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The SIGG BPA Confession: You aren’t going to like it any more than we do

The SIGG BPA Confession: You aren’t going to like it any more than we do
Update: Heard about Gaiam's BPA problem?

Swiss sports and children's bottle maker SIGG has admitted what many consumer advocates have suspected for years, but never proven: That the epoxy lining used for years in SIGG bottles - which they secretly swapped out for a new liner last summer - contained the hormone-disrupting chemical bisphenol-A. There's more to the story than that, but the bottom line is that this company is in a very vulnerable position, and there are a couple of factors that will make it hard for them to claim the high road on this issue.

Which bottle do I have?


Let's figure out what you have - if you have any SIGG water bottles, I'm guessing that's the first thing you want to know.

If you own SIGG bottles you purchased before August 2008, you definitely have one with the old liner. But even SIGG bottles that are less than a year old don't necessarily have the new liner. In fact, SIGG's announcement may be somewhat conveniently timed - it can take several months for products to move through the supply chain, and if I were a betting man I'd bet that many of the SIGG bottles with the BPA-containing liner were being sold as late as this spring.

But it's easy to compare them by sight alone. The old version of the liner is very brassy looking, like the inside of a can of tomatoes. The new liner is dull and beige.


As a case in point, a product sample SIGG sent us in the fall of 2008 actually has the old liner.

SIGG's slippery claims


Consumer groups have been alleging since at least 2007 that SIGG bottles are lined with a BPA-containing epoxy, and on the face of it the claim makes sense - SIGG bottles are aluminum, after all, the same material used in canned foods, infant formula, and soda that have been second-class citizens in the debate over BPA exposure. SIGG, in turn, maintained that their bottles did not leach BPA, but that they could not disclose the formula for the liner because it was made by someone else. It is important to note here that they did not claim not to know what was in the formula, only that they could not or would not reveal it. As SIGG Switzerland CEO Steve Wasik explained it in April 2008:

SIGG has proprietary rights with a 3rd party producer of our liner formula. In other words, we do not produce it ourselves. This supplier is based in Switzerland and has an impeccable reputation for quality and safety. SIGG is the only water bottle on the market to use this special liner. As there are many copy-cat manufacturers in the market (most based in China) that would like to get their hands on this formula, our supplier has an agreement with SIGG to keep his formula confidential.

Because we know that this liner is the very best on the market and we have had a positive working relationship with this supplier, we have honored that agreement.


With that context in mind, let's jump back to early 2007, when the Environmental Working Group published a guide to BPA-free products that listed SIGG water bottles as containing BPA. SIGG responded by demanding that the organization either furnish proof that this was true or remove SIGG from its list. Listen to the very carefully crafted language of then-SIGG USA president Wasik:

On March 9th, it was brought to my attention that a website sponsored by the Environmental Working Group (EWG) made mention that SIGG bottles contain plastic liners with bisphenol A (BPA).

I can assure you that SIGG bottles are absolutely not made with a plastic liner and are in fact lined with a proprietary non-toxic, water-based resin which has been refined over decades of study and is extremely safe & stable.

Based on the confidence we have in our product backed by numerous laboratory studies, we questioned the EWG and requested that they provide us with the testing they have conducted on SIGG - or alternatively to remove the "SIGG" mention from their website if they have not tested SIGG. Within 24 hours of this request, the EWG removed SIGG's name from their report. [Via Eco Child's Play]


I encourage you to read those paragraphs again. There are great ravines of fact bridged by carefully chosen inference. And they helped ensure that SIGG benefited mightily from the rampant purchases of aluminum and stainless steel water bottles Americans made in 2007 and 2008 to replace their Nalgene and other polycarbonate sports bottles. Where would SIGG have been if they had admitted to having BPA in their product at the time, but assured consumers that it would not leach out?

Meanwhile, the Organic Consumers Association had picked up the SIGG contains BPA claim, and reported that consumers should avoid SIGG bottles along with many other known BPA-containing products. They published this in the March 8, 2007 issue of their newsletter, Organic Bytes.

But SIGG was edited out of that document, too - even the PDF version of the newsletter! - after an unspecified party alerted the OCA to SIGG's counter-claim. In the next issue of Organic Bytes, editors Craig Minowa and Ronnie Cummins wrote:

In Issue #104, we ran a piece with quick tips on how to avoid toxic BPA. One of our bullet points mentioned avoiding SIGG water bottles (among other brands). We acquired that information from the Environmental Working Group. Unfortunately, the data was slightly dated. SIGG has since gone BPA-free, so it is now safe to purchase SIGG water bottles.


SIGG began releasing independent testing showing that its bottles leached no BPA in tests that mimicked liquids like colas, fruit juices, and water. These tests don't appear to be any different from the kinds of tests Canada would do if SIGG wanted to import bottles with that liner into our BPA-banning neighbor's home turf - put the material up against a liquid, wait, and see what comes out. In other words, Health Canada and anyone else who regulates BPA will not test for the presence of BPA in the material itself; they will test to see if BPA comes out of the material. It is entirely conceivable that a material could be made using BPA but be so well-engineered and so carefully used that it does not leach BPA, and that appears to be what SIGG accomplished with its third-party provider.

Still, things seemed a little funny. As Amelia Royko Maurer of the green online shop Free Market Organics wrote in an undated page of notes and clippings on her website:

When I bought my first Sigg bottle, I called the company up and asked what the liner was all about. They said something like they were working on a patent and could not yet reveal what it was. So I waited and wrote again. Then I would just periodically check in at their website to see if they had given the answer yet. Finally one day it said the liner was a "water based epoxy resin". If you look today, they have removed the word epoxy, but the funny thing is, none of their other retailers have, which looks a little obvious, especially since their descriptions of it all match accept for the missing word "epoxy." They mention that it is not plastic - which is true, nonetheless, BPA is used to make most epoxy resins. [Link]


For much of this period, we assumed that SIGG was either bluffing about knowing whether the product was made using BPA (it wouldn't sound very good to admit you were using a coating but weren't entitled to the formula, would it?) or that there was some strange legal quandary that prevented them from coming out and explicitly saying their product was BPA-free. (Incidentally, many companies that have been selling products as BPA-free must now wrestle with some of those questions.) Because of these unanswered questions, we chose not to flag SIGG bottles with BPA as a "chemical of concern" in the ZRecs Guide, but flagged our level of confidence in the information provided by the company as "Low," because it was clear SIGG was failing to disclose something, although we couldn't be certain what.

We'll be changing it soon to reflect SIGG's new revelation, so this is for posterity:


Despite this "Low" confidence rating, we trusted (and continue to trust) their third-party testing. It isn't the stuff of peer-reviewed scientific journals, but it's the kind of data companies have to submit to government agencies to certify their products. It describes the methods used and provides a lot of detail. And Z has used SIGG sippys off and on for years. We have no concerns about BPA exposure, based on the test results.

But that doesn't mean we like the way SIGG does business.

Whether or not you are comfortable using a bottle that contains but does not leach BPA, for us the real story here is how a company using BPA that would have been absolutely sidelined by consumers seeking BPA-free alternatives managed to make itself a central player by carefully controlling information about its products, challenging consumer advocacy organizations when they made statements that were unproven but that the company knew to be true, and "coming clean" only when it suited its own purposes.

Now SIGG CEO Wasik has proudly announced on SIGG's U.S. website:

Within the scientific community, the safety of the packaging ingredient bisphenol A (BPA) remains the subject of considerable debate and controversy as evidenced by the FDA meetings on the topic this month. For decades, BPA has been the industry standard for protective coatings – approved by food and health regulators around the world. One year ago, Andrew von Eschenbach, the Commissioner of the FDA, announced that, "The science we have reviewed does not justify recommending that anyone discontinue using products containing BPA." At that time, SIGG Switzerland, the world leader in premium reusable bottles, had already made the transition into bottles that are BPA free.


(Of course, it wasn't long before we all became painfully aware of how cozy the FDA and industry were during that time. But let's not quibble over details.)

Within the reusable bottle water category, polycarbonate plastic bottles (#7) came under scrutiny in early 2008 because they were found to leach BPA. As a result, many consumers turned to metal bottles (aluminum and stainless steel) because these bottles had no issues with BPA migration. Prior to its transition, SIGG utilized a water-based epoxy liner which contained a trace amount of BPA. The bottles were thoroughly and regularly tested in both the USA and Switzerland and all tests revealed absolutely no migration or leaching of BPA or any other substance from the protective inner liner. These tests have been public information on the SIGG website for several years and remain there today.

Despite the fact that these bottles were manufactured well within strict international regulations and posed no health risk, my team and I initiated a project in June 2006 to develop a new liner which would be both BPA free and produced in a more environmentally friendly manner. We recognized early that there were questions surrounding BPA and we wanted to be sure that we had a bottle liner that you, our customers, could have absolute confidence in.

After two years of comprehensive testing and development and a one million dollar investment in new equipment for our Swiss factory, SIGG began producing bottles with our new, next generation "EcoCare" liner in August 2008. Providing the same quality and protection afforded by the previous liner, this new powder-based, co-polyester coating has been thoroughly tested and is certified to be 100% free of BPA... [Link]


WTF SIGG?


August 2008? Yep, SIGG has been sitting on this news for a year. Why? Well, one reason a reasonable person might assume would be a factor is that the overwhelming majority of SIGG bottles made with the old liner have now moved through what is probably a year-long supply chain of production, distribution, and brick-and-mortar and online sales. SIGG offers a product line of dizzying variety sold at premium prices, and they are probably slow to move. But of course that is not the real reason!

The primary reason that I am writing this letter today is because I believe that the BPA conversation has changed dramatically in the last 12 months. Last year, the primary concern was that of BPA leaching from bottles. Since that time the dialogue has evolved such that now some people are concerned about the mere presence of BPA and some states are considering legislation.


But how much trust can consumers spare for a company that operates this way? Does this chain of events lead you to have "absolute confidence" in SIGG's desire to meet your expectations - and to protect your health?

As Alicia at online retailer The Soft Landing put it in a post yesterday about her company's experiences with SIGG that ultimately led her to stop selling them in her online shop:

We’re not interested in dealing with another used car salesman. There are too many other top notch water bottle companies out there! It’s not about the "mere presence of BPA" or that their studies didn’t show any leaching - it’s about the principle of trust. We as parents, consumers and advocates should demand transparency from companies who build their entire foundation on being healthy and green.


We'd be very surprised if SIGG wasn't prepared for some kind of backlash. The question is, how big will it be? We want to know what you think about this issue. Does this news anger you? Or do you think this is the only way a business could handle this kind of transition, and applaud SIGG for "taking the lead" in making a safer aluminum container lining?

Tomorrow I'll talk a bit about what we find really shocking about SIGG's strategy to minimize the flight of consumers from its brand. It's a move that could shake things up the backrooms of the children's products industry and yield a lot of new, but not necessarily enlightening, claims and counter-claims about various products' safety.

New to ZRecs? Find out what we do in this list of our best recent consumer reporting and reviewing.

Updates to this story




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SIGG's public statements about BPA


"SIGG's Bottle Liner"
publication date unknown, received by ZRecs on March 18, 2008

SIGG Bottle Liner

From: Steve Wasik President, SIGG USA Re: SIGG’s Bottle Liner One of the reasons SIGG is the world leader in the manufacturing of premium water bottles is because of our proprietary bottle liner. This special liner is a water-based, non-toxic polymer which has been perfected over decades of Swiss craftsmanship. Like Coca-Cola’s soft drink recipe, the SIGG liner formula remains secret and unavailable to third parties in order to protect our competitive advantage. The Swiss have confirmed to me the following information which may be of interest to you: • The SIGG “internal protection lacquer” (a.k.a. - the bottle liner) meets and exceeds requirements outlined by the USA FDA regulations (175.300). The liner is micro thin and still allows for the bottle to be 100% recyclable. Based on multiple tests (both in-house and independent), the SIGG liner does not impart any taste or odors into the liquid. The liner is resistant to fruit juice acids, isotonic/energy drinks, alcohol and virtually any consumable beverage. Due to the finish/porosity of the liner, SIGGs outperform polycarbonate #7 (Lexan) and other plastic materials at reducing bacteria build-up and ease of cleaning. SIGG’s bottle liner is totally inert because it is baked on at extremely high temperatures (over 200 degrees Celsius). The liner is flexible and remains intact and fully functioning no matter how dented the outside of the bottle becomes due to rough use. SIGGs are safe to be placed in the dishwasher with no harm to the liner. The Swiss believe the bottles can be washed more thoroughly by hand in hot soapy water. Dark spots which materialize in the bottle are sugar deposits and can typically be cleaned by baking soda or SIGG cleaning tablets. In addition, SIGG’s liner protects from any migration or leaching of the liner & container into the liquid. All tests of the liquid reveal no trace (0 %) of any of the following chemicals: Perfluorooctanoic Acid (PFOA), Bysphenol A (BPA) and Bysphenol B (BPB). “Only the 2 bottles manufactured by SIGG, the market leader, showed no traces of aluminum... The manufacturer SIGG shows that it is possible to avoid residue from synthetic coating.” - OKO independent test, Germany 1997 • “According to the results of our evaluation, use of a SIGG bottle does not add to the beverage any particles and/or components which are harmful to human health, or which alter the odor or flavor of the beverage.” - Dr. Ulrich Nehring, Institute Nehring, 2001 • “While the polycarbonate bottles we tested leached a significant amount of BPA, the SIGG bottles – both new & used – showed no detectable BPA.” - Jonathan Chun, PhD, Alliance Tech, USA 2007 • • • • •



"Former Liner Full Report, BPA Leach Testing, June 2007"
publication date unknown, received by ZRecs on March 18, 2008

Former Liner Full Report BPA Leach Testing June 2007

Bisphenol-A Leaching from Water Bottles prepared for Stamford, CT SIGG USA © Alliance Technologies, LLC 2007 www.alliancetechgroup.com info@alliancetechgroup.com 732.355.1234 (ph) Alliance Technologies, LLC 1 Deer Park Drive, Suite D Monmouth Junction, NJ 08852 732.355.1234 (ph) / 438.8265 (fx) www.alliancetechgroup.com 8 June 2007 Client: SIGG USA 1177 High Ridge Road Stamford, CT 06905 Requestor: Steve Wasik Study: LIMS #: Re: Bisphenol-A Leaching from Water Bottles 20070075 SUMMARY Five types of water bottles were submitted to determine bisphenol-A (BPA) leaching into reverse osmosis (RO) water. The bottles were filled with water and heated in a temperature regulated oven in order to simulate usage & aging. This treated water was extracted and analyzed for BPA by gas chromatography and mass spectrometry (GCMS). A significant amount of BPA leached out of Lexan polycarbonate (PC #7) bottles, generic aluminum, and low density polyethylene bike bottles at 90ºC after 3 days of incubation. In contrast, no BPA was detected above the LOQ in SIGG bottles under the same severe environmental conditions. EXPERIMENTAL 40 Bottles were received and entered into a Laboratory Information Management System (LIMS) (Figure 2). Each bottle was filled with RO water and the volume of water and the surface area exposed to the water were measured and recorded. The bottles were placed in a regulated environmental chamber (Espec) at a fixed temperature. At specified periods of time, the plastic or aluminum bottles were removed from the oven and the water transferred to individual glass jars and stored in a refrigerator until analysis. To extract the BPA, the pH of the treated water was adjusted to about 3 before extraction using a small solid phase extraction (SPE) column (Oasis HLB WAT106202). The loaded SPE cartridges were eluted with a methanol:ethylether mixture and dried over solid sodium sulfate. The solvent from the filtered sample was removed over a hot water bath and the residue dissolved in 1 ml chloroform for GCMS analysis. Alliance Technologies, LLC 1 Deer Park Drive, Suite D Monmouth Junction, NJ 08852 732.355.1234 (ph) / 438.8265 (fx) www.alliancetechgroup.com Figure 1: Typical Bottle Types and Sample Designations New SIGG 20070075-01 Used SIGG 20070075-02 Generic Aluminum 20070075-03 Lexan (Polycarbonate #7) 20070075-04 Bike Bottle (Polyethylene) 20070075-05 Alliance Technologies, LLC 1 Deer Park Drive, Suite D Monmouth Junction, NJ 08852 732.355.1234 (ph) / 438.8265 (fx) www.alliancetechgroup.com Calibration: A series of standards were prepared by quantitatively dissolving solid Bisphenol-A (Aldrich, 99+%) in chloroform and analyzing by GCMS. The standards were used to quantify BPA in the water samples. RESULTS & DISCUSSION 7-Day, 90ºC Lexan Polycarbonate #7 Bottle Exposure Conditions Study In order to determine suitable exposure conditions 4 Lexan (polycarbonate #7) bottles were incubated with RO water over several days. At set time periods the bottles were removed from the oven and transferred to glass jars. The RO water from these bottles was extracted to determine the level of leachable BPA as a function of exposure time. Each Lexan bottle was filled with about 750mL of RO water and maintained at 90ºC for 1, 2, 3, and 7 days. The liquid was then extracted for BPA and analyzed. Figure 2 summarizes the BPA leached as a function of time. Results were reported as parts per billion (ppb) and also normalized by the area exposed to the water (nanograms BPA leached per square centimeter of exposed surface area or ng/cm2). At 90ºC, a significant increase in BPA leaching was observed in two and three days compared to one. As a result, 3 days was chosen as a time period that would produce a measurable BPA concentration. 3-Day, 90ºC Leach Test vs Bottle Type Bottles of each type (SIGG, Used SIGG, Lexan, generic Al, and Bike Bottle) were filled with 750-1000mL RO water and heated at 90ºC for 3 days. The leachate was extracted for BPA and analyzed. Results are shown in Figure 3. After 3 days, a significant amount of BPA, >70ppb (110ng/cm2), was leached from the Lexan water bottles compared to the other bottles. The generic Aluminum bottles showed the next highest levels of BPA with 19ppb (32ng/cm2) detected followed by the polyethylene bottles with nearly 10ppb (16ng/cm2). In comparison, SIGG bottles faired extremely well. Based on this analytical method, the limit of quantitation (LOQ) for BPA was approximately 2ppb. The LOQ is the level of BPA that can be determined reliably in these samples. Even under these extreme temperature conditions, no BPA was detectable in the SIGG bottles above this LOQ. Alliance Technologies, LLC 1 Deer Park Drive, Suite D Monmouth Junction, NJ 08852 732.355.1234 (ph) / 438.8265 (fx) www.alliancetechgroup.com Figure 2. Lexan Exposure Time Study BPA Leaching into Water in Lexan Polycarbonate Bottles 70.0 61.8 60.0 51.9 50.2 50.0 BPA Leach (ppb) 40.0 30.0 20.0 10.0 3.8 0.0 1 2 3 7 Exposure Time (days) Figure 3. BPA Leaching Study BPA Leaching into Water vs. Bottle Type @ 90C 82.0 72.0 62.0 52.0 42.0 32.0 22.0 12.0 2.0 2007007501, New SIGG 200700752007007502, Used SIGG 03, Generic Al 2007007504, Lexan PC 2007007505, Bike Bottle 19.0 71.4 BPA (ppb) 9.8



"SIGG Quality Guarantee"
released April 15, 2008

SIGG Quality Guarantee- April 15, 2008

Date: Subject: April 16, 2008 SIGG Quality & Safety Guarantee We have had a few inquiries in response to the recent report on NBC’s Today Show surrounding polycarbonate #7 plastic bottles (like Nalgene). Scientists have offered competing views of the health risks which may result from these plastic bottles leaching the chemical BPA. It’s a fact that this chemical, designed to reduce corrosion, also exists in some metal containers like canned foods. In the 100 years that SIGG has been in business, the bottle liner we have used has evolved and improved over time. We sincerely believe that our current SIGG liner and our application process for applying it, is the best in the world because it is totally inert and imparts absolutely no chemicals into the beverage. SIGG has proprietary rights with a 3rd party producer of our liner formula. In other words, we do not produce it ourselves. This supplier is based in Switzerland and has an impeccable reputation for quality and safety. SIGG is the only water bottle on the market to use this special liner. As there are many copy-cat manufacturers in the market (most based in China) that would like to get their hands on this formula, our supplier has an agreement with SIGG to keep his formula confidential. Because we know that this liner is the very best on the market and we have had a positive working relationship with this supplier, we have honored that agreement. We believe more important than the formula of the liner – is the performance of the liner. Very thorough migration testing in laboratories around the world is conducted regularly and has consistently shown SIGG bottles to have no presence of lead, phthalates, Perfluorooctanoic Acid (PFOA), Bysphenol A (BPA), Bysphenol B (BPB) or any other chemicals which scientists have deemed as potentially harmful. For example, last summer SIGG bottles were tested for BPA versus the competition at Alliance Technologies, one of the finest independent laboratories in America. Under harsh conditions to simulate time and use, the results were as follows: • • • • Polycarbonate #7 plastic bottles – 71 ppb (parts per billion) were leached into the water. Chinese-made aluminum water bottles – 19 ppb New SIGG bottles – no detectable BPA Used SIGG bottles (2 years old) – no detectable BPA Despite the scientific evidence that SIGG bottles are 100% safe, I understand the desire of some people to know more about the proprietary SIGG liner. As our Swiss supplier insists on protecting his formula & keeping it confidential, I have commenced the process of exploring new suppliers. You can be sure that we will thoroughly test the performance of a new liner under all conditions as we have the current liner – and that it will perform as good or better than the existing liner. In addition, we are optimistic that we can make the liner to be even more environmentally-friendly. Rest assured, SIGG Switzerland remains 100% committed to the health and safety of our customers. Sincerely, Steve Wasik CEO, SIGG Switzerland



"EcoCare Swiss Testing Feb 2008"
released August 2009

EcoCare Swiss Testing Feb 2008

SQTS - SWISS QUALITY TESTING SERVICES Grünaustrasse 23 Rte de l’industrie 61 www.sqts.ch CH-8953 Dietikon CH-1784 Courtepin info@sqts.ch Telefon +41 (0)44 277 31 41 Telefon +41 (0)26 684 80 40 Telefax +41 (0)44 277 31 70 Telefax +41 (0)26 684 80 49 25 February 2008 Sigg Switzerland AG Walzmühlenstrasse 60 CH-8501 Frauenfeld Your Reference: Our Reference: 14.01.2008 / AG 2008L00835 Certificate You appointed us in the letter dated 14th January 2008 to analyse and to assess Sigg bottles with respect to current food legislation. Product data: Sample: Sigg bottles, inside coated Intended use: In accordance with your data the bottles of different sizes are used for aqueous, acidic and alcoholic filling goods Analytic Overall migration The global migration was analytically examined by us. For this the sample material was brought into contact with aqueous and nonaqueous solvents under test conditions which are suitable to simulate the influence of foodstuff. Test conditions were selected according Council Directive 85/572/EEC and Commission Directive 97/48/EC. Due to foreseen multiple use the overall migration was performed three times, whereas only the value of the third migration is reported. The bottles were filled with simulance, closed with the stopper and turned upside down. Examination of the lacquer film The coating film was analyzed for BADGE, BFDGE, NOGE and Bisphenol A and F after acetonitrile extraction. Test on heavy metals By using X-ray fluorescence several coloured lids and the stopper were analyzed for Cadmium and heavy metal. ——————————————————————— STS 038 ——————————————————————— SQTS - SWISS QUALITY TESTING SERVICES Results of the examinations Overall migration: Simulants Water 3 % Acetic acid 15 % Ethanol Test conditions (Time/Temperature) 3 * 24h 40 °C 3 * 24h 40 °C 3 * 24h 40 °C Dry Residue of Migrates in mg/dm2 2 6 3 Examination of the lacquer film Acetonitrile extraction Substance BADGE (a) BADGE.HCl (b) BADGE.HCl.H2O (c) BADGE.2HCl (d) BADGE.H2O (e) BADGE.2H2O (f) BFDGE (g) BFDGE.2HCl (h) BFDGE.2H2O (i) Bisphenol A Bisphenol F NOGE Result µg/dm2 n.d. n.d. n.d. n.d. n.d. n.d. n.d. n.d. n.d. n.d. n.d. n.d. LoQ µg/dm2 2 2 2 2 2 2 2 2 2 2 2 2 *LoQ = Limit of Quantification, n.d. = not detectable Test on heavy metals Probe Lid green Lid yellow Lid red Lid white Stopper black Cadmium < 50 mg/kg < 50 mg/kg < 50 mg/kg < 50 mg/kg < 50 mg/kg n.d. = not determined; Limit of Detection: Cadmium: 0.005% (50 mg/kg ——————————————————————— STS 038 ——————————————————————— SQTS - SWISS QUALITY TESTING SERVICES Assessment Overall migration Under the prescribed test conditions with aqueous and nonaqueous simulants there was no overall migration which exceeded the limit according to Council of Europe resolution ResAP(2004)1. Furthermore the overall migration values fulfils the requirements of the US FDA limits of the CFR 21, § 175.300. Examination of the lacquer film The coating film does not contain detectable residues of BADGE, BFDGE, NOGE and Bisphenol A and F. The limits set in the Commission Regulation (EC) 1895/2005/EC will not be achieved or even exceeded. Heavy metals No heavy metals according to the CH food contact legislation as well as to the CH chemical risk reduction regulation could be detected. Therefore, also the requiremetns of EN 14350-2 are fulfiled. General Assessment Due to the evaluation based on the submitted documents and analytical tests the present product used as intended fulfils the requirements of the regulation (EC) 1935/2004 article 3. Under the normal and foreseeable use conditions the product specified above does thereafter not add components to food in quantities that are suitable to endanger the human health or to cause an untenable change of the composition. No phthalates were used according to the manufacturer’s documents. Therefore the requirements of the directive 2005/84/EC are fulfilled. This report exclusively refers to the analyzed samples. In the case of a change of the raw materials, the raw material composition of the product, the manufacturing process, the legal regulations or new toxicological realizations this evaluation loses its validity. References: - Commission Directive (85/572/EEC) of 19 December 1985 - Commission Directive 97/48/EC of 29 July 1997 - Framework Resolution ResAP (2004) 1 on Coatings intended to come into contact with foodstuffs, adopted by the Committee of Ministers on 1st December 2004 - FDA 21 CFR Parts 170 to 199 - Commission Regulation (EC) No 1895/2005 of 18 November 2005 - CH Regulation on Food Contact of 23.11.2005, version 12.12.2006 - CH-Chemical Risk Reduction Regulation (ChemRRV) of 18.05.2005, version 01.05.2007 - Regulation (EC) No 1935/2004 of the European Parliament and of the Council of 27 October 2004 - Commission Directive 2005/84/EC of 14 December 2005 - DIN EN 14350-2:2004 ——————————————————————— STS 038 ——————————————————————— SQTS - SWISS QUALITY TESTING SERVICES Dietikon, 25 February 2008 SQTS - SWISS QUALITY TESTING SERVICES Dr. Thomas Gude Head Food/Non-Food Division ——————————————————————— STS 038 ———————————————————————
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Categories: BPA, chemical safety, SIGG, water bottles

When it comes to “BPA-free,” consumers have nothing to fear but fear itself

The current status of bisphenol-A, which is teetering somewhere between near-unilateral corporate disavowal and a patchwork of outright bans, is what it is because we - parents, consumers, and part-time, practical activists - made it that way. That means we also have the power to decide what Health Canada's discovery of trace levels of BPA in non-polycarbonate bottles means to us. And the choice we make as consumers can have a big impact on whether there is a bright future ahead for "BPA-free."

We disagree with the argument that you should not be worried because the study is flawed. Yes, the study needs to be replicated. But our primary concerns - the apparent lack of a control and the lack of disclosure of detailed information - have both been cleared up. We now have all the data, an explanation of how they established a control group (in glass!), and the bottom line is, HC probably correctly identified that there are trace quantities of BPA in "BPA-free" products.

The question is, what does this mean?

In the week following the release of this report data we have seen some bloggers working to publicize it in as sensational a manner as possible. Worse, we have seen hardworking brands dedicated to providing the safest products possible declared to be liars who acted in bad faith by presenting BPA-containing products to consumers as BPA-free.

We don't see it that way, for a couple of reasons.

First, these levels are really, really, really small. The highest levels of BPA detected in non-polycarbonate plastics was under 2% of that found in polycarbonate, and that was found in pure water. In a 10% ethanol solution, which is more comparable to breast milk or formula, there was no detectable amount.

Second, non-polycarbonate bottles aren't the only place you wouldn't expect to find BPA, but will. Remember, this BPA probably came from dust present in the manufacturing facilities where the bottles were made. Trace amounts of BPA have been detected in drinking water (the Health Canada study corrected for it), and in human breast milk, not to mention infant formula (in higher quantities still). If you use recycled toilet paper, there is probably BPA in it, because there is BPA in the heat-sensitive paper used in credit card receipts, which is a significantly recycled paper product, and for all we know there could be BPA in dust in paper mills as well. It is the very ubiquity of harmful chemicals in our environment that make them, on the whole, so worthy of excommunication from the chemistry of our lives.

In other words, if a study that showed virtually every non-PC baby bottle on the market during lengthy exposure to fatty liquid simulants showing a complete non-detect for BPA has you worried, you're missing the forest for the trees.

We say all this from the perspective of people who have helped shepherd people through an intense period of consumer self-examination. After reporting for a while on BPA leaching from polycarbonate bottles, mainstream media interest and coverage of the issue picked up, and a couple of watershed announcements got everyone searching online for answers. At its peak we had parents emailing us daily telling us they could not sleep because they had poisoned their babies and asking how could they get the poison out. It got to the point where we spent more time reassuring people that their children were going to survive than we did recommending safer bottles and sippy cups. But when you're talking about sperm counts, anogenital distances, possible links to upticks in diabetes or other problems, the specter of an unknown relationship to long-term cancer risk, and effects on fish and wildlife, you are not talking about children being poisoned by their own parents, you are talking about a population and an environment that is being subjected to exposure to a chemical that should be swiftly retired from the scene.

For that reason, many activists, including Z Recommends, Non-Toxic Kids, Eco Child's Play, the Environmental Working Group, SafeMama, and many others, worked hard from the start to address this issue on all fronts: To encourage consumers to buy products that were not made with polycarbonate plastic or were free of BPA using widely-validated methods of detection; to pressure companies to educate themselves about chemicals in their products, to allow ZRecs to share that information with consumers, and to find alternatives to BPA-containing plastics, which were usually quite close at hand; and to tell Congress that we as consumers believed this substance should be legislatively removed from the market.

In that case, the mass parental freak-out had a net positive effect. Parents abandoned BPA-rich polycarbonate plastic in droves, migrated to new companies using safer plastics or to glass bottles, and their children are genuinely better off for it. And ultimately, companies decided it was not worth their time to battle for a plastic that parents didn't believe in anymore, and they gave it up.

But this time, it's different. If you, as a parent, choose to freak out about trace amounts of BPA found in bottles not made using it, at levels far below the sensitivity of any prior established testing method and far below the level banned by the country at the forefront of BPA regulation (Canada); if you choose to demonize companies that have tried to protect your children from BPA, and done a very good job of it; and if there are enough parents who join you in freaking out about it, you will make every company that went into BPA-free products and had the temerity to say as much wish they had never had anything to do with you. You will make them wish they had continued to ignore and defy and work around you until you got so disgusted with the so-called responsiveness of the free-market system to consumer choice that you fed your children out of borosilicate test tubes.

We have read a few breathless accounts of the demonic duplicity of companies like Medela, Born Free, and Adiri, who are now "not really" BPA-free, and to those with such misplaced hostility we say: What planet are you on? We'd suggest you - as a consumer, a parent, and an advocate for change - do the same. The same parents who led the charge for change in the marketplace (change that has come to us, by leaps and bounds, over the past year) have the power to say, We have realistic expectations and reasonable concerns.

And from the looks of it, that's where this situation seems headed. Parents are not (at the moment) freaking out about these trace readings - perhaps because they understand the data, or perhaps because Health Canada took such pains to explain that they weren't worried.

What BPA-free will ultimately mean


We believe the U.S. government, if and when it gets around to regulating estrogenic chemicals like BPA, will have to set levels of tolerance, not outright bans. Like lead, phthalates, and other chemicals we wish to regulate for the protection of human health, we must set a level of "free-ness" that will be a clear standard to which companies will be held. Otherwise, "free" will be a slippery term dependent on the capabilities of scientists to measure, rather than the ability of companies to perform up to established expectations.

Companies have a right to expect this kind of treatment, and companies that have taken the lead in providing BPA-free products should be prepared to be the leaders on this, too. Our job as consumers and activists is to let them know that we're ready to hear that conversation happen whenever it needs to happen, and we will continue to support the companies that have supported our needs and our concerns. If you agree, don't be shy about it. If others dogpile on companies whose commitment to providing safer products for your children has made a positive difference in your life, say so.

It will still be up to the scientists to determine what level of exposure to chemicals like BPA may cause harm. But we do not believe a zero tolerance approach is a practical response, and we also don't believe that "BPA-free" must mean zero tolerance now and to whatever decimal place technicians can arrive at, any more than "fat-free" means truly free of fat or "phthalate-free" means truly free of phthalates (in fact, it means it has less than 0.1%).

If additional testing confirms the trace levels of BPA found in these non-polycarbonate products, we will flag items in the ZRecs Guide to Safer Children's Products to alert parents to that fact, but with the caveat that we don't think these levels should currently be seen as a concern. Unless and until established and realistic levels for what "BPA-free" means indicate that a given product doesn't meet the standard, we will not be changing our labeling of these products in the ZRecs Guide from "BPA-free" to mark them as containing BPA. The levels are too low, and the results too uncertain, for that to be either useful to consumers or fair to companies.
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Categories: advocacy, baby gear, BPA, chemical safety

Breaking News: Health Canada to release detailed findings of controversial BPA study

Breaking News: Health Canada to release detailed findings of controversial BPA study
Photo by Inferis, shared via Flickr.
Early this evening, we concluded two days of dialogue with officials at Health Canada by securing a formal confirmation that the agency will release detailed information from the recently published study of Bisphenol-A migration in non-polycarbonate and "BPA-Free" plastic baby bottles, including the specific amounts detected by the testing matched to the specific brands of bottles tested.

We called for this move last week in an initial analysis of the study, and applaud Health Canada's decision.

To date, Health Canada has declined to release anything beyond the average levels of BPA migration for the entire set of non-polycarbonate bottles. The agency then released additional correspondence to a Canadian news agency under an Access to Information request and blacked out the names of two bottles being discussed for their surprisingly high levels of BPA.

Z Recommends has previously broken news regarding the presence of BPA in non-polycarbonate plastics, including feeding utensils and sippy cups, and maintains the ZRecs Guide to Safer Children's Products, an extensive directory of information collected from well-placed company representatives regarding BPA and other chemicals of concern in children's products.

The agency did not name a date for the release of this information, but a Friday release seems likely.

That won't be the end of this story, by a long shot. We're looking forward to continuing to contribute to the discussion and debate regarding what Health Canada's findings mean, and will save most of our thoughts until we can see how the data shakes out. Suffice to say for now that the fallout will be significant, there will be several major interest groups involved (beyond any number of bottle companies and government scientists), and there may be fewer companies claiming to make BPA-free bottles - or making bottles at all - when this is all over.
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Categories: baby gear, BPA, chemical safety

Minutes from the backroom BPA meeting between Coca-Cola, Alcoa, NAMPA, GMA, ACC, and Del Monte

Minutes from the backroom BPA meeting between Coca-Cola, Alcoa, NAMPA, GMA, ACC, and Del Monte
The Cosmos Club, site of the BPA strategy session. Photo by M.V. Jantzen, shared via Flickr.
Source: Milwaukee Journal-Sentinel. Backstory here.

Meeting Minutes
North American Metal Packaging Alliance, Inc.

May 28, 2009, 10:00 a.m. - 3:10 p.m. EDT
RE: BPA Joint Trade Association Meeting on Communications Strategy
Meeting Goal: Develop potential communication/media strategies around BPA

Discussion Topics: Consideration of available web-based communication options, including targeted geographies, as well as mainstream media response

Attending Companies: Coca-Cola, Alcoa, Crown, North American Metal Packaging Alliance, Inc., Grocery Manufacturers Association (GMA), American Chemistry Council, Del Monte

Summary: Attendees discussed the need to be more proactive in communications to media, legislators, and the general public to protect industries that use BPA, prolong the life of BPA, put risks from chemicals in proper prospective, and transcend the media and the blogosphere. Attendees believe a balance of legislative and grassroots outreach (to young mothers ages 21-35 and students) is imperative to the stability of their industry; however, the association members continue to struggle to initiate research and develop a clear-cut plan to defend their industry. The committee will spend approximately $500,000 to develop a survey on consumer BPA perceptions and messaging and eventually content and outreach materials. Overall, the committee seemed disorganized, and its members frustrated. Lack of direction from the committee and these associations could continue to allow other associations and environmental groups to push BPA out.

Other Points: Attendees suggested using fear tactics (e.g. “Do you want to have access to baby food anymore?”) as well as giving control back to consumers (e.g. you have a choice between the more expensive product that is frozen or fresh or foods packaged in cans) as ways to dissuade people from choosing BPA-free packaging. Attendees noted, in the past, the different associations have had a reactive strategy with the media, with very limited proactive outreach in reaching out to journalists. The committee agrees they need to promote new, relevant content to get the BPA perspective into the media mix. The committee believes industry studies are tainted from the public perspective.

The committee doubts social media outlets, such as Facebook or Twitter, will work for positive BPA outreach. The committee wants to focus on quality instead of quantity in disseminating messages (e.g. a young kid or pregnant mother providing a positive quote about BPA, a testimonial from an outside expert, providing positive video, advice from third party experts, and relevant messaging on the GMA website). Members noted traditional media outreach has become too expensive (they have already spent hundreds of thousands of dollars) and the media is starting to ignore their side. The committee doubts obtaining a scientific spokesperson is attainable. Their “holy grail” spokesperson would be a “pregnant young mother who would be willing to speak around the country about the benefits of BPA.”

Eventually, the committee concluded before deciding on the tactics to spread their messages, they need to develop the messages. The committees plan to fund a joint survey and message testing—what new messages they need to sell—before implementing a website and creating materials. Another task group will be implemented to finalize how to develop messages and aggressively use electronic media to deliver those messages.

Members noted the industry needs research on how perceptions of BPA are translating into consumer behavior—Is it translating into most moms not buying canned products or just a minority of moms? They hope to form messages relevant to how people live their lives—What does not having BPA mean to your daily lifestyle? Focusing on the impact of BPA bans on minorities (Hispanic and African American) and poor is also important. The members want to put the danger of BPA into perspective.

Legislatively, the committee is focusing on Connecticut and California. Committee members are meeting with as many representatives on the Health Committee as possible. The members are focusing on more legislative battles and befriending people that are able to manipulate the legislative process. They believe a grassroots and legislative approach is favorable because the legislators worry about how the moms will react. If the Connecticut bill goes through, the committee believes it will be a good opportunity to talk about the negative impact that ban will have on businesses and employment—How will it affect the union workers? The committee wants to put a proposal together for the right way to deal with legislative issues in each state.

The committee discussed Prop 65 in California—requiring the Governor to publish, at least annually, a list of chemicals known to the state to cause cancer or reproductive toxicity. The committee will form a coalition to write a submission about the benefits of using BPA by the deadline for submissions on June 30, 2009. Members will also build up their contact base in Sacramento. The committee does not want to win at the legislative level and then not have anyone to buy the product.

The committee questioned whether or not trade associations should challenge what is being said about BPA. Other trade associations for plastics have begun writing letters in response to “lies” being told about BPA. The committee proposed to be involved in the dialog and comment electronically and directly back to reporters. Attendees noted it does not matter what the next material is, there will be issues with it, and the committee wants to work to make people feel more comfortable with BPA and “BPA2” or whatever chemical comes next.

The committee suggested dividing the costs of the work and research equally by the members. The members are guesstimating it will cost at least $200,000 for the message testing and the survey and $500,000 for the entire project. The committee is also looking for new members to help with costs and outreach.
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Categories: BPA, chemical safety

Get ready for the BPA backlash

Get ready for the BPA backlash
Photo by stevendepolo, shared via Flickr.
Consumers have been abandoning BPA's miracle plastic, polycarbonate, by the droves, the biggest U.S. baby bottle manufacturers have promised to stop using it, and cities, counties, and states have begun passing bans (various NY counties; Minnesota; and now Chicago). But polycarbonate is just the tip of a great big BPA iceberg, as we've been reporting for a while now. A recent study suggests that BPA leaches from polycarbonate bottles not only when heated, as the baby bottle makers used to be so fond of assuring us, but even, and quite floridly, in cases when bottles are not used for hot liquids or washed in dishwashers. (Incidentally, we're guessing that the BPA iceberg itself is, in fact, the tip of another iceberg... and yes, it's icebergs all the way down.)

Consumers finally seem prepared to screw this logic to the sticking place. If BPA in polycarbonate is bad, then it must also be bad in epoxy resins in infant feeding utensils, infant formula packaging, baby food jars, canned goods, and even paper packaging. (You know the slick surfaces of those frozen entree containers? We (and others) can't say much about any particular paper food packaging, but I can guarantee you some of it uses BPA.) Connecticut looks ready to ban BPA in food packaging, with legislation on the governor's desk that would ban it by 2011 and require warning labels beforehand. The U.S. Congress is considering a federal ban on BPA in food packaging, baby bottles, and cups as well.

While the baby bottle and sports bottle companies have been able to shift gears without too much trouble, food packagers don't have it so easy. Some alternatives exist, but some foods pose more of a risk than others, implementation of any change would be costly, and any misstep could open a company to new liability if materials proved less reliable under the icky real-world stresses canned food can go through in its long journey from factory to table. Naturally, none of these companies were studying or investing in these alternatives when this issue was sitting on the burner on high, because hey, the water was kinda nice. Now that the issue is actually boiling over, and moms across America are buying frozen or fresh produce instead of the suddenly-sketchy canned stuff, food packagers are getting concerned. And what better way to communicate that concern, the North American Metal Packaging Alliance has sagely reasoned, than with a fear-mongering anti-anti-BPA PR campaign?

Some guilty soul in the industry slipped a reporter at the Washington Post the notes from an industry meeting outlining their planned response to the BPA-in-food-packaging crisis. Listen up, moms:

The notes said the executives are particularly concerned about the views of young mothers, who often make purchasing decisions for households and who are most likely to be focused on health concerns.

Those at the meeting held at the Cosmos Club "believe a balance of legislative and grassroots outreach [to mothers 21 to 35 years old and students] is imperative to the stability of their industry; however, the association members continue to struggle to initiate research and develop a clear-cut plan to defend their industry," an unidentified participant wrote.

Industry representatives weighed a range of ideas, including "using fear tactics [e.g. "Do you want to have access to baby food anymore?" as well as giving control back to consumers (e.g. you have a choice between the more expensive product that is frozen or fresh or foods packaged in cans) as ways to dissuade people from choosing BPA-free packaging," the notes said.

The attendees estimated it would cost $500,000 to craft a message for a public relations campaign, according to the notes. "Their 'holy grail' spokesperson would be a 'pregnant young mother who would be willing to speak around the country about the benefits of BPA,'" the notes said. [Link]


That's $500K for "crafting a message," folks. How much will the industry spend to insult us with it in print, on television, and online?

And how much would it cost to develop and roll out a viable alternative - one which was cleared in advance of any estrogenic activity, so Coca-Cola, Campbell's, and Gerber knew they were minimizing the chances of another issue like this cropping up three or five more years down the road?

I think my favorite part is where the Post quotes the note as saying industry leaders are primarily interested in "legislative battles and befriending people that are able to manipulate the legislative process." I'm pretty sure you wouldn't see such bald language even in the most nefarious progressive circles. Read the article for much more.
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Categories: BPA, chemical safety, politics

Results of the first ZRecs 50/50 Sale, and notes for the future

Results of the first ZRecs 50/50 Sale, and notes for the future
A few weeks ago we conducted an experimental sale of Thinkbaby's BPA Free Feeding Set, one of our favorite children's dish sets on the market, and called it retail advocacy. The model is simple: We host a sale of a limited number of products for a limited window of time, keep our profit margins tight to offer a good deal to consumers, and split the proceeds with a non-profit organization that does good work.

The portion we keep helps us to do the kind of reporting you turn to Z Recommends to provide - honest, thoughtful explorations of what's happening in industry and politics as well as unflinching product reviews, in-depth consumer research, and safety information. For this sale, we decided to do our 50/50 split with the Breast Cancer Fund.

After shipping costs, which were relatively high for this trial sale, we earned $381.84 on about 50 units sold. Half of that is $190.92, which we're thrilled to send to the Breast Cancer Fund on behalf of everyone who chose to purchase a feeding set from us. For us, this is just the first step - as far as we're concerned, it's just a drop in the bucket compared to what we can do as we improve on this system. We've begun outlining ways to streamline the process, to reduce our overhead, and to begin running sales on a more frequent basis, with our previous policies and procedures for publicizing the sale on our blogs in effect.

We've been considering a variety of products for our second sale, trying to select one we think a significant cross-section of ZRecs readers will be interested in and can't easily get at the price we can offer while still offering a fair return on what will be a money-down investment in product. We made up a short list of a dozen or so children's products we knew we could stand behind 100% - we already know the design of these products, inside and out, as well as hundreds (thousands?) of others that just wouldn't make the cut - and started running some numbers.

We knew that in addition to meeting our high expectations for materials safety, the product we selected had to be a great value, easy to package and ship, and an innovative product that commanded attention for all the right reasons. We ruled out some products because of their minimum retail pricing, others because they're for little babies and we think our readership trends towards toddlers. In the end, there was one clear standout - two more of the best products we've seen since we launched Z Recommends and began reviewing products over two years ago, from a company that has been at the forefront of both safer plastics and innovative design for children.

We'll have a firmer date soon on when we'll launch the second ZRecs 50/50 sale, and can't wait to tell you about it, as well as the charity we'll be donating 50% of the proceeds to.

Thanks again to everyone who made our first ZRecs 50/50 sale a success for both ZRecs and the Breast Cancer Fund!
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Categories: BPA, chemical safety
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