legislation

Legislation, environment & sustainability

Managing the legality and sustainability our products and business is massively important to Holchem.

Our commitment to producing safe products is supported by comprehensive management systems that reflect legal and regulatory compliance as a minimum standard, and cover raw material use and product assessments, labelling and packaging requirements.

Legislation

Cleaning products in Europe are regulated by many pieces of legislation usually enacted from European Regulation. Some of the legislation includes, but not exclusively:

  • Detergent Regulations: 2004/648/EC
  • CLP: Classification Labelling and Packaging Regulation: 1272/2008
  • REACH: Registration, Evaluation, Authorisation and restriction of Chemicals: EC 1907/2006
  • BPR: EU Biocides Regulation: 528/2012
  • The Cosmetic Products Enforcement Regulations 2013

 

Our commitment to producing safe products is supported by comprehensive management systems that reflect legal and regulatory compliance as a minimum standard, and cover raw material use and product assessments, labelling and packaging requirements. We seek to ensure product safety, customer satisfaction and legislative compliance by:

  • Assessing products before launch in internal and, in certain cases, external technical evaluations to ensure compliance with all known legislation in the countries of use. This includes Human Safety and Environmental Impact assessment requirement under CLP for most cleaning products and Human Safety requirements under Cosmetic Products Enforcement Regulations 2013 for hand hygiene products.
  • External testing against European Norms for surface disinfectants and hand hygiene products
  • Provision of product information through labelling, product information sheets (PI) and safety data sheets (SDS)
  • Providing access to emergency information through our 24/7 emergency telephone number +44 (0) 7050 265597
  • Updating of the National Poisons Information Service (NPIS) with all product SDS
  • We have a policy of not testing products on animals, or requesting testing of products or ingredients by any supplier or third party

 

Product Design

Environmental protection centres on the product itself, and product stewardship requires all involved in its lifespan to reduce any related environmental effects. At Holchem, we always look to reduce our impact on the environment and continually work to reduce the impact of our operations and products.

The majority of our 400 liquid product formulations are provided as concentrated products requiring dilution at the point of use at between 1% and 5%.  By optimising our products to deliver enhanced cleaning power but with less effect on the environment, Holchem have been able to ensure our customers see the same, or improved, high quality level of clean, reduced impact of the products on the environment, whilst at the same time lessening the cost of the overall clean.

 

Green Chemistry

The concept of environmentally friendly chemicals, green chemistry and reduced environmental impact is complex.  The key point to remember is that detergents and disinfectants, we produce, are heavily regulated by instruments such as Detergent Regulations, the Biocidal Products Regulation and REACH; all of these regulations aim to enhance environmental protection.  However, Holchem can show many examples of our commitment to reduced environmental impact often prior to legislation. For example Triclosan has been used for many years as a biocide or preservative in hand soaps and personal care products such as toothpaste.  Triclosan has a poor environmental profile and tends to bioaccumulate.  In 2010 Holchem implemented a programme of removing Triclosan from hand care products produced in our plant. Subsequently in 2016, implementing decision published by the European Commission states Triclosan (EC No 222-182-2, CAS No 3380-34-5) is not approved as an active substance for use in biocidal products for product-type 1 (disinfectants for human hygiene).

 

Roundtable on Sustainable Palm Oil (RSPO)

The RSPO was established in 2004 to promote the production and use of sustainable Palm Oil for People, Planet, and Prosperity. The RSPO has developed a set of environmental and social criteria which companies must comply with in order to produce certified Sustainable Palm Oil. When applied the criteria can help to minimise the negative impact of palm oil cultivation on the environment and communities in palm oil producing regions. Our associate membership as Holchem forms an important part of our environmental statement. It means that any palm oil derived surfactants we buy are supported under sustainable sourcing. We are constantly evolving and implementing our policies and are particularly pleased to be part of the RSPO.

 

Biodegradability

Biodegradability only applies to organic materials, i.e. those based on carbon.  A significant proportion of the raw materials used in detergents are inorganic (for example acids and alkalis).  Although these will be broken down by neutralisation processes they cannot biodegrade.  Many misleading claims are made around biodegradability.

Surfactants are widely used in detergents.  To comply with the EU the Detergents Directive (684/2004 and amendments) all surfactants must be biodegradable.  Indeed even biocides that are designed to kill micro-organisms and thus have an environmentally hazardous classification must be biodegradable.

 

Natural Products

Holchem, like a majority of the detergents industry uses surfactants derived from Palm Kernel Oil (PKO). Palm oil is a highly efficient producer of oil per hectare of cultivated land. Holchem requests that all our suppliers of surfactants have an ethical policy towards PKO and support the Roundtable on Sustainable Palm Oil (RSPO). The RSPO has developed a set of environmental and social criteria which companies must comply with in order to produce Certified Sustainable Palm Oil (CSPO). When they are properly applied, these criteria can help to minimize the negative impact of palm oil cultivation on the environment and communities in palm oil-producing regions.

Routinely Holchem screens surfactants from non-PKO sources, for example Sugar, Rapeseed Oil, Soya, or Wheat. All of these sources require land and therefore impact food production, so ethically do not stand up as environmentally friendly alternatives to PKO. It is also possible to use petroleum derived materials; but this is not sustainable.

 

Heavy Metals & EDTA

The traditional method of manufacturing Sodium Hydroxide is by electrolysis using a Mercury Electrode; the result is that there would always be trace heavy metal in the final product.  In 2007 Holchem made the decision to only source Sodium Hydroxide manufactured by the newer Membrane technology.  Since then we have not sourced Mercury grade material for our plant.

EDTA is an essential component of many detergents; it provides scale control in hard water areas and aids the removal of mineral components of soils.  EDTA has a poor biodegradability profile.  Holchem have a policy of ensuring that the levels of EDTA used in products are kept to a minimum.  In some products, we have replaced EDTA with a newer biodegradable alternative. Eventually we will no doubt replace all EDTA, but today we have to manage supply availability of the newer materials.

 

Non-Chemical Cleaning

The concept of chemical free cleaning has to be considered with great care, everything (even water) is a chemical.  However Holchem have a number of biological cleaners in our range. These use the minimum amount of chemical needed to create the right environment for benign bacillus bacteria to destroy soiling.

 

Chemical Miles

We source locally, wherever possible, the raw materials we use in our formulations, with many of them such as caustic soda, sodium hypochlorite and quaternary ammonium compounds sourced within 30 miles of our production facility. The concept of Chemical Miles considers the distances involved in bringing raw materials to our factory.

 

Production

Our purpose-built designed facility at Gateway House, Bury in Lancashire is a modern, low impact facility across 105,000 square feet, fully optimised for the safe handling and processing of hazardous chemicals (complying with Top Tier COMAH) and operates to the Environmental Management System ISO 14001:2004

 

Packaging

By reusing 25 litre kegs, drums and IBC’s as well as palletised containers, we go further than solely meeting our obligations under legislation and minimise the impact of packaging as much as we can. Typically Holchem recycles more than 195,000 plastic kegs/year. We do this by encouraging our customers to return empty and rinsed storage containers, which then allows us to fully launder and reuse them.

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