Environmentally
Preferable
Purchasing
­
Overview
of
Comments
Received
from
January
1999
FRNPage
1
of
4
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frover.
htm
6/
20/
2003
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Preferable
Purchasing
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Overview
of
Comments
From
January
1999
FRN
on
the
use
of
Third
Parties
in
Developing
Standards
About
EPP
EPP
Guidance
Federal
Efforts
EPP
Tool
Suite
EPP
Documents
EPP
Links
Overview
of
Comments
Received
from
the
January
1999
Federal
Register
Notice
on
the
use
of
Third
Parties
in
Developing
Standards
EPA
received
20
responses
to
its
Federal
Register
notice
on
the
Development
of
Voluntary
Consensus
Standards
for
Environmentally
Preferable
Goods
and
Services.
Seven
of
the
respondents
answered
some
or
many
of
the
specific
questions
posed
by
EPA;
the
rest
did
not.
The
responders
included
representatives
of
the
following
groups:

Within
the
manufacturer/
vendor
group,
three
responders
offered
candidates
for
pilot
projects;
these
3
responders
are
grouped
separately
from
the
9
manufacturers/
responders
who
did
not
offer
pilot
projects.

The
following
paragraphs
summarize
recommendations
and
issues
shared
by
responders
grouped
as
followed:
independent
SDOs,
purchasers,
manufacturers/
vendors
offering
pilot
projects,
manufacturers/
vendors
not
offering
pilot
projects,
and
the
other
responders
not
belonging
to
any
of
these
groups.

Back
to
top
Independent
Standards
Organizations
Independent
SDOs
expressed
a
strong
level
of
interest.
One
proposed
a
pilot
The
Five
Guiding
Principles
EPA's
Final
Guidance
Standards
Development
Top
20
Priorities
Group
Number
of
respondants
Independent
standards
developing
organizations
(
SDOs)
4
Purchasers
1
Manufacturers/
vendors
12
Associations
8
Companies
4
Other
3
Total
20
RECEIVED
OPPT
NCIC
2003
JUN20
7:
42AM
OPPT­
2003­
0032­
0006
Environmentally
Preferable
Purchasing
­
Overview
of
Comments
Received
from
January
1999
FRNPage
2
of
4
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frover.
htm
6/
20/
2003
project
(
ASTM)
and
another
encouraged
EPA
to
use
existing
standards
(
Green
Seal).
The
scope
of
the
sectors
covered
by
these
organizations
was
either
very
broad
(
ASTM,
UL,
Green
Seal)
or
narrow
(
NSF).
Most
are
ANSI­
accredited
(
ASTM,
UL,
NSF)
or
have
detailed
written
procedures
(
Green
Seal).
Most
of
these
SDOs
also
conduct
product
certification
(
UL,
Green
Seal,
NSF).
Outside
of
the
suggested
pilot
project
(
buildings),
these
responders
had
little
or
no
information
about
EPP
market
needs.
These
responders
offered
relatively
few
recommendations
to
EPA
and
raised
few
other
issues.
There
was
some
division
within
the
group
between
advocating
a
consensus
generating
process
(
NSF)
and
recommending
that
EPA
not
use
consensus
standards
(
Green
Seal).

Purchasers
One
responder,
the
U.
S.
Navy,
was
a
purchaser.
It
recommended
extensive
criteria
that
voluntary
standards
should
meet
and
encouraged
EPA
to
first
establish
minimum
criteria
for
voluntary
consensus
standards
for
EPP.

Manufacturer/
Vendors
Offering
Pilot
Projects
Three
responders
(
Terresolve,
NAIMA,
RIPA)
in
the
manufacturer/
vendor
group
offered
up
pilot
project
candidates.
These
responders
were
all
supportive
about
EPP
and
demonstrated
knowledge
of
the
environmental
attributes
of
their
products,
especially
in
regard
to
competing
products.

Manufacturers/
Vendors
Not
Offering
Pilot
Projects
Manufacturers
and
vendors,
including
their
associations
and
representatives,
provided
the
largest
number
of
responses.
However,
the
responses
from
manufacturers/
vendors
not
offering
pilot
projects
focused
on
general
issues
and
not
the
specific
questions
listed
by
EPA.
Several
of
the
manufacturer/
vendor
responses
had
a
large
number
of
common
items
and/
or
endorsed
the
responses
of
other
responders
in
this
group.

First,
many
of
these
responders
recommended
that
EPA
focus
its
use
of
voluntary
standards
on
pre­
selected
pilot
projects
that
had
the
support
of
the
responsible
sector.
These
commenters
argued
that
E.
O.
13101,
NTTAA,
and
OMB
Circular
A­
119
limited
EPA's
use
of
SDOs
to
pilot
projects
or
that
EPA
should
as
a
matter
of
policy
start
with
pilot
projects
advocated
by
industry
(
Georgia­
Pacific,
American
Forest
&
Paper
Association
(
AF&
PA),
Amway,
Eastman­
Kodak,
Chemical
Specialties
Manufacturers
Association
(
CSMA),
Edison
Electric
Institute
(
EEI),
Chlorine
Chemistry
Council
(
CCC),
and
Coalition
for
Truth
in
Environmental
Marketing
Information
(
CTEMI)).

Second,
many
of
the
responders
in
this
group
recommended
that
EPP
standards
development
should
conform
to
ISO
standards,
including
reasonable
efforts
to
achieve
consensus
(
Georgia­
Pacific,
AF&
PA,
Amway,
Eastman­
Kodak,
CSMA,
EEI,
CCC,
CTEMI).

Several
responders
in
this
group
expressed
concerns
that
EPA
might
be
trying
to
develop
a
standard
for
defining
such
broad
terms
as
"
environmentally
preferable"
(
CSMA,
AF&
PA,
Amway,
American
Wood
Products
Institute
(
AWPI))
Environmentally
Preferable
Purchasing
­
Overview
of
Comments
Received
from
January
1999
FRNPage
3
of
4
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frover.
htm
6/
20/
2003
and/
or
referred
to
the
FTC
Guidelines
(
Georgia­
Pacific,
AF&
PA,
Amway,
Eastman­
Kodak,
CSMA).

Several
responders
in
this
group
also
expressed
concern
about
adverse
market
impacts
(
Georgia­
Pacific,
AF&
PA,
Amway,
Eastman­
Kodak,
CTEMI).
Two
recommended
that
EPA
avoid
categorically
steering
agencies
toward
or
away
from
particular
goods
and
services
(
EEI,
Amway).
Others
urged
that
EPA
not
initiate
new
EPP
pilot
projects
on
products
(
e.
g.,
paper
and
wood
products)
that
already
are
being
addressed
through
other
programs
(
Georgia­
Pacific,
AF&
PA,
Amway,
Eastman­
Kodak).

Other
Not
falling
into
the
Independent
SDO,
Purchaser,
or
Manufacturer/
Vendor
Groups
are
responders
Chemical
Compliance
Systems,
Inc.,
a
consulting
firm
looking
for
funding
to
develop
a
computerized
EPP
support
tool;
the
Consumer's
Choice
Council,
a
coalition
of
environmental,
labor,
and
human
rights
organizations
that
works
to
facilitate
the
identification
of
environmentally
and
socially
responsive
products
through
third­
party
certification,
which
made
recommendations
and
raised
issues;
and
the
Logistics
Management
Institute,
a
nonprofit
research
and
consulting
organization,
which
also
made
recommendations
and
raised
issues
related
to
EPA's
notice.
Both
the
Consumer's
Choice
Council
and
the
Logistics
Management
Institute
encouraged
EPA
to
take
advantage
of
existing
standards
and
expressed
concern
that
waiting
for
standards
would
delay
government
progress
in
green
purchasing.

Back
to
top
Cross­
Cutting
Issues
Degree
of
Interest
in
EPP
Standards
Although
there
are
literally
hundreds
of
organizations
involved
in
voluntary
standard
setting
according
to
the
National
Institute
of
Standards
and
Technology,
the
leading
independent
SDOs
with
potential
interest
in
environmentally
preferable
purchasing
(
Green
Seal,
ASTM,
UL,
NSF)
all
responded
to
EPA's
notice.

Degree
of
Consensus
Needed
for
Standards
The
major
issue
that
cuts
across
the
five
categories
relates
to
the
necessary
or
desirable
degree
of
consensus
process
needed
to
develop
EPP
standards.
Positions
include
(
1)
consensus
standards
must
be
used,
(
2)
reasonable
effort
to
achieve
consensus
on
standards
is
sufficient,
without
requiring
consensus,
and
(
3)
"
leadership"
standards
must
be
used,
not
consensus
standards.
Position
1
is
supported
by
some
of
the
Manufacturer/
Vendor
commenters
who
addressed
this
issue
(
CTEMI,
EEI,
and
CCC)
as
well
as
NSF.
Position
2
is
supported
by
many
of
the
Manufacturer/
Vendor
responders
(
Georgia­
Pacific,
AF&
PA,
Amway,
Eastman­
Kodak,
CCC)
who
addressed
this
issue.
Position
3
is
supported
by
Green
Seal
and
the
Consumer's
Choice
Council.
Environmentally
Preferable
Purchasing
­
Overview
of
Comments
Received
from
January
1999
FRNPage
4
of
4
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frover.
htm
6/
20/
2003
Who
Should
Decide
the
Need
for
Standards
A
related
issue
of
great
concern
to
the
Manufacturer/
Vendor
group
­­
that
industry
sectors
should
decide
whether
EPP
standards
are
needed
­­
was
not
addressed
by
the
other
responders;
however,
the
recommendations
of
Green
Seal
and
the
Consumer's
Choice
Council
for
"
leadership
standards"
could
be
interpreted
as
in
opposition
to
the
Manufacturer/
Vendor
group
position.
A
couple
of
responders,
both
of
whom
recommended
pilot
projects,
expressed
concerns
about
misinformation
in
the
marketplace
(
AWPI,
NAIMA).

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top
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on
Friday,
May
9th,
2003
URL:
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frover.
htm
