Maine Healthy Children's Project
March 30, 2015
Dear Mr. Turenne and Mr. Graham,
The Learning Disabilities Association of America (LDA) appreciated the opportunity to meet with you and your colleagues last September in person, and more recently in February 2015 by phone. Our organizations - LDA, Autism Society, The Arc and National Down Syndrome Society - are pleased to hear that Walgreens is developing a Chemical Sustainability Program to address toxic chemicals in the products you sell, and that you expect to announce the policy this spring.
We are especially concerned with chemicals that can negatively affect brain development, and with the great vulnerability of children, starting in utero, to harm from even low levels of toxic chemical exposures such as endocrine disruptors. Many of these chemicals are found in cosmetics and personal care products, toys, baby items and cleaning supplies – all product categories sold by Walgreens and marketed to women of childbearing age.
As the country’s largest pharmaceutical chain, Walgreens is in a unique position to lead the industry with the development of a chemicals policy that is health-protective, comprehensive, and forward-looking in terms of not allowing the substitution of one harmful chemical for another. We believe the policy should particularly scrutinize chemicals that build up in the food chain and people (and in babies and breast milk), and are toxic to human health. We are hopeful that Walgreens’ new chemicals policy will address not only private label but also brand name products, to truly protect your customers from toxic chemical exposures.
Our organizations are glad to hear that you are making this issue a priority, and we understand that you are studying the Boots’ Restricted Substance List, to ensure that chemicals of high concern are identified and avoided. We also encourage you to consider the Hazardous 100+ List of Chemicals of High Concern, as well as chemicals that other major retailers are prioritizing for action, such as the chemicals that Target and Walmart are asking suppliers to address.
We urge you to consider the BizNGO Principles for Safer Chemicals that the Mind the Store campaign has shared with Walgreens:
· Know and disclose product chemistry. Manufacturers will identify the substances associated with and used in a product across its lifecycle and will increase as appropriate the transparency of the chemical constituents in their products, including the public disclosure of chemicals of high concern. Buyers will request product chemistry data from their suppliers.
· Assess and avoid hazards. Manufacturers will determine the hazard characteristics of chemical constituents and formulations in their products, use chemicals with inherently low hazard potential, prioritize chemicals of high concern² for elimination, minimize exposure when hazards cannot be prevented, and redesign products and processes to avoid the use and/or generation of hazardous chemicals. Buyers will work with their suppliers to achieve this principle.
· Commit to continuous improvement. Establish corporate governance structures, policies and practices that create a framework for the regular review of product and process chemistry, and that promote the use of chemicals, processes, and products with inherently lower hazard potential.
· Support public policies and industry standards. Advance the implementation of the above three principles, ensure that comprehensive hazard data are available for chemicals on the market, take action to eliminate or reduce known hazards and promote a greener economy, including support for green chemistry research and education.
These principles are key features of an effective strategy for promoting, developing and using chemicals that are environmentally preferable across the entire lifecycle.
We would be happy to assist in any way, or to further share our perspectives. We are confident that Walgreens’ leadership on this issue will result in a robust chemicals policy starting this spring that especially safeguards pregnant women and children. We thank you for your attention at the highest levels to this critical issue.
Scott Badesch, President, Autism Society
Nancie Payne, President, Learning Disabilities Association of America
Sara Hart Weir, President, National Down Syndrome Society
Peter V. Berns, CEO, The Arc
Joan Teach, Board President, Learning Disabilities Association of Georgia
Lori Perkins, CHADD Chapter Coordinator, Children and Adults with ADHD of Georgia
Cheri A. Crowe, President, Learning Disabilities Association of Greater Baltimore
Beverly Holden Johns, President, Learning Disabilities Association of Illinois
Montie Stone, Executive Director, Kids Enabled
Tracy Gregoire, HCP Coordinator, Learning Disabilities Association of Maine
Loreena D. Parks, HCP Coordinator, Learning Disabilities Association of Michigan
Martha Moriarty, Executive Director, Learning Disabilities Association of Minnesota
Kristina Scott, President, New Hampshire Learning Disabilities Association
Francesca Sommer, Executive Director, Learning Disabilities Association of New York State
Linda Modenbach, Board President, Learning Disabilities Association of Oklahoma
Dr. Joy S. Marsh, State President, Learning Disabilities Association of Tennessee
Deanne Shields, President, Learning Disabilities Association of Utah
This letter is addresesed to:
Alain Turenne, Div VP of Corporate Social Responsibility & Product Integrity
Jim Graham, Senior Manager of Corporate Media Relations
FMI, check out our Walgreens page