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1. What independent, third-party agency certified your product to be biodegradable?
Several independent agencies in the U.S. and Canada test formulated products and ingredients to certify biodegradability claims. To be certified “Biodegradable” all components of a product must be documented as degradable by microorganisms into simple substances – carbon dioxide, water and minerals – under aerobic conditions. Guideline test methods are provided in the Code of Federal Regulations (CFR) 40, Subpart D, 890.3100-3400, US Environmental Protection Agency.

The claim “100% Biodegradable” is being widely used on many products that do not qualify for independent certification because one or more ingredients cannot meet the specified test parameters. Well-known and respected independent certification agencies in North America include Scientific Certification Systems (Green Cross), Green Seal, and the Environmental Choice Program (ECP) in Canada. When you see the symbol of one of these certifying agencies on a label, you can be sure the product is actually biodegradable.

2. What documentation do you have to support the claim that the product is “environmentally safe”?
The U.S. Federal Trade Commission has established guidelines for the use of environmental marketing claims. Section 5 of the Federal Trade Commission Act makes it unlawful to use deceptive acts and practices in commerce. Any party making a direct or indirect claim about the environmental attributes of a product must, at the time the claim is made, possess evidence to support the claim. In the context of environmental marketing claims, such support will often require reliable scientific tests, analyses, research or studies using procedures generally accepted in the profession to yield accurate and reliable results. Thus any company making a claim of “environmentally safe” must be able to provide documentation to substantiate the claim.

3. Does your product contain any known or suspected carcinogens?
Formaldehyde is an ingredient of many RV holding tank treatment products. It has appeared on the National Toxicology Program Report on Carcinogens as a probable cancer causing agent since inception of the program. It has also been recognized as a probable cancer causing agent by the International Agency for Research on Cancer (IARC) for more than 20 years. The primary routes of human exposure to formaldehyde are inhalation and through skin contact, both of which are factors in RV holding tank treatment applications.

4. Does your product contain any known formaldehyde derivatives or components that can break down into formaldehyde under any circumstances?
In addition to being a possible carcinogen, formaldehyde is an microbiocide which kills bacteria. When heated, paraformaldehyde releases formaldehyde.3 Bronopol may release formaldehyde in aquaeous solutions, especially at warmer temperatures or higher pH’s.

Bacteria are necessary for the proper functioning of septic tanks and septic systems. Holding tank wastes treated with formaldehyde or related compounds when discharged to home septic systems or campground or dump station septic systems may disrupt the functioning of a septic system, cause drainfield clogs, or may lead to costly repairs or replacement of the system. Malfunctioning septic systems can contaminate ground water, surface water or soil.

5. Does your product contain any other disinfectants, preservatives or microbiocides?
As mentioned above, disinfectants or microbiocides kill friendly bacteria along with odor-causing and disease-causing bacteria. Friendly bacteria are necessary for the proper functioning of septic systems. This is a primary concern if wastes are dumped at stations in campgrounds and RV parks that are on septic systems or if wastes are dumped into home septic systems. Formaldehyde, bronopol, 1-(3-chloroallyl)-3, 5, 7-triza-1azoniaadamantane chloride and quarternary ammonium compounds are all biocides or preservatives.

6. Does your product contain any nitrates?
In 1974 Congress passed the Safe Drinking Water Act. This law requires EPA to determine safe levels of potentially harmful chemicals in drinking water. Maximum contaminant level goals have been set for nitrates/nitrites because of the possible health risks and exposure risk of these contaminants in drinking water. Short term exposure to excessive levels of nitrate in drinking water can interfere with the oxygen-carrying capacity of children’s blood and cause serious illness. Long term exposure can cause hemorrhaging of the spleen. According to the federal EPA, nitrates and nitrites are very soluble and do not bind to soils. Therefore, they have a high potential to migrate to ground water. Because they do not evaporate, nitrates/nitrites are likely to remain in water until consumed by plants or other organisms.

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