG versions contain 15% added water to prevent them from solidifying at common storage temperature.

If you buy only TEA 85 LFG, the concentration is 85% of 85 or 72.25% thus it fails to make the 80% minimum concentration that would trigger the CFATS rules. The three remaining grades are all above the minimum concentration threshold.

500lb is the common weight for TEA in drums. All grades of TEA in drums exceed the 200# screening threshold quantity. None of the grades meet this quantity in 40# pails. Doing a little math reveals that you could have the following number of pails:

  • TEA 85                         5 pails
  • TEA 85 LFG               Any Quantity of pails or drums
  • TEA 99                         4 pails
  • TEA 99 LFG                5 Pails

If you find that you need to comply with CFATS because you store or use TEA (or any of the additional 300 or so chemicals of Interest on the list), your first step in is to arrange to have the U.S. Department of Homeland Security’s Office of Infrastructure Protection appoint you or one of your employees as an Authorized User of Chemical-terrorism Vulnerability Information. They will then need to prepare a Top-Screen profile using the DHS Chemical Security Assessment Tool (CSAT). Once this has been done and submitted to DHS a Chemical Security Identification Number will be assigned to your facility. In our experience it appears unlikely that your facility would be classified as High-Risk if the sole reason for registering was a drum or two of TEA. It could be more of a problem if the DHS identified you as a consignee of TEA while inspecting the shipping records of a vendor.

Triclosan Trouble

The Federal Food and Drug Administration (FDA) has announced it is reviewing the safety of triclosan, the active ingredient in many antibacterial soaps and body washes.  This follows the December 10th release of the Fourth National Report on Human Exposure to Environmental Chemicals by the Centers for Disease Control and Prevention.  The report provided an extensive look at 75 chemicals that had not been previously measured in the US population.  Triclosan, characterized in the report as an “endocrine disruptor” was among the materials present in blood or urine samples from the 2400 study participants.  While industry trade groups point out that the mere presence of environmental chemicals in blood or urine is not necessarily cause for health concerns, it is eerily similar to the situation that caused the demise of the material triclosan replaced, hexachlorophene.

Some will remember the trade name pHisoHex, a highly effective over-the-counter (OTC) antibacterial skin cleanser available in the 1960’s.  In 1969, hexachlorophene was suspected as being a carcinogen.  pHisoHex and several OTC antibacterials for treating acne and other uses including surgical scrubs were withdrawn from the market.  Later studies cast doubt on the original classification of hexachlorophene as a carcinogen but the damage was done.  Once FDA approval for an active ingredient has been withdrawn, it is all but impossible to undo the damage.  Caution is advised if triclosan plays an important role in your product mix.

Lubrizol: C&EN’s company of the year!

We’re proud to number Lubrizol among our suppliers, not only because of the superior products it brings to market, but because it’s one of the true leaders in the industry.  That was recognized by Chemical & Engineering News, which has spotlighted Lubrizol as its Company Of The Year for 2009.

As their article puts it,

The most impressive performance among chemical companies last year was Lubrizol’s. Looking at the firm’s results, one would hardly know a recession was going on. Its earnings for the first three quarters increased 67%, to $385 million, on sales of $3.4 billion. Executives expect earnings to increase 78% for the full year and hit a company record. James L. Hambrick, Lubrizol’s CEO, credits his employees. “It’s not an exaggeration for me to tell you that every single person in our company did more with less this year,” he told analysts in October.

What makes this even more impressive are the companies also in the running for the title; worthy and statured firms, all of them.  Lubrizol made the best of tough times in the industry, setting itself up for success as the economy rebounds.

The passing of a pioneer: Dr. Albert Kligman

Dr. Kligman, the dermatologist and educator who led Retin-A to market, among other achievements, passed away on February 9, 2010, at the age of 93.  He was a signature example of the commitment and sense of inquiry and innovation that’s led to so many breakthroughs over the years in both the sciences, and their  practical application in the realm of personal care products.   His endowments to the University of Pennsylvania, and the influence he’s had on generations of students, will ensure the progress and good works he initiated will continue well into the future.

Natural personal care products see fresh new investments!

Investment dollars are finding their way back into the natural personal care category, according to this recent story via CGI Magazine; recent acquisition deals show how companies and brand are recovering the interest of investors after an 18-month lull brought on by the financial crisis.

Names such as Aveda managed to maintain growth and solid results throughout the downturn, in part because of their independence and because consumers identified them as ‘ethical’ brands which offered the authenticity that’s important to more and more shoppers as time goes on.

This news also points up how investment follows innovation, as pathfinders in this category are now reaping the rewards of offering consumers alternatives that, in many cases, instigated new lifestyle behaviors and buying patterns, helping to create mass momentum behind a fresh new extension to the personal care category.

Wooden Pallet Alert

Last December, the producer of  Tylenol reported a recall due to what was described as an unusual odor.  Since then, the recall has been extended to include additional products most of which were produced at a factory in Puerto Rico.  The recall now covers more than 50 million consumer packages.  Some illnesses are alleged.

Tylenol’s manufacturer issued a statement on December 18 stating: “The uncharacteristic smell is caused by the presence of trace amounts of a chemical called 2,4,6-tribromoanisole. The source of the 2,4,6-tribromoanisole is believed to be the breakdown of a chemical used to treat wooden pallets that transport and store packaging materials.”

The pallets in question are believed to have originated in the Dominican Republic however; it is proving to be difficult to trace their exact origin.  To complicate matters, the Dominican Republic shares the island of Hispaniola with Haiti and has suffered significant infrastructure disruption as a result of the recent earthquake.

What might this mean to you?  Keep in mind that wooden pallets are used and re-used throughout the industry.  The problem was identified following a spike in consumer complaints.  The pallets bearing early shipments of off-odor products have had plenty of time to work their way to your dock!  Once in your warehouse, they may cause issues with product stored on or adjacent to affected pallets.

If your product line includes FDA Regulated Food, Drug, Cosmetic or Medical Device items you should be especially concerned.  The FDA’s position is bluntly stated in an official warning letter to the Tylenol Manufacturer that you can examine at:

http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm197811.htm .

The National Wooden Pallet and Container Association has issued a fact sheet regarding the Tylenol recall which can be viewed at:

http://www.nwpca.com/_INTLRegulations/Tylenol.pdf

The FDA Warning Letter cites Tylenol’s producer for failure to submit Field Action Reports (FARs) to the FDA within three days.  Had the product been a food, the allowed time would have been 24 hours effective when the Reportable Food Registry (RFR) regulations went into effect on September 8, 2009.  The RFR uses FDA’s new electronic portal.

Be sure your drivers, warehousemen and dock workers are alert to this problem and equipped to take prompt decisive action.

AkzoNobel’s new investment in the future

Our valued supplier AkzoNobel is investing heavily in innovation,  pointed up by this article about their significant outlay to enhance their research establishment at Felling, in the UK.  The benefits of this will undoubtedly be felt by customers, like ours, who depend on exactly this sort of heads-up investment to assure them of ingredients and formulations that will advance their own competitive edge.

We’re fortunate to have suppliers, such as AkzoNobel, that haven’t relented in their R&D spending during the recession because they recognize how critical it is to future success.  And their products will be foremost among those that prime the pump for a strong recovery.

Innovation…it’s also about attitude.

Here’s a very good post from Business Week about why those in business who complain and feel victimized don’t invent — they find reasons not to succeed, so they don’t bother to try, and accept failure as inevitable consequence, not as an opportunity to learn and move forward.  So they don’t innovate.  Often, even the best of us place our faith (or cynicism) in larger forces, whether in the marketplace, in our business or in our life, and default to those forces; we don’t attempt change or invention because we think the deck is already stacked against us.  There’s no greater untruth!

Some years ago, a book called Luck Factor scientifically examined the psychology of “luck” and how it’s not a predetermined external factor (the “gambler’s fallacy” of belief in lucky streaks that helps casinos keep raking it in, in Vegas) but a function of attitude — people who saw life as offering opportunity would invariably have good things happen to them, because they’d see situations differently from those who saw the glass half-empty, and who would manufacture negative attitudes, hold back in potentially beneficial situations, and otherwise lose out on the “luck” circumstances offered them. 

So if you audit your attitude, believe in the time-tested values of elbow grease and imagination, then you’ve got every chance of succeeding.  Maybe even more, considering there are others who may get hung up on their own doubts!

The segment that’s groomed for (even more!) growth

This SpecialChem post spotlights one of the notable growth areas in personal care specialties, men’s grooming products, growing at a strong rate despite the struggles of other sectors, due to four basic factors:

…the ongoing rise of middle-class sectors in fast growing nations such as Brazil, Russia, India, and China; the Internet and similar technology providing enhanced access to new consumer bases outside wealthy industrialized regions; marketers’ increasingly sophisticated appeals to men, including creating or repositioning brands that flatter the male sense of national and/or ethnic identity; and the universal appeal of naturally or organically formulated toiletries that satisfy growing consumer consciousness regarding environmentalism and potential health problems originating from chemical-laden products.

 

The projected total market?

Within five years, the global market for all male-consumed grooming products is forecast to mushroom to $85 billion, compared to $28 billion for male-specific products.

What makes it an innovation story?  Simply the fact that this segment was a scarce fraction of itself just a decade ago. 

Thanks to the wherewithal and vision of manufacturers and marketers alike, it’s now an engine for growth worldwide, thanks to plentiful new products and inventive appeals that have revolutionized men’s attitudes toward personal grooming.

Taking nothing for granted: a primer for 2010

The conservatively upbeat outlook for this year is tempered by the obvious slowness in other areas of the economy that affect the chemical industry, though the personal care products category has been a bright spot.  The overall business declined by 6.2% in 2009, its second drop following a 4.7% fall in 2008.

We’d like to think that made the personal care sector stand out isn’t just the power of consumer demand — though we obviously can’t begin to discount that.  Some of the credit, according to industry pundits and analysts, goes to the the very qualities we rely upon for our own success here at Coast Southwest (but which are certainly not exclusive to us): a high degree of customer engagement, leading to partnered innovation resulting in strong product offerings in these burgeoning segments. 

These product categories are intensively competitive, and demand constant development of new formulations, new ideas and new approaches.  That takes imagination, communication and collaboration, on an intense level.  Just because a given category is accelerating is no guarantee of success; indeed, that situation presents its own challenges and potential for missteps.  And just because the analytics and predictions indicate an upswing, where 2010 will really succeed or fail is “on the ground” — through the continual effort and focus of the people making the breakthroughs and connections necessary to drive that success.

Simplistic?  Maybe.  But it’s interesting how, time and again, success or failure comes back to these evergreen basics.