Rite Aid

Policy:Adopted a retailer safer chemicals policy

16.5 out of 23.5 points

Rite Aid launched a Chemicals Policy in September 2018. In an updated version of the policy posted on its website in early 2021, the company states “Rite Aid is committed to working with our supplier partners on the safe management of toxic chemicals to ensure the products we sell are safe and healthy for our customers and the environment.”

Rite Aid has set public, quantifiable goals for reducing and eliminating CHCs in its products and has created a BRSL for its own-brand formulated products. The company stated in the November 2019 version of its policy: “In 2016, Rite Aid committed to eliminating eight chemicals of high concern from its private brand formulated products by 2020. These chemicals include: triclosan, propyl paraben, formaldehyde, dibutyl phthalate, toluene, diethyl phthalate, butyl paraben, [and] nonylphenol ethoxylates.” In a separate communication in September 2019, staff members clarified that the elimination commitment does not generally apply to components of generic ingredients such as fragrance, but they expect to receive generic ingredient components from “own brand” suppliers in the future. The company reported in December 2020 that it would require this disclosure beginning in 2021. In the company’s 2020 corporate social responsibility (CSR) report, Rite Aid further clarified that the timeline for the elimination commitment was “the end of calendar year 2020.”

The company noted in its 2019 CSR report that it expanded its BRSL to 69 chemicals total in 2018. In its 2020 CSR report, Rite Aid stated that while the elimination commitment only covers the 8 initial “chemicals of highest concern,” the company is “informally screening” the ingredients of new items against the larger RSL of 69 chemicals and against the BPC stewardship list (comprised of six authoritative and regulatory lists), “in anticipation of future program expansion.” Importantly, Rite Aid further notes in the 2020 report: “Suppliers are instructed to reformulate in-scope items that have been identified as containing chemicals on our RSL and the BPC stewardship list with safer alternatives referenced on the EPA Safer Choice list” and staff provided a few examples of such replacements in an August 2020 statement.

Staff members had also told us in September 2019 that in 2018, the company expanded its policy to cover national-brand formulated products, committing to screen all personal care and household cleaning products against its expanded BRSL and all personal care products against the BPC list. In December 2020, staff confirmed that Rite Aid “performed regular screenings of national brands products against our RSL and BPC stewardship list” in 2020. In the Fall 2019 update to its policy, Rite Aid notes that the company’s “long-term goal is to extend its chemical policy to cover all of the products sold in its stores.”

Rite Aid sells products marketed primarily to women of color, such as hair relaxers through the “tight curls” category. However, the company does not currently explicitly apply its BRSL to those products or address CHCs commonly found in them. Rite Aid also sells at least one skin-lightening cream marketed to women of color that advertises right in the details on the product webpage “Made with hydroquinone,” which is a CHC. Rite Aid noted in its safer chemicals policy published in early 2021 that: “In 2021, Rite Aid plans to expand its restricted substance list to include toxic chemicals in beauty and personal care products marketed to women of color. Rite Aid will utilize this expanded RSL for screening purposes similar to the BPC Stewardship list.” Partial extra credit of 0.75 points is awarded to recognize these plans.

Rite Aid noted in December 2020 that it finalized an RSL covering food-contact materials, including food packaging, and is requiring its own-brand suppliers to comply as of December 2020. Notably, the RSL restricts PFAS as a class, all ortho-phthalates, bisphenols, heavy metals, perchlorate, benzophenone, and certain solvents.

In September 2019, staff noted its associates wear polyethylene food service gloves, rather than PVC gloves that may contain toxic ortho-phthalates, at hand-dip ice cream counters in stores on the West Coast. We have awarded partial credit of 0.75 points for a limited beyond restricted material list (BRML) in a minor aspect of operations for one plastic of environmental health concern (PEHC), PVC. We award full credit for a BRSL for operations to recognize Rite Aid installing over 11 million square feet of bio-based floor tile in its stores, amounting to about 40% of its stores, in the last five years. This tile is free of phthalates, heavy metals, and polyvinyl chloride (PVC, and the information is from its 2020 CSR report and December 2020/January 2021 staff statements.

Rite Aid does not have any stores outside of the U.S. The company does not have a publicly available manufacturing restricted substance list (MRSL) or a publicly available beyond restricted material list (BRML) for plastics of environmental health concern (PEHC) except as noted above.

Glossary of Terms

Oversight: Established management responsibilities and incentives

2.5 out of 5 points

At least one Rite Aid senior vice president has responsibilities that include chemical safety. Additionally, staff reported that in 2019, Rite Aid created a position for a Corporate Responsibility Program Manager charged with coordinating the company’s chemical policy working group in the Corporate Social Responsibility Committee. The Committee provides “regular updates to our Board.” The working group’s purpose is “to review supplier compliance, address outstanding issues and to work on program refinement and enhancements.”

Rite Aid does not appear to offer financial incentives for senior management to implement its safer chemicals policy.

Glossary of Terms

Accountability: Ensures supply chain accountability

9.5 out of 15 points

In 2019, Rite Aid staff told us that a staff person verifies that suppliers have provided independent third-party testing results confirming new in-scope items are free from disclosed “Evil 8 chemicals,” but if the supplier cannot provide these results, Rite Aid gets the item tested at the supplier’s expense. The company also told us that in 2020, Rite Aid would implement random item testing to validate ongoing compliance but has not provided an update on this since then. In August 2020, staff noted that a certified laboratory tests all own-brand products with a label claim that they are “free of” a chemical for the Evil 8 chemicals and ensures the Evil 8 are not hiding in generic components like fragrance. We are awarding full credit for requiring third-party testing. However, because Rite Aid only gets the items tested if the supplier does not, and beyond that only tests products displaying “free of” claims, we are awarding 2 points of partial credit for Rite Aid conducting testing itself. We encourage Rite Aid to test all products containing undisclosed generic ingredients for the Evil 8 chemicals, not just products with “free of” claims.

In Rite Aid’s 2019 update to its policy, the company stated that it “moved from survey-based assessments of RSL compliance to automated screening using the WERCSmart platform.” The company had planned for this to happen in late 2018, and according to staff, the company provided the newly released policy and expanded RSL and explained product screening expectations to the nearly 500 supplier partners at its annual supplier conference in September 2018. As of mid-October 2018, the company was finalizing vendor guidance documentation to be uploaded to its Supplier Portal to train vendors “on WERCSmart registration, Rite Aid data consent authorization, and product assessment reporting.” The vendor guidance document, which has been issued since then and updated further, is extensive and discusses supplier expectations and requirements related to the company’s chemical policy in detail. This guidance can serve as a model for other companies.

In the company’s 2020 CSR report, Rite Aid states: “Our chemical policy has been formally incorporated into our own brand product sourcing process.” In December 2020, staff clarified that this meant the chemical policy is incorporated into an internal “onboarding checklist” and new item award letters (which happened in 2019), and that the supplier compliance guide has been updated “to include compliance with our chemical policy.” The company noted that suppliers must sign the guide to certify compliance, so we award full credit for the supplier contract component.

Glossary of Terms

Disclosure: Requires suppliers to report use of chemicals in products to retailer

9.5 out of 17.5 points

In Rite Aid’s 2019 update to its policy, the company stated that it “moved from survey-based assessments of RSL compliance to automated screening using the WERCSmart platform. Suppliers are required to report all ingredients in their formulated products to WERCSmart.” In a notable update provided to us in 2020, Rite Aid staff stated that it would begin requiring suppliers of own-brand formulated products to disclose all generic ingredients in WERCSmart starting in 2021 by the end of 2023. According to statements by staff in 2018, WERCSmart’s records do not typically include information on impurities, and the 2021 update to its policy states: “We are … encouraging our suppliers to begin disclosing nonfunctional constituents (such as by-products and contaminants) in their products once this capability becomes available on WERCSmart.” The points awarded reflect that Rite Aid requires all ingredients in formulated products to be disclosed, including the components of generic ingredients, and only encourages impurities to be disclosed.

Rite Aid staff noted in August 2020 that 61% of own-brand products can be completely screened (including the formulations of third-party components), up from 56% in 2019, and extra credit is awarded for reporting these metrics. Extra credit is also awarded for the disclosure policy applying to more than one major product category, since the RSL restricting the Evil 8 chemicals applies to “all formulated Rite Aid private brand Health, Beauty, Personal Care, Baby, Household Chemical and Food products.” Rite Aid also receives extra credit for asking its suppliers to disclose generic ingredients by the end of 2023.

Glossary of Terms

Action: Reduced or eliminated chemicals of high concern (CHCs) or plastics of environmental health concern (PEHCs) within the last three years

17 out of 26 points

In its 2020 CSR report, Rite Aid discussed its progress toward the goal of eliminating the eight original chemicals (“Evil 8”) from the primary formulations of its own-brand products by the end of the year: “With the help of both our supplier partners and collaboration with Underwriters Laboratories (UL), as of March 2020 we had reached 95% compliance with this commitment. We are confident we will meet our goal by the end of the year.” In December 2020, staff reported that only 2 percent of Rite Aid’s in-scope assortment contained Evil 8 chemicals as of the end of November 2020, 71 items had been reformulated as of December 2020, and only three items are going through the final stages of this process. Staff noted that replacements for paraben preservatives included methylchloroisothiazolinone, methylisothiazolinone, and sodium citrate. For some of the products, any Evil 8 chemicals were removed without any replacement needed. Extra credit is awarded for Rite Aid reporting at least one alternative the company has moved to and for the company moving to alternatives that are not rated as GreenScreen Benchmark-1 or List Translator-1.

Staff stated in December 2020 that since the company’s program and screening process were introduced, “no new in-scope own brand items containing disclosed Evil 8 chemicals have been approved or have made it to our shelves” and that between 2019-2020, 278 new own-brand items are free of the Evil 8.

Since expanding its RSL to 69 total chemicals, staff reported in 2019 that 87% of own-brand products are free of all 69 chemicals, and 84% are free of chemicals on the BPC Stewardship List, which Rite Aid adopted to help identify emerging chemicals of concern. In December 2020, staff stated that the company’s “national brand assortment within PurView increased by approximately 20% from 2019-2020” as more suppliers consented to Rite Aid screening their products. As of December 2020, 83% of the national brand products that can be screened passed Rite Aid’s (expanded) RSL screen and 64% passed the BPC Stewardship List screen.

The company also took action ahead of state and city bans and reformulated its own-brand sunscreen products with SPF under 50 to remove oxybenzone in late 2018; these products began appearing on shelves in February 2019. The company is transitioning all of its own-brand sunscreens to a new supplier so that their formulations will be free of oxybenzone, octinoxate, and the Evil 8.

Rite Aid has not publicly documented progress on reducing plastics of environmental health concern or chemicals of high concern in beauty products of environmental justice concern beyond regulatory compliance in the last three years.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

4.5 out of 16 points

Rite Aid staff reported to us in September 2019 that: “Suppliers are instructed to reformulate in-scope items that have been identified as containing chemicals on our RSL and the BPC Stewardship list. In addition to being referenced in our chemical policy, our ‘gatekeeper’ provides direct supplier guidance during the reformulation process, including specific reference to the EPA Safer Choice list. Rite Aid retests all reformulated products to confirm that appropriate substitutions have been made.” This was confirmed in the 2020 CSR report, which stated that “suppliers are instructed to reformulate…with safer alternatives referenced on the EPA Safer Choice list.”

According to staff statements in August 2020, the company showed that they have put this into practice, and noted that 3 chemicals that are replacements for the Evil 8 chemicals are on the Safer Chemical Ingredients List (although two are “yellow triangle,” meaning “The chemical has met Safer Choice Criteria for its functional ingredient-class, but has some hazard profile issues.”) Impressively, the company also noted that it was able to remove some Evil 8 chemicals from the its own-brand products without any replacement.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

10.5 out of 20 points

Rite Aid’s safer chemicals policy, BRSL for products, BRSL for food-contact materials including food packaging, and limited BRSLs for operations are publicly available. The company has also disclosed the identity of the six authoritative and regulatory lists that comprise the Beauty and Personal Care (BPC) stewardship list, which it screens certain items against.

Rite Aid stated in its 2018 policy that it: “will encourage suppliers to publicly disclose all ingredients online or on pack, including the constituents of fragrance and other generic ingredients.” In 2019, the company updated the language in its policy and in its vendor guidance to convey it was encouraging a higher level of disclosure. Its supplier guidance document states that Rite Aid encourages “suppliers to publicly disclose all intentionally added ingredients (including the constituents of fragrance and other proprietary components and allergens), as well as nonfunctional constituents online and on pack (if practicable).”

Glossary of Terms

Chemical Footprint: Evaluates its chemical footprint

3 out of 7.5 points

Rite Aid is a signatory to the Chemical Footprint Project and requests that its own-brand suppliers of formulated products participate in the CFP survey in 2021. The company had previously requested that its suppliers participate in the survey in 2020.

Glossary of Terms

Third-party Standards: Promotes credible third-party standards for safer products

0.75 out of 8.5 points

Rite Aid stated in its 2018 policy that it plans to “promote third-party certifications, such as US EPA Safer Choice products.” The company reiterated these plans in September 2019 statements and in its 2020 CSR report. The company currently sells three Safer Choice-certified products, three “EWG Verified” products, and one GOTS-certified product, but the company does not appear to promote these products.

It appears that search filters highlighting certifications such as Safer Choice and Cradle to Cradle will be added to its website once the data is collected from suppliers through WERCSmart. Partial credit is awarded, as the plans have not yet been implemented, and full credit will be awarded after implementation.

Glossary of Terms