1
May
18,
2005
EPP
PURCHASING
GUIDES
 
RESPONSE
TO
COMMENTS
I.
BACKGROUND
On
June
30,
2004,
EPA
issued
a
Federal
Register
(
FR)
notice
soliciting
public
comment
on
four
draft
EPP
Purchasing
Guides.
The
intent
of
the
guides
is
to
help
federal
government
purchasers
consider
the
environmental
factors
in
the
EPP
equation
when
making
purchases
in
the
following
areas:

 
Carpets
 
Cleaning
products
 
Copiers
 
Meetings
and
conferences
The
FR
notice
also
asked
for
reaction
to
several
questions,
including
whether
the
guides'
discussions
were
helpful
and
whether
the
approach
used
in
the
guides
was
useful.
The
comment
period
was
open
for
60
days.

EPA
received
24
comment
in
all,
including
some
comments
that
were
submitted
late:
11
on
the
Cleaning
Products
Guide;
2
on
the
Copiers
Guide;
7
on
the
Carpets
Guide;
1
on
the
Meetings
and
Conferences
Guide;
and
3
general
comments
applicable
to
multiple
guides.

Comments
were
submitted
by
9
trade
associations,
6
companies/
labs,
4
government
purchasers,
2
individuals,
2
anonymous,
and
1
environmental
choice
program.

This
document
summarizes
the
major
comments
received
on
the
guides
and
includes
EPA's
response
to
those
comments.

II.
CLEANERS
GUIDE
Comment:
Several
commenters
requested
that
EPA's
Design
for
the
Environment
(
DfE)

Formulator
Initiative
and
the
Unified
Green
Cleaning
Alliance
be
added
to
the
list
of
resources
in
the
guide.

Response:
EPA
concurs
and
has
added
these
references
to
the
revised
draft.
2
Comment:
Several
commenters
submitted
minor
editorial
comments
either
in
written
format
or
within
a
redlined
version
of
the
guide.

Response:
EPA
has
incorporated
most
of
these
edits
in
the
revised
draft.
Others
that
did
not
adhere
to
EPA/
GPO
style
were
not
accepted.

Comment:
Several
commenters
expressed
concern
over
the
issue
of
life
cycle
analysis,
main
concerns
being
that
is
needs
to
be
better
defined
as
it
relates
to
cleaning
products,
and
that
it
is
costly
to
implement.

Response:
As
EPA
has
indicated
in
the
guides,
life
cycle
analysis
is
one
of
EPA's
five
guiding
principles
for
making
environmentally
preferable
purchases.
To
assist
purchasers
further,
EPA
has
added
a
link
in
the
guide
for
additional
information
on
life
cycle
analysis.

Comment:
Several
organizations
submitted
comments
in
effect
saying
that
the
choice
of
a
particular
product
or
ingredient
is
affected
or
influenced
by
certain
situations
or
circumstances
and
that
the
selection
process
is
not
always
straightforward.

Response:
EPA
agrees
that
tradeoff
issues
are
involved
in
the
product
selection
process.
The
guides
were
not
intended
to
be
prescriptive,
but
rather
to
provide
suggestions
to
help
government
purchasers
consider
environmental
factors
when
making
purchasing
decisions.
In
the
first
paragraph
of
the
guides,

EPA
acknowledges
that
multiple
factors
are
important.

Comment:
The
Consumer
Products
Specialty
Corporation
(
CSPA)
and
the
Alkylphenols
&

Ethoxylates
Research
Council
(
APERC)
submitted
similar
comments
expressing
concern
that
EPA
is
providing
information
that
is
not
verified
by
the
referenced
organizations.

Response:
As
noted
earlier,
EPA's
purpose
in
the
guides
is
to
identify
a
number
of
environmental
factors
to
consider
in
purchasing
decisions.
These
considerations
come
from
EPA,
other
government
agencies,
industry,
and
non­
governmental
organizations.
The
organizations
referenced
in
the
guides
are
credible,
reputable
organizations
that
EPA
and
others
have
worked
with
for
years.
As
noted
in
the
introductory
paragraph,
EPA
is
not
endorsing
specific
organizations
and
has
not
verified
all
information
provided
by
these
organizations.
Fact
checking
and
verifying
all
of
the
information
posted
or
published
by
these
groups
is
not
realistic
from
a
time
or
budgetary
standpoint.
3
Comment:
A
couple
of
organizations
commented
that
the
guide
should
address
cleaning
as
a
process,
not
just
focus
on
products
or
ingredients.

Response:
Ingredients
are
a
relevant
consideration;
however,
the
guide
does
include
a
number
of
other
attributes
besides
ingredient
characteristics.
The
focus
of
the
guide
is
on
information
related
to
purchasing
decisions.
Comprehensive
information
on
cleaning
processes
and
practices
is
available
from
a
variety
of
sources
(
some
of
these
are
already
included
in
the
"
Contacts
and
Resources"
section
of
the
guide
and
others
have
been
added).

Comment:
ServiceMaster
Clean
submitted
a
comment
saying
that
EPA
should
be
careful
when
using
the
term
"
hazardous"
to
describe
cleaning
products.

Response:
EPA
has
used
this
term
in
the
guide
to
accurately
categorize
the
concentrated
forms
of
some
cleaners,
as
defined
by
several
regulatory
programs.

Comment:
APERC
submitted
a
comment
questioning
why
EPA
has
"
dismissed
the
basic
principles
of
risk
assessment."

Response:
The
purpose
of
the
guide
is
to
provide
practical
information
that
will
assist
federal
purchasers
in
making
purchasing
decisions.
The
guide
is
not
intended
to
be
a
risk
assessment
document,
nor
is
it
meant
to
substitute
for
Material
Safety
Data
Sheets
or
similar
documents
that
provide
important
information
on
proper
storage,
handling,
use,
and
disposal.
Many
of
the
recommendations
in
the
guide
are
based
on
the
fundamental
pollution
prevention
principles
of
reducing
the
quantity
and
hazards
of
materials
used.
The
pursuit
of
pollution
prevention
objectives
is
not
dependent
on
risk
findings.

Comment:
Both
CSPA
and
APERC
submitted
comments
arguing
that
an
entire
class
of
compounds
 
alkylphenol
ethoxylates
(
APEs)
 
should
not
be
implicated
because
of
a
single
ingredient.

APERC
also
believes
that
EPA
has
mistaken
nonylphenol
with
nonylphenol
ethoxylates
regarding
its
inference
about
reproductive
effects
and
endocrine
disruption.

Response:
The
actual
risks
from
these
chemicals
at
typical
exposure
levels
are
often
uncertain,
and
in
many
cases
are
probably
low.
Regardless
of
the
expected
risk
levels,
however,
reducing
the
intrinsic
hazard
of
a
product
is
a
desirable
pollution
prevention
objective
as
part
of
decisions
that
also
take
into
account
other
important
product
attributes.
EPA
also
notes
the
following
information
from
a
National
Academy
of
Sciences
report
that
corroborates
the
Agency's
statement:
"...
alkylphenol
ethoxylates
have
4
been
shown
to
induce
vitellogenin
synthesis,
a
hallmark
of
estrogen
exposure,
and
to
decrease
the
rate
of
testicular
growth
in
male
fish
in
tests
that
duplicate
concentrations
found
in
some
effluents."
Hormonally
Active
Agents
in
the
Environment,
National
Research
Council,
National
Academy
of
Sciences,
1999.

Comment:
The
Soap
and
Detergent
Association
submitted
a
comment
expressing
concern
over
the
guide's
implication
that
cleaning
products
containing
phosphorus
or
nitrogen
are
contributing
to
nutrient
loading
in
water
bodies.
The
organization
pointed
out
that
any
relevant
contributions
are
negligible.

Response:
EPA
recognizes
the
commenter's
concern
and
has
amended
the
revised
draft
guide
accordingly.

Comment:
CSPA
submitted
a
comment
disputing
the
statistic
in
the
guide
regarding
cleaning
products'
contribution
to
nonvehicular
VOC
emissions
in
California.

Response:
Based
on
review
of
the
data,
EPA
has
deleted
this
sentence.

Comment:
Several
organizations
submitted
comments
disputing
the
statement
in
the
guide
regarding
reports
to
Poison
Control
Centers
involving
cleaning
products.

Response:
EPA
acknowledges
that
the
statistic
referenced
in
the
guide
relates
to
household
cleaning
products,
not
commercial,
and
is
therefore
not
applicable
to
this
guide.
EPA
has
replaced
the
statistic
with
one
that
is
more
relevant
to
commercial
cleaners.

Comment:
ServiceMaster
Clean
and
the
Soap
and
Detergent
Association
took
issue
with
the
guide's
suggestion
that
purchasers
use
cleaning
products
that
are
made
from
renewable
resources,
such
as
biobased
materials.
The
commenters
claimed
that
this
decision
should
be
made
on
a
case
by
case
basis
and
that
life
cycle
studies
do
not
show
a
clear
advantage
to
using
renewable
resources.

Response:
Use
of
renewable
resources
is
a
commonly
accepted
environmental
principle
aimed
at
conserving
natural
resources
and
reducing
pollution.
EPA
emphasizes
that
the
attributes
mentioned
in
the
guide
are
merely
considerations,
and
that
different
situations
may
require
purchasers
to
be
more
focused
on
particular
attributes.
EPA
points
out
in
the
"
What
Can
You
Do?"
section
of
the
guide
that
the
overall
best
value
when
making
purchasing
decisions
takes
into
account
performance,
price,
availability,
regulatory
requirements,
and
environmental
impact.
EPA
further
states
that
purchasers
should
examine
as
many
relevant
product
attributes
as
possible,
recognizing
that
tradeoffs
are
inevitable.
5
Comment:
ServiceMaster
Clean
indicated
that
"
LD50"
testing
involves
animal
testing
and
that
this
may
be
at
odds
with
the
ethical
policies
of
some
companies.

Response:
The
lethal
and
effective
dose
concentrations
indicated
in
the
guide
are
related
to
aquatic
testing,
not
mammalian.
EPA's
inclusion
of
"
low
aquatic
toxicity"
in
its
list
of
desirable
attributes
is
again
based
on
the
approach
of
reducing
hazards
while
also
taking
into
account
other
important
product
attributes.
EPA
also
reiterates
that
this
is
just
one
attribute
that
should
be
examined,
with
the
understanding
that
tradeoffs
are
to
be
expected.

Comment:
CSPA
indicated
that
it
strongly
disagrees
with
the
guide's
statement
to
limit
the
use
of
disinfectants.

Response:
EPA
has
clarified
this
statement
in
the
revised
guide
by
indicating
when
disinfectant
use
is
most
appropriate
(
i.
e.,
in
areas
where
people
are
likely
to
come
in
contact
with
the
contaminated
surface)

and
when
it
is
less
useful.

Comment:
CSPA
also
indicated
that
broad
claims
such
as
"
environmentally
preferable"
should
not
be
used
and
are
contrary
to
the
FTC
environmental
marketing
guide.

Response:
EPA
notes
that
this
is
the
term
used
in
EO
13101.
The
purpose
of
the
guide
is
to
assist
federal
purchasers
in
determining
environmental
preferability.
Use
of
the
term
in
an
advertising
or
marketing
context
is
a
different
issue.

Comment:
ServiceMaster
Clean
expressed
concern
that
the
attributes
regarding
clear
labeling
and
information
on
use
and
disposal
could
mean
an
additional
regulatory
burden
for
companies.

Response:
EPA
notes
that
this
is
not
a
regulatory
requirement.
It
is
simply
common
sense
for
consumers
to
purchase
products
with
clear
labels
and
instructions.

Comment:
Coastwide
Laboratories
suggested
adding
language
regarding
the
efforts
a
company
has
made
to
minimize
the
effects
of
transportation.

Response:
EPA
believes
that
many
of
the
"
Packaging
and
Shipping"
attributes
in
the
guide,
such
as
having
products
shipped
in
bulk
and
using
refillable
bottles,
already
inherently
take
into
account
transportation
effects.
6
Comment:
CSPA
believes
the
Contacts
and
Resources
list
in
the
guide
is
too
focused
on
environmental
groups.

Response:
EPA
has
researched
and
added
other
resources
to
create
a
more
complete
list.

III.
CARPETS
GUIDE
Comment:
Several
commenters
submitted
minor
editorial
suggestions
to
be
incorporated
into
the
guide.

Response:
EPA
has
incorporated
these
edits
when
applicable.

Comment:
The
Air
Force
Center
for
Environmental
Excellence
submitted
a
comment
suggesting
that
EPA
remove
the
reference
to
using
PET
carpet
in
offices
and
residential
areas
(
which
the
guide
says
are
light
to
moderate­
wear
conditions)
because
the
Air
Force
classifies
offices
as
heavy
to
severe­
wear,
and
residential
as
moderate
to
severe­
wear,
which
would
preclude
them
from
using
PET
carpet.

Response:
EPA
added
language
to
the
guide
explaining
that,
in
general,
carpet
made
from
PET
and
polypropylene
face
fiber
is
not
as
durable
as
carpet
made
from
nylon
face
fiber
and
that
EPA
recommends
that
consumers
refer
to
the
"
Selecting
Carpet
and
Rugs"
page
of
the
Carpet
and
Rug
Institute's
(
CRI's)

Web
site
at
<
www.
carpet­
rug.
com/
index.
cfm>
when
determining
which
type
of
carpet
to
purchase.

Comment:
INVISTA
submitted
a
comment
indicating
that
the
name
"
DuPont
Carpet
Reclamation
Program"
should
be
changed
to
"
INVISTA
Reclamation
Program"
to
reflect
the
new
corporate
identity.

INVISTA
also
indicated
that
several
carpet
companies
have
products
that
are
certified
environmentally
preferable
under
SCS
Pilot
specification.

Response:
EPA
has
changed
the
name
of
the
program
from
Dupont
to
INVISTA
in
the
guide.
In
addition,
EPA
added
reference
to
the
SCS
carpet
specification
page
and
the
fact
that
several
carpet
manufacturers
have
received
this
certification.

Comment:
The
Vinyl
Institute
submitted
a
comment
suggesting
that
the
sentence
that
refers
to
use
of
recycled
PVC
be
expanded
to
apply
more
broadly
to
all
materials.

Response:
EPA
has
revised
the
guide
to
include
all
materials
in
its
reference
about
use
of
recycled
materials.
7
Comment:
An
EPA
Region
9
employee
submitted
a
comment
noting
controversy
regarding
the
use
of
recycled
PVC.
The
commenter
included
and
article
from
Healthy
Building
News.
The
commenter
also
believes
the
guide
should
specify
non­
PeBDE
carpet
cushion
since
PeBDE
is/
has
been
phased
out.

Response:
While
EPA
agrees
that
some
controversy
may
exist
regarding
the
use
of
PVC
in
carpet,

the
Agency
notes
that
the
guide
merely
acknowledges
the
availability
of
recycled
PVC
in
carpet.
EPA
is
in
no
way
saying
that
PVC
should
be
considered
over
other
recycled
materials.
Regarding
the
specification
of
non­
PBDE
carpet
cushion,
EPA
has
added
language
to
this
effect
in
the
guide.

Comment:
Collins
&
Aikman
(
C&
A)
submitted
a
comment
suggesting
that
EPA
mention
another
new
product
in
the
"
Materials
Used
in
Carpet"
section
of
the
guide.
The
product
is
a
carpet
backing
made
from
postconsumer
glass
and
PVB
plastic
recovered
from
windshield
and
safety
glass
recycling.

Response:
EPA
has
added
reference
to
the
new
carpet
backing
product
in
the
guide.

Comment:
The
Carpet
and
Rug
Institute
(
CRI)
submitted
several
comments
related
to
health
and
environmental
issues;
life
cycle
and
tradeoff
issues;
the
five
guiding
principles;
and
the
"
What
Can
You
Do?"
sections.

Response:
EPA
has
added
language
addressing
several
of
CRI's
comments
in
the
revised
guide.

IV.
COPIERS
GUIDE
Comment:
The
American
Plastics
Council
(
APC)
believes
that
all
of
the
points
listed
under
"
Why
Green
Your
Copier?"
are
already
covered
by
ENERGY
STAR
and
other
programs.

Response:
EPA
acknowledges
that
several
other
programs
offer
guidance
for
choosing
environmentally
preferable
copiers,
but
the
Agency
notes
that
the
purpose
of
its
Copiers
Guide
is
to
present
existing
information
in
one
useful
resource
to
assist
federal
government
purchasers
in
making
purchasing
decisions.

Comment:
TerraChoice
requested
that
the
new
criterium
CCD­
035
for
Copiers
be
added
to
the
guide.

Response:
EPA
has
added
reference
to
Canada's
Environmental
Choice
Program
and
its
photocopier
certification
in
the
"
Contacts
and
Resources"
section
of
the
guide.
8
Comment:
The
Electronic
Industries
Alliance
(
EIA)
questions
the
need
for
the
guide,
citing
the
Electronic
Product
Environmental
Assessment
Tool
(
EPEAT)
and
other
EPA­
led
efforts
underway
to
address
EPP
for
electronics.

Response:
EPA
agrees
that
there
are
several
quite
useful
projects
underway
to
address
environmental
issues
for
electronics,
but
the
Agency
notes
that
not
all
of
these
efforts
specifically
target
copiers,
which
is
the
focus
of
this
guide.
In
particular,
EPA
strongly
supports
the
EPEAT
process
and
commends
EIA
for
its
involvement
in
it,
but
notes
that
copiers
are
not
currently
included
in
it.
In
addition,

the
EPP
guides
are
meant
to
pull
together
relevant
information
for
procurement
officials
from
a
number
of
sources
beyond
EPA,
including
other
governments,
businesses,
and
nongovernment
groups.
There
are
other
sources
of
information
for
this
guide
besides
the
efforts
cited
in
the
comment.

Comment:
EIA
claims
that
the
guide
fails
to
adhere
to
such
principles
as
use
of
life
cycle
environmental
impacts.

Response:
EPA
notes
that
it
is
difficult
to
respond
to
this
comment
because
it
does
not
provide
explanations
or
examples
regarding
the
statement.
However,
the
Agency
notes
that
life
cycle
analysis
is
one
of
EPA's
five
guiding
principles
for
making
environmentally
preferable
purchases
and
is
discussed
in
the
guide
multiple
times.
To
assist
purchasers
further,
EPA
has
added
a
link
in
the
guide
for
additional
information
on
life
cycle
analysis.

Comment:
EIA
states
that
the
"
guidelines
lack
scientific
and
technical
rigor."

Response:
EPA
did
not
intend
for
the
Copiers
Guide
to
present
specific
criteria
for
purchasing
environmentally
preferable
products.
The
purpose
of
the
guide
is
merely
to
describe
the
challenges,

successes,
and
resources
associated
with
copiers,
focusing
on
how
to
incorporate
environmental
considerations
into
purchasing
decisions.
EPA
has
outlined
overall
principles
for
its
EPP
Program
and
EPA
clearly
identifies
its
EPP
guidelines
on
its
Web
site.
These
guidelines
do
not
require
any
agency
to
use
any
specific
documents,
such
as
the
Copiers
Guide.
To
further
clarify
the
purpose
of
the
EPP
guides,
EPA
has
replaced
the
term
"
guidelines"
with
"
considerations"
in
each
of
the
guides.

Comment:
EIA
stated
that
"
a
number
of
the
suggested
characteristics
are
not
easily
quantifiable."

Response:
EPA
has
attempted
to
cite
numeric
standards
when
available,
but
notes
that
some
of
the
environmental
considerations
suggested
in
the
guide
involve
less
quantitative
actions.
While
this
sometimes
9
complicates
the
procurement
decision,
these
points
are
still
believed
to
be
worth
considering.

Comment
:
EIA
does
not
support
the
use
of
third­
party
testing
for
product
research
.

Response:
EPA
agrees
with
EIA
that
procurement
officials
should
use
industry­
developed
statements
and
self
certifications,
and
has
added
language
to
that
effect
to
the
guide,
but
also
believes
that
there
may
be
a
role
for
third
party
testing
and
thus
continues
to
include
it
as
an
example.

Comment:
EIA
recommends
that
the
scope
of
the
document
be
limited
to
stand­
alone,
standard­
size
copiers
only,
but
does
not
explain
the
basis
for
this
preference.

Response:
Absent
more
information
on
the
basis
for
this,
EPA
will
retain
the
guide's
current
scope,

which
does
address
multi­
functional
systems
as
well
as
stand­
alone
copiers.

Comment:
EIA
"
is
concerned
that
the
guideline
has
added
categories
that
are
beyond
the
scope
of
environmental
characteristics,"
but
also
says
the
guide
"
fails
to
account
properly
for
other
important
factors,
including
price,
performance,
service,
reliability,
etc."

Response:
Although
the
guide
focuses
on
environmental
characteristics,
in
certain
places
it
does
refer
to
other
relevant
considerations
in
the
purchase
decision,
such
as
cost.
In
fact,
the
guides
include
discussion
of
EPA's
five
guiding
principles,
one
of
which
is
to
"
include
environmental
factors
as
well
as
traditional
considerations
of
price
and
performance
as
part
of
the
normal
purchasing
process."

Comment:
EIA
believes
the
toner
cartridge
recommendation
in
the
guide
is
unclear
and
may
provide
an
inappropriate
preference
for
some
cartridges.

Response:
EPA
did
not
intend
to
give
preference
to
any
particular
type
of
environmentally
preferable
toner
cartridge
procurement
option.
To
give
equal
preference
to
each
option,
EPA
has
changed
the
recommendation
in
the
guide
to
read
"
Use
returnable,
recyclable,
or
remanufactured
toner
cartridges."

Comment:
APC
submitted
a
comment
questioning
the
styrene
and
polybrominated
biphenyls
(
PBBs)
and
diphenyl
ethers
(
PBDE)
criteria
provided
in
the
guide.
Specifically,
APC
asked
for
this
information
to
be
corroborated,
including
indicating
what
the
criteria
are
based
on..

Response:
A
proposed
rule
on
PBDEs
refers
to
these
chemicals
as
persistent,

bioaccumulative,
and
toxic.
PBBs
are
classified
as
carcinogenic
by
the
NTP
and
IARC
and
are
also
10
persistent
and
bioaccumulative.
Neurological
effects
have
been
seen
in
workers
exposed
to
styrene
and
there
is
suggestive
evidence
of
adverse
reproductive
effects
in
exposed
workers.
Animal
studies
with
styrene
have
also
shown
effects
in
the
liver,
kidneys,
blood,
and
immune
system.
The
RfC
for
styrene
is
1
mg/
m3.

V.
MEETINGS
AND
CONFERENCES
GUIDE
Comment:
An
individual
commented
that
the
first
sentence
of
the
guide
is
too
jocular
considering
the
serious
nature
of
the
guide.

Response:
EPA
acknowledges
the
individual's
comment
and
has
changed
the
first
sentence
of
the
guide.

Comment:
The
same
individual
commented
that
he
does
not
believe
the
guide
goes
far
enough
in
actually
requiring
hotels
and
venues
to
meet
minimum
standards
or
to
be
rated
on
their
environmental
preferability.

Response:
The
guides
are
merely
intended
to
provide
useful
information
to
assist
federal
purchasers
in
making
environmentally
preferable
purchasing
decisions.
Under
EO
13101,
EPA
has
no
legal
or
statutory
authority
to
require
hotels
and
other
venues
to
meet
minimum
standards.

Comment:
The
American
Plastics
Council
(
APC)
believes
the
guide
does
not
include
enough
information
on
products
that
contain
recycled
content.

Response:
EPA
notes
that
it
mentions
multiple
times
in
the
guide
to
look
for
recycled
content
as
a
desirable
attribute
when
planning
meetings.
EPA
mentions
other
factors
as
well
to
present
a
balanced
approach
to
decisionmaking.

Comment:
APC
also
questioned
why
EPA
gives
preference
for
reusable
mugs
over
cups
that
have
recycled
content.

Response:
EPA
did
not
intend
to
discount
recyclable
food/
beverage
items
as
options
when
planning
environmentally
preferable
meetings.
The
Agency
was
merely
being
consistent
with
its
pollution
prevention
hierarchy,
which
encourages
source
reduction
(
including
reuse)
first,
followed
by
recycling
and
composting,
and,
lastly,
disposal
in
combustion
facilities
and
landfills.
To
clarify
its
position,
EPA
has
11
added
language
to
the
guide
regarding
the
use
of
recycled­
content/
recyclable
containers.
