Jacqueline Claudia talks with Earth911 on data-driven technology to optimize retailer recycling

As you dig yourself out of that post-holiday workload this week -  we invite you to take a quick pause and join us on a journey that began during Thanksgiving week. In our SmarterX internal company chat, a seemingly trivial question about gravy ignited a discussion that led us on a somewhat ridiculous but undeniably important exploration.

Who defines if gravy is a liquid or a solid? What is the basis of that definition? When you pick up a gravy product, where did it come from? And how does where it comes from impact its value or characteristics? How does all of that impact how it’s handled across the supply chain? Each tablespoon of gravy - as with any product - comes with a million questions and answers.

These questions aren't just about gravy; they're about the very essence of products and substances we encounter every day. We had some laughs along the way, but we promise - our explorations will get you thinking 🧠: 

It all began with a simple question: ‘What is gravy?’ 

Some of us asked ChatGPT directly. If you’re wondering about it’s traditional, textbook definition, here ya go: 

Gravy, traditionally understood as a sauce made from the thickened and seasoned juices of cooked meat, has a rich history in the culinary world. This definition is consistent across various sources, with the Cambridge English Dictionary describing it as a sauce made with meat juices and flour, served with meat and vegetables. The Collins English Dictionary adds that it can also be a sauce made by thickening and flavoring the juices that exude from meat during cooking. Similarly, Dictionary.com defines gravy as the fat and juices that drip from cooking meat, often thickened and seasoned, and used as a sauce for various dishes. Wikipedia expands on this by noting that it's often made from the juices of meats that run naturally during cooking and thickened with substances like cornstarch for added texture.

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Does that bore you? Yeah, us too. So we went deeper.

As we dove in as a team, we quickly found that the  diversity of products labeled as "gravy" in our own database at SmarterX added several extra layers of intrigue to the discussion.

Gravy is not just a simple sauce; it's a product with a rich and varied history, different types, and more. It can be found in various forms, from pet care products to warm sauces, and it even blurs the line between food and pharmaceuticals. ‍

‍Team members from across the organization got creative leveraging Artificial Intelligence to shape and mold our data on gravy. It started with our SmarterX data on ~4000 products tagged as 'gravy' in our systems... and evolved from there.

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The Gravy Classifier ---> Visualizing  the “WHAT” of’ what is gravy?’

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Within minutes, ChatGPT could determine whether a product in the database was gravy or not, based on simply the product’s name and item type. While we went down several interesting rabbit holes on gravy as a team afterwards - the core message was clear: Something - a substance, a product - is gravy simply because we say "IT'S GRAVY". 
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Then word clouds, bar charts, and pie charts were generated to visualize the distribution of gravy products and item types by supplier, the breakdown of gravy products that are liquid vs. solid - and more. Making the data more accessible and engaging.

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Gravy at Thanksgiving - A data story.

It was starting to become obvious from the data that gravy was a lot more than Thanksgiving side dish. In fact, we started to see a trend showing that gravy was often NOT something you'd ever serve at thanksgiving. And we asked for some visuals on it... but at first, ChatGPT got it wrong. (Tell us if we're crazy... but would YOU serve dog food at Thanksgiving!?) 

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So, we tried again. Using the typical "consumer(s)" of the product as a way to more accurately categorize if a product can and should be served at Thanksgiving.

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New product development: 'Universal Gravy'

Now we started thinking.... how can we use this data to envision a BRAND NEW type of gravy product? The concept of "Universal Gravy" was introduced, a gravy product for all of these consumers (including pets?). The final result?: Universal Gravy: Bringing Family and Pets Together.

PRODUCT DETAILS
UPC: 99999999999 Product Name: UNIVERSAL_GRAVY Supplier: Global Flavors Inc. Item Ingredients List: beef stock, chicken stock, onion, garlic, soy sauce, spices Item Type: Gravy Physical Form: Liquid Serve at Thanksgiving: Family Number of Ingredients: 6
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Gravy, but make it... healthy? 

Then we wanted to know... which gravy product is the most health for our families this Thanksgiving holiday? If you're worried about that kind of thing. As it turns out: Fancy Feast cat food is your best bet. We'll skip it, but it was still interesting to look at the comparison of two of the leading human gravy products.

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The future of gravy

And, finally, we dove into the potential future of gravy. Based on what we know about gravy today - what could the gravy product and how they exist in the future look like? 

Can we make gravy in a more sustainable and less expensive way? And, in the wake of climate change, will how we look at the consistency of gravy change as the world warms? Is this is ridiculous thought, or is there some validity to it? In a consistently warmer climate, could most solid foods become liquid, effectively turning the entire food ecosystem into gravy? This intriguing thought raises questions about how climate change might reshape how we think about and handle goods.

In asking ChatGPT to come with some future concepts for how these gravy products might exist in our future world, we got come fascinating concepts and visuals.

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While we went down several interesting explorations on gravy as a team, one thing was clear: What began as a simple question about gravy evolved into a captivating journey through why we identify products and classify products certain ways. The multitude of information that can be derived from product data if you ask the right questions.

So.... what should we ask next? 

Recent regulatory changes, specifically the Resource Conservation and Recovery Act (RCRA) guidance for hand sanitizers and the new hazardous waste regulations in California, are sparking changes across the industry. Here are a few key takeaways and guidance on how to chart these regulatory waters.

It's important to stay vigilant in understanding and complying with these  regulatory changes. But remember -- we're here to chart these waters with you and for you. Reach out to our team at any time with questions at regulations@smarterx.com  

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Understanding RCRA and Hand Sanitizers

The U.S. Environmental Protection Agency (EPA) has revised its stance on the RCRA industrial ethyl alcohol exemption as it relates to alcohol-based hand sanitizers. The previous interpretation treated unused alcohol-based hand sanitizer as regulated hazardous waste but this is now likely to change, with the EPA allowing generators of unused alcohol-based hand sanitizer to consider energy recovery as a disposal path.

• In the wake of possible changes, retailers should confirm their disposal practices comply with TTB and EPA regulations. The Alcohol and Tobacco Tax and Trade Bureau (TTB) regulations apply to recycling of industrial ethyl alcohol. Therefore, retailers should make sure their disposal partners abide by these rules. If unused alcohol-based hand sanitizer is being recycled then the generator must comply with the RCRA legitimacy factors in 40 CFR 260.43.

• For suppliers, make sure to evaluate your disposal process. Unless you are managing unused alcohol-based hand sanitizer as RCRA regulated hazardous waste,  the material must be treated as a valuable commodity when it is under your control. Additionally, you should ensure that your waste hauler understands whether the material is hazardous waste or intended for reclamation. The latest EPA interpretation, published May 5 2023, allows generators of unused alcohol-based hand sanitizer to  consider energy recovery. Reclaimed ethanol can be used as a fuel or fuel additive and can be burned for energy recovery within the U.S., as long as all applicable TTB regulations and RCRA legitimacy factors are complied with throughout the reclamation process. 

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Navigating California’s New Hazardous Waste Regulations

In response to California Senate Bill 158, the Department of Toxic Substances Control (DTSC) will now be developing new Hazardous Waste Management Reports and Plans every three years. The bill's primary goals are to establish a baseline understanding of hazardous waste management, identify data gaps, and make plans to fill these gaps.

• With this process change in mind, retailers should take the time to engage with it. You have the opportunity to provide input during the planning process, which may be a valuable chance to express any concerns or potential impacts to business operations. Also, stay updated! Keep abreast of legislative updates, especially regarding potential changes in waste management hierarchy, as it could affect the strategies to reduce hazardous waste generation.

• For suppliers, take the time to align your operations. The new regulations emphasize waste reduction, recycling, and treatment before disposal. Suppliers must ensure their operations align with this hierarchy. Also, participate in and prioritize data collection. As the DTSC seeks to fill data gaps, suppliers may have the opportunity to contribute meaningful data and potentially influence the direction of future waste management strategies in California. And finally, plan for stricter standards. With less than 19 percent of hazardous waste tracked in California classified as hazardous under federal criteria, expect California's regulations to be stricter. Suppliers should be prepared for more stringent rules and broader scopes of hazardous waste identification.

Let’s face it – CPG regulations can be convoluted. They are often (necessarily) filled with complexity and nuance that don’t make it easy to decipher how exactly they may affect you and the products you sell. 

We know how important it is for you to stay up-to-date with anything that could impact your business. That's why we're here to fill you in on some interesting updates that we're keeping a close eye on. These recent updates cover four main areas: DOT PHMSA International Harmonization (HM-215Q), Vermont HB 67, and Washington SB 5144, and MOCRA. So, let's dive in.

DOT PHMSA International Harmonization (HM-215Q)

Get ready for some positive changes: The Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) has proposed a rule (HM-215Q) that will make your life easier. The new rule was proposed in May, and is likely to be finalized by EOY. Here's what you need to know:

• Button cell batteries: Good news. You'll still need to test button cell batteries installed in equipment, but you won't have to worry about sharing the Test Summary (TS) report anymore. It's a small change, but it means less paperwork and more streamlined compliance for you.
• Lithium battery markings: Say goodbye to the phone number requirement on the lithium battery mark. This simplification will make labeling lithium batteries easier and removes confusion from the supply chain. 
• PSN and ID8000 updates: There are a few minor updates to the Proper Shipping Name (PSN) and ID8000. These updates will help you properly identify and ship hazardous materials. It's essential to stay informed about these changes to ensure you're on the right track when it comes to shipping regulations.

Vermont HB 67

‍Vermont has some interesting legislation in the works, and it's something you'll want to pay attention to. The legislation was delivered on May 12th and comes with 2025 implementation dates. Here's the lowdown:

• Funding the HHW program: The new law would require manufacturers and brands to step up and fund the Household Hazardous Waste (HHW) program in Vermont.
• Increased responsibility on the consumer for haz-waste vs. non haz-waste: This change could mean that the distinction between Haz-waste and Non-haz-waste would be as important to consumers, waste management entities, recyclers, and brands as it is to Retailers.
• Waste handling fees and brand responsibility: The legislation allows for waste handling fees, which will be redistributed to brands, and is typically based on their market share. Orphaned products (products without a brand owner) would be collectively covered by participating brands. 
• Exemptions and special considerations: The law includes exemptions for certain products like pesticides, cosmetics, drugs, certain paints, and already covered electronics and batteries. Make sure you're aware of these exemptions to avoid any compliance headaches. 

Washington SB 5144

‍Washington has also got some new regulations coming your way. The legislation was signed on May 11th by the governor, with 2027 implementation dates. Here's the scoop:

• Battery stewardship plan: If you are a “producer”of covered batteries or products containing them, you'll need to participate in a state-approved battery stewardship plan. It's all about responsible management and ensuring proper recycling and disposal.
• Who's a producer? The law broadly defines a producer as battery manufacturers, retail brands, third-party brands, licensees of a brand, importers, or anyone selling the product in the state. It's an inclusive, hierarchical definition to ensure accountability throughout the battery supply chain.
• Battery markings and compliance: although coming into force at a later date, “producers” shall supply, and retailers must collect, a certification that the covered batteries have the required "producer" marking along with the battery chemistry. Lawmakers are placing primary responsibility on the producer, but also require due diligence from retailers.

FDA's Modernization of Cosmetics Regulation Act of 2022

‍Although published at the end of 2022, there’s significant regulatory change coming that impacts the cosmetics industry:

• FDA regulations for fragrance allergen rules: The FDA is mandated to promulgate regulations for allergen rules within 18 months of December 29, 2023. Keep an eye out for these regulations to ensure your products comply with the new requirements.
• Fragrance allergen ingredient disclosure: Once the list of fragrance allergens is finalized, brands and manufacturers must disclose these allergens on the cosmetic product label . This means you may see changes in product labeling and information provided to customers.
• Does label disclosure equal FDA disclosure? While label disclosure is an important part of complying with FDA regulations, producers of cosmetic products must also register with the FDA and submit a Cosmetic Product Listing, which includes “...a list of ingredients in the cosmetic product, including any fragrances, flavors, or colors, with each ingredient identified by the name, as required under section 701.3 of title 21, Code of Federal Regulations (or any successor regulations), or by the common or usual name of the ingredient”.  Will this disclosure of information to the FDA be the same information required on the product label? The answer will impact the logistics of information transparency in the supply chain.

Staying informed about regulatory updates doesn't have to be overwhelming. These updates are here to make your life easier. So stay in the loop, adapt your processes as needed, and reach out to our team of experts with questions at any time, and check back next month for more updates.