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Good Healthy Competition

June 23, 2015 by  
Filed under HDOX IS GOOD.

It has come to our attention that our competition is a bit unhappy with us. They are using our logo and product information in their sales pitch now (which is a trademark and copyright mess that I would think they want no part of). The following are some of their “facts” and the cold hard truths.

Section 1: Effluent
Their Claim

Recently a competitor has made the claim that Peroxy HDOX is in violation of EPA regulations and it cannot be dumped down the drain. This statement is false and misleading. They focus on the “Environmental Hazards” section of the product label which reads as follows:
“Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System [NPDES] permit and the permitting agency has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance, contact your State Water Board or Regional Office of the EPA.” (Earth Laboratories, 2008)

Their claim is that this means you cannot dump more than 1 gallon of this product in use dilution down a drain.

The Facts

In 1993 the EPA set a requirement that any manufacturing or end use product must contain the following standardized statement on any product container.
“Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System [NPDES] permit and the permitting agency has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance, contact your State Water Board or Regional Office of the EPA.” (United States Environmental Protection Agency, 1993)

Because manufacturers had trouble fitting all of this onto small containers, in 1995 the EPA updated this by saying:

“Effective immediately, the scope of P.R. Notice 93-10 is revised to exempt end-use products in containers of less than 5 gallons…” (United States Environmental Protection Agency, 1995)

Because Peroxy HDOX is primarily sold in bulk (55 gallon drums, train tankers, etc.) to factories and other OEM customers, this notice was placed on the packaging as required by the EPA. When Earth Laboratories decided to bring this product to the wholesale cleaning market and began packaging it in 1 gallon containers, the warning was not removed, although it could have been.

Furthermore, on the same label that they are cherry picking this information from it clearly states
“Wastes resulting from the use of this product may be disposed of on site or at an approved waste disposal facility.” (Earth Laboratories, 2008)
Please see attached supporting EPA documents.

Section 2: Warning Statements

Their Claim

This competitor has also taken information from an out dated MSDS hazards section in an attempt to make the product look dangerous. The section they refer to is:
“Effects of Overexposure – Conditions to Avoid Causes eye irritation: Symptoms may include pain, redness, swelling and possible tissue damage. Causes skin irritation: Symptoms may include pain, redness, and swelling. May be harmful if swallowed: Symptoms may include nausea, vomiting, pain and diarrhea. Breathing product may cause respiratory irritation: Symptoms may include coughing and difficulty breathing. Do not get in eyes, on skin, or on clothing. Avoid breathing product mist. Do not swallow. Use with adequate ventilation. Wash thoroughly after handling.” (Earth Laboratories, 2006)

The Facts

This is a common warning on a concentrated chemical MSDS. The new SDS regulations properly show warnings and pictograms in a universal way. The SDS for Peroxy HDOX shows the hazards using GHS standards, and it shows:
“HAZARD CLASSIFICATIONS: Serious eye irritation. Category 2A.” (Earth Laboratories, 2015)
Category 2 means that it causes:
“Reversible adverse effects on cornea, iris, conjunctiva” (United States Occupational Safety & Health Administration, 2015)
Subcategory 2A classifies it as:
“Irritant” (United States Occupational Safety & Health Administration, 2015)

Section 4: First Aid Measures for Peroxy HDOX reads:

“Inhalation: Remove victim to fresh air & keep at rest in a position comfortable for breathing. Get medical advice / attention if you feel unwell.
Skin: Wash skin with soap and water. Take off contaminated clothing and wash before reuse. If skin irritation occurs: Get medical advice / attention.
Eyes: Rinse cautiously with water for several minutes. Remove contact lenses if present and easy to do – continue rinsing. If eye irritation persists: Get medical advice / attention.
Ingestion: Rinse mouth. Do NOT induce vomiting. Get immediate medical advice / attention.” (Earth Laboratories, 2015)
This language is part of the new GHS standard and more accurately describes the dangers.

Section 3: Too Good To Be True

Another dubious statement made by a broker for this competitor is that Peroxy HDOX is “Too good to be true”. While we appreciate this praise about how good our product is, it implies that there is some hidden dark truth about Peroxy HDOX. In order to be EPA registered Peroxy HDOX had to divulge all components, even the trade secret ones, and be reviewed thoroughly for hazards. It is undoubtedly what we claim it is, and it is undoubtedly EPA registered as a Sanitizer, Virucide, Fungicide, Disinfectant, Deodorant, and Cleaner. Earth Laboratories, Inc. has been completely forthcoming with ingredients to the EPA, our HMIS has not changed, and with the new GHS regulations our Hazard Classification has not changed.

To ensure that you can trust our word, we will do our best to never mention, allude to, or give disinformation to you, our customers — with regard to our product or anyone else’s.

Works Cited
Earth Laboratories. (2006, April 4). Products. Retrieved June 17, 2015, from Earth Laboratories Inc.: http://www.earthlaboratories.com/products
Earth Laboratories. (2008, May 22). Peroxy HDOX Label. Evansville, IN, USA.
Earth Laboratories. (2015, June 1). SDS. Retrieved June 17, 2015, from HDOXinfo.com: http://www.hdoxinfo.com/#!msds/cl0n
United States Environmental Protection Agency. (1993, July 29). PRN 93-10: Effluent Discharge Labeling Statements. Retrieved June 17, 2015, from EPA.Gov: Division, Registration. “EPA.” PRN 93-10: Effluent Discharge Labeling Statements. United States Environmental Protection Agency, 29 July 1993. Web. 17 June 2015.
United States Environmental Protection Agency. (1995, May 1). PRN 95-1: Effluent Discharge Labeling Statements. Retrieved June 17, 2015, from EPA.Gov: http://www2.epa.gov/pesticide-registration/prn-95-1-effluent-discharge-labeling-statements
United States Occupational Safety & Health Administration. (2015, June 1). A Guide to The Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Retrieved June 17, 2015, from OSHA.Gov: https://www.osha.gov/dsg/hazcom/ghs.html#3.0

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