Environmentally
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­
Summary
of
Comments
Received
from
the
Federal
Regi..
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1
of
2
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www.
epa.
gov/
opptintr/
epp/
guidance/
frsum.
htm
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20/
2003
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Preferable
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Toxic
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>
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>
Summary
of
Comments
Received
from
the
Federal
Register
Notice
About
EPP
EPP
Guidance
Federal
Efforts
EPP
Tool
Suite
EPP
Documents
EPP
Links
Summary
of
Comments
Received
from
the
January
1999
Federal
Register
Notice
on
the
use
of
Third
Parties
in
Developing
Standards
Index
Independent
Standards
Developing
Organization
(
SDOs)

l
ASTM
l
Underwriters
Laboratories,
Inc.

l
Green
Seal
l
NSF
International
Purchasers
l
Department
of
the
Navy
Manufacturers/
Vendors
l
A.
Vendors
Offering
to
be
Pilot
Candidates
l
Terresolve
Technologies,
Ltd.

l
North
American
Insulation
Manufacturers
Association
l
Reusable
Industrial
Packaging
Association
l
B.
Other
Vendors/
Manufacturers
l
Georgia­
Pacific
l
American
Forest
&
Paper
Association
l
Amway
Corporation
l
Eastman­
Kodak
Company
l
Chemical
Specialties
Manufacturers
Association
l
Edison
Electric
Institute
l
Chlorine
Chemistry
Council
l
Coalition
for
Truth
in
Environmental
Marketing
Information,
Inc.

l
American
Wood
Preservers
Institute
Other
l
Chemical
Compliance
Systems,
Inc.

l
Consumer's
Choice
Council
The
Five
Guiding
Principles
EPA's
Final
Guidance
Standards
Development
Top
20
Priorities
RECEIVED
OPPT
NCIC
2003
JUN20
7:
42AM
OPPT­
2003­
0032­
0007
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
Received
from
the
Federal
Regi..
Page
2
of
2
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum.
htm
6/
20/
2003
l
Logistics
Management
Institute
Back
to
top
Pollution
Prevention
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OPPT
Home
EPA
Home
|
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and
Security
Notice
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Us
Last
updated
on
Friday,
May
9th,
2003
URL:
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum.
htm
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Independent
Standards
Devel..
Page
1
of
5
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum1.
htm
6/
20/
2003
Environmentally
Preferable
Purchasing
Recent
Additions
|
Contact
Us
|
Print
Version
Search:

EPA
Home
>
Prevention,
Pesticides
&
Toxic
Substances
>
Pollution
Prevention
>
Environmentally
Preferable
Purchasing
>
EPP
Guidance
>
Standards
Development
>
Summary
of
Comments
­
Independent
Standards
Developing
Organization
(
SDOs)

About
EPP
EPP
Guidance
Federal
Efforts
EPP
Tool
Suite
EPP
Documents
EPP
Links
Summary
of
Comments
Received
from
the
Federal
Register
Notice
of
Voluntary
Standards
for
EPP
­
Independent
SDOs
Independent
Standards
Developing
Organization
(
SDOs)

l
ASTM
l
Underwriters
Laboratories,
Inc.

l
Green
Seal
l
NSF
International
[
EPA
Questions
answered:
1,
2,
3,
4,
5,
6,
7,
8
]
The
Five
Guiding
Principles
EPA's
Final
Guidance
Standards
Development
Top
20
Priorities
1.
Name
ASTM
Address
West
Conshohocken,
Pennsylvania
Contact
Info
Steve
Mawn
(
610)
832­
9687
Nature
of
Organization
Develops
voluntary
consensus
standards
for
diverse
group
of
materials,
products,
systems,
and
services.

2.
Standards
Development
Activities
for
Which
Sectors?
Over
100
different
industries.

3.
Procedures
ASTM
is
an
ANSI
accredited
standards
developing
organization.

4.
Environmental
Attributes
in
Scope
of
Standards?
Subcommittee
E06.71
is
focusing
on
environmental
attributes
of
building.

5.
Perform
Product
Certification?
No.

6.
Perform
Product
Attribute
Development?
Not
typically
in
the
past.

7.
Nature
of
Government
Participation,
If
Any:
About
1,300
representatives
from
government
regulatory
and
procurement
agencies.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Independent
Standards
Devel..
Page
2
of
5
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum1.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1,
2,
3,
4,
5,
6,
7,
8]
8.
EPP
Market
Needs:
Building
and
constructions
sector
EPP
needs
assessed.

Recommendations:
EPA
should
participate
in
subcommittee
on
sustainability
within
Committee
on
Performance
of
Building.

Other
issues:
ASTM
interested
in
expanding
subcommittee
efforts
to
help
implement
E.
O.
13101
with
respect
to
the
sustainability
of
the
built
environment.

1.
Name
Underwriters
Laboratories,
Inc
Address
Melville,
New
York
Contact
Info
Paul
Orr
(
516)
271­
6200
Nature
of
Organization
Not­
for­
profit
that
develops
and
publishes
safety
standards
and
performs
conformity
assessments.

2.
Standards
Development
Activities
for
Which
Sectors?
Not
all
specified,
but
includes
refrigerant
and
halon
recovery
and
recycling
equipment,
emission
reduction
equipment,
cooking
equipment,
underground
storage
tanks,
and
excavation
liners.

3.
Procedures
UL
has
its
own
procedures
and
is
accredited
by
ANSI
to
obtain
recognition
of
a
UL
Standard
by
means
of
the
Accredited
Organization
and
the
ANSI
Canvass
Methods.

4.
Environmental
Attributes
in
Scope
of
Standards?
Develops
standards
with
public
safety,
human
well
being,
and
the
environment
in
mind.

5.
Perform
Product
Certification?
Yes.

6.
Perform
Product
Attribute
Development?
Not
Addressed
7.
Nature
of
Government
Participation,
If
Any:
State
and
local
officials
plus
representatives
of
federal
agencies
such
as
EPA,
FDA,
ATSDR,
USDA,
CPSC,
and
OSHA.

8.
EPP
Market
Needs:
Not
Addressed
Recommendations:
EPA
should
continue
data
gathering
in
markets
most
suited
for
EPP
and
make
this
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Independent
Standards
Devel..
Page
3
of
5
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum1.
htm
6/
20/
2003
Return
to
the
Organization
List
[
EPA
Questions
answered:
1,
2,
3,
4,
5,
6,
7]
markets
most
suited
for
EPP
and
make
this
information
available
to
voluntary
standards
developers
who
have
demonstrated
that
they
can
responsibly
and
effectively
contribute
to
the
health
and
well
being
of
the
public.

Other
issues:
UL
is
prepared
to
work
closely
with
EPA
and
other
interested
parties
to
determine
the
level
of
expertise
required
for
EPP
standards
development.

1.
Name
Green
Seal
Address
Washington,
D.
C.

Contact
Info
Michael
Shor
(
202)
872­
6400
Nature
of
Organization
501(
c)(
3)
nonprofit
with
mission
to
identify
and
promote
environmentally
responsible
products,
purchasing,
and
production.

2.
Standards
Development
Activities
for
Which
Sectors?
All
manufactured
goods
and
services.

3.
Procedures
Follows
ISO
14020
and
14024.
Meets
EPA's
criteria
for
third­
party
certifiers.

4.
Environmental
Attributes
in
Scope
of
Standards?
All
Green
Seal
standards
include
environmental
attributes.

5.
Perform
Product
Certification?
Yes.
A
core
program.

6.
Perform
Product
Attribute
Development?
Yes.
Examines
lifecycle
impacts
and
specifies
environmental
attributes.

7.
Nature
of
Government
Participation,
If
Any:
Representatives
of
EPA
and
DOE
and
other
agencies
typically
participate.

8.
EPP
Market
Needs:
Not
addressed.

Recommendations:
EPA
should
not
require
consensus
standards;
consensus
requirement
will
lead
to
no
standards
or
weak
standards.

EPA
should
use
Green
Seal
standards
because
they
are
immediately
available
at
no
cost
and
are
the
only
U.
S.
lifecycle
environmental
standards
for
manufactured
products.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Independent
Standards
Devel..
Page
4
of
5
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum1.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1,
2,
3,
4,
5,
6,
7,
8
]
products.

Other
issues:
EPA
has
no
authority
to
require
or
adopt
consensus
standards.

1.
Name
NSF
International
Address
Washington,
D.
C.

Contact
Info
Joseph
Cotruvo
(
202)
289­
2140
Nature
of
Organization
Develops
standards
and
certifies
numerous
health
and
environmental
products.

2.
Standards
Development
Activities
for
Which
Sectors?
Drinking
water,
water
treatment,
commercial
food
equipment,
wastewater
treatment,
and
others.

3.
Procedures
Has
detailed
procedures
and
is
accredited
by
ANSI.

4.
Environmental
Attributes
in
Scope
of
Standards?
Plans
to
incorporate
new
criteria
for
environmental
protection;
several
standards
where
NSF
expects
to
add
or
improve
environmental
performance
criteria.

5.
Perform
Product
Certification?
Yes.

6.
Perform
Product
Attribute
Development?
Indirectly,
yes.

7.
Nature
of
Government
Participation,
If
Any:
Federal,
state,
and
local
government
representatives
participate
in
standards
development.

8.
EPP
Market
Needs:
Examining
EPP
market
needs
at
present
time.

Recommendations:
Best
approach
should
involve
a
consensus
generating
process
that
has
a
strong
scientific
basis
and
can
reflect
changes
in
knowledge.

Encourage
EPA
to
provide
initial
seed
funding
support
to
pilots.

Other
issues:
The
standards
development
process
is
particularly
expensive.

The
definitions
of
environmental
preferability
are
very
complex
and
not
obvious,
and
therefore
not
easily
determined.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Independent
Standards
Devel..
Page
5
of
5
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www.
epa.
gov/
opptintr/
epp/
guidance/
frsum1.
htm
6/
20/
2003
Back
to
top
Return
to
Summary
of
Comments
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to
Standards
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Menu
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Home
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|
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Last
updated
on
Friday,
May
9th,
2003
URL:
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum1.
htm
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Purchasers
Page
1
of
2
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum2.
htm
6/
20/
2003
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Preferable
Purchasing
Recent
Additions
|
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EPA
Home
>
Prevention,
Pesticides
&
Toxic
Substances
>
Pollution
Prevention
>
Environmentally
Preferable
Purchasing
>
EPP
Guidance
>
Standards
Development
>
Summary
of
Comments
­
Purchasers
About
EPP
EPP
Guidance
Federal
Efforts
EPP
Tool
Suite
EPP
Documents
EPP
Links
Summary
of
Comments
Received
from
the
Federal
Register
Notice
of
Voluntary
Standards
for
EPP
­
Purchasers
Purchasers
l
Department
of
the
Navy
[
EPA
Questions
answered:
1]
The
Five
Guiding
Principles
EPA's
Final
Guidance
Standards
Development
Top
20
Priorities
1.
Name
Department
of
the
Navy
Address
Washington,
DC
Contact
Info
Gregory
Schirf
(
703)
604­
5424
Nature
of
Organization
Government
agency
that
procures
large
quantifies
of
supplies,
equipment,
and
services.

Recommendations:
EPA
should
first
establish
minimum
criteria
for
voluntary
consensus
standards
for
EPP
and
organizations
that
test
EPP.

Voluntary
standards
adopted
by
EPA
should
meet
the
following
criteria:

l
public
forum
that
allows
all
stakeholders
to
participate
l
provide
a
single
list
of
preferable
attributes
l
compare
products
within
the
context
of
their
intended
use
and
current
practices
l
consider
incremental
cost
increases
relative
to
environmental
benefits
l
resolve
competing
environmental
concerns
and
values
quantitatively
l
require
independent
verification
of
claims
l
independence
from
existing
regulatory
concerns
l
not
pose
undue
burden
on
business
l
available
at
reasonable
or
no
cost
l
consider
occupational
safety
and
health
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Purchasers
Page
2
of
2
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www.
epa.
gov/
opptintr/
epp/
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frsum2.
htm
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20/
2003
Back
to
top
Return
to
Summary
of
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Home
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Home
|
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and
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Us
Last
updated
on
Friday,
May
9th,
2003
URL:
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www.
epa.
gov/
opptintr/
epp/
guidance/
frsum2.
htm
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
1
of
15
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epa.
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epp/
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frsum3.
htm
6/
20/
2003
Environmentally
Preferable
Purchasing
Recent
Additions
|
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Us
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Version
Search:

EPA
Home
>
Prevention,
Pesticides
&
Toxic
Substances
>
Pollution
Prevention
>
Environmentally
Preferable
Purchasing
>
EPP
Guidance
>
Standards
Development
>
Summary
of
Comments
­
Manufacturers/
Vendors
About
EPP
EPP
Guidance
Federal
Efforts
EPP
Tool
Suite
EPP
Documents
EPP
Links
Summary
of
Comments
Received
from
the
Federal
Register
Notice
of
Voluntary
Standards
for
EPP
­
Manufacturers/
Vendors
Manufacturers/
Vendors
A.
Vendors
Offering
to
be
Pilot
Candidates
l
Terresolve
Technologies,
Ltd.

l
North
American
Insulation
Manufacturers
Association
l
Reusable
Industrial
Packaging
Association
B.
Other
Vendors/
Manufacturers
l
Georgia­
Pacific
l
American
Forest
&
Paper
Association
l
Amway
Corporation
l
Eastman­
Kodak
Company
l
Chemical
Specialties
Manufacturers
Association
l
Edison
Electric
Institute
l
Chlorine
Chemistry
Council
l
Coalition
for
Truth
in
Environmental
Marketing
Information,
Inc.

l
American
Wood
Preservers
Institute
A.
Vendors
Offering
to
be
Pilot
Candidates
[
EPA
Questions
answered:
1,
2,
3,
4,
5,
6,
7,
8
]
The
Five
Guiding
Principles
EPA's
Final
Guidance
Standards
Development
Top
20
Priorities
1.
Name
Terresolve
Technologies,
Ltd.

Address
East
Lake,
Ohio
Contact
Info
Mark
Miller
(
440)
951­
8633
Nature
of
Organization
Presumed
manufacturer
or
vendor.

2.
Standards
Development
Terresolve
does
not
develop
specific
business
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
2
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1,
2]
2.
Standards
Development
Activities
for
Which
Sectors?
Terresolve
does
not
develop
specific
business
or
industry
standards.
Products
include
various
oils,
greases,
fluids,
and
lubricants.

3.
Procedures
Wrote
environmentally
responsible
definitions.

4.
Environmental
Attributes
in
Scope
of
Standards?
Terresolve
has,
in
place,
standard
development
activities
specifically
integrating
environmental
attributes
as
part
of
all
their
standards.

5.
Perform
Product
Certification?
Not
currently;
is
considering
doing
so.

6.
Perform
Product
Attribute
Development?
Terresolve
uses
various
environmentally
responsible
definitions
for
their
products.

7.
Nature
of
Government
Participation,
If
Any:
Terresolve
would
welcome
government
or
regulatory
departments
and
agencies
to
participate
in
their
procedures.

8.
EPP
Market
Needs:
Terresolve
is
very
aware
of
market
needs
for
environmentally
preferable
products.
Terresolve
currently
works
in
markets
where
standards
are
not
required.

Recommendations:
Commenter
provided
definitions
for
several
environmental
attributes
(
i.
e.,
biodegradable,
non­
toxic,
agricultural­
based,
and
bio­
based)
and
marketing
terms
(
i.
e.,
environmentally
safe,
environmentally
preferable).

1.
Name
North
American
Insulation
Manufacturers
Association
(
NAIMA)

Address
Alexandria,
Virginia
Contact
Info
Angus
Crane
703/
684­
0084
Nature
of
Organization
Trade
association
of
North
American
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
3
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1,
2,
4,
8]
Nature
of
Organization
Trade
association
of
North
American
manufacturers
of
fiber
glass,
slag
wool,
and
rock
wool
insulation
products.

2.
Standards
Development
Activities
for
Which
Sectors?
Specific
types
of
insulation
products.

3.
Procedures
Not
addressed.

4.
Environmental
Attributes
in
Scope
of
Standards?
Energy
efficiency.

5.
Perform
Product
Certification?
Not
addressed.

6.
Perform
Product
Attribute
Development?
Not
addressed.
Lifecycle
analysis
tool
developed
for
competing
insulation
products.

7.
Nature
of
Government
Participation,
If
Any:
Not
addressed.

8.
EPP
Market
Needs:
Cited
demand
in
building
sector
and
misinformation
in
the
marketplace.
Also
has
commissioned
studies
to
document
energy
savings
and
pollution
reduction
achieved
through
use
of
insulation
products.

Recommendations:
A
voluntary
standard
should
be
developed
to
identify
the
characteristics
of
environmentally
preferable
insulation
products.

1.
Name
Reusable
Industrial
Packaging
Association
(
RIPA)

Address
Landover,
Maryland
Contact
Info
Dana
Worcester
(
301)
577­
3786
Nature
of
Organization
Represents
the
industrial
container
manufacturing
and
reconditioning
industries
in
North
America.

2.
Standards
Development
Activities
for
Which
Sectors?
Industrial
packaging.

3.
Procedures
Not
specified.
Has
worked
with
ASTM
and
ANSI.

4.
Environmental
Attributes
Yes
(
total
energy
use,
solid
wastes,
emissions
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
4
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
B.
Other
Vendors/
Manufacturers
[
EPA
Questions
answered:
1]
4.
Environmental
Attributes
in
Scope
of
Standards?
Yes
(
total
energy
use,
solid
wastes,
emissions
to
air
and
water).

5.
Perform
Product
Certification?
Not
addressed.

6.
Perform
Product
Attribute
Development?
Not
addressed.

7.
Nature
of
Government
Participation,
If
Any:
Not
specified.
Has
worked
with
EPA
and
California
Integrated
Waste
Management
Board.

8.
EPP
Market
Needs:
Federal
government
is
one
of
the
largest
industrial
packaging
users.
Many
government
agencies
and
their
contractors
use
industrial
containers
for
receipt
of
products
or
waste
disposal.

Recommendations:
Urges
establishment
of
a
voluntary
standard
specifying
that
industrial
containers
be
manufactured
or
reconditioned
to
DOT
requirements
for
reusable/
reconditionable
containers.

EPA
should
examine
standards
promoting
reuse
followed
by
recycling.

Other
issues:
Concerned
with
EPA's
greater
focus
on
the
recycled
content
of
new
containers
than
on
the
benefits
of
container
reuse.
Is
willing
to
develop
or
help
to
develop
standards
for
reusable
industrial
containers.

1.
Name
Georgia­
Pacific
Address
Atlanta,
Georgia
Contact
Info
Sergio
Galeano
(
404)
652­
4000
Nature
of
Organization
Manufacturer
of
paper
and
wood
products.

Recommendations:
EPA
should
focus
its
use
of
voluntary
standards
development
on
pre­
selected
pilot
projects
supported
by
a
consensus
of
a
sector
responsible
for
the
product
category
under
review.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
5
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1]
review.

EPA
must
clearly
identify
the
process
and
the
scientific
basis
it
will
use
to
determine
which
products
are
to
be
considered
"
environmentally
preferable."

EPA
should
issue
a
new
public
notice
after
consulting
with
organizations
interested
in
pilot
projects.

EPA
should
not
initiate
new
EPP
pilot
projects
on
products
that
are
already
being
addressed
through
other
programs
(
e.
g.,
paper
and
wood
products).

To
comply
with
the
NTTAA
and
OMB
Circular
A­
119,
EPA
should
first
identify
pilot
projects
and
project
participants
before
initiating
a
standards
process.

EPP
must
meet
the
same
standards
of
accuracy,
scientific
substantiation,
and
nondeception
that
apply
to
private
sector
product
declarations
affecting
purchasing
decisions.

EPA
must
ensure
that
EPP
standards
development
conforms
to
ISO
standards
including
(
1)
reasonable
effort
to
achieve
consensus;
(
2)
verifiable
scientific
basis;
(
3)
based
on
lifecycle
analysis,
subject
to
critical
review;
and
(
4)
avoid
establishing
unfair
barriers
to
trade.

Other
issues:
Continued
proposal
and
changes
in
environmental
attributes
creates
a
"
moving
target"
situation
for
products
and
customers
that
is
costly,
confusing,
and
interfering
with
normal
trading
practices.

E.
O.
13101
limits
EPA's
evaluation
of
the
use
of
standards­
developing
organizations
to
pilot
projects.

If
lifecycle
assessment
is
to
be
used,
the
tool
has
many
limitations,
and
international
standards
and
good
practices
impose
strict
requirements
on
its
use.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
6
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
1.
Name
American
Forest
&
Paper
Association
(
AF&
PA)

Address
Washington,
D.
C.

Contact
Info
Nature
of
Organization
Trade
association
of
the
forest,
paper,
and
solid
wood
products
industry.

Recommendations:
EPA
should
focus
its
use
of
voluntary
standards
development
on
pre­
selected
pilot
projects
supported
by
a
consensus
of
a
sector
responsible
for
the
product
category
under
review.

EPA
must
clearly
identify
the
process
and
the
scientific
basis
it
will
use
to
determine
which
products
are
to
be
considered
"
environmentally
preferable."

EPA
should
issue
a
new
public
notice
after
consulting
with
organizations
interested
in
pilot
projects.

EPA
should
not
initiate
new
EPP
pilot
projects
on
products
that
are
already
being
addressed
through
other
programs
(
e.
g.,
paper
and
wood
products).

To
comply
with
the
NTTAA
and
OMB
Circular
A­
119,
EPA
should
first
identify
pilot
projects
and
project
participants
before
initiating
a
standards
process.

EPP
must
meet
the
same
standards
of
accuracy,
scientific
substantiation,
and
nondeception
that
apply
to
private
sector
product
declarations
affecting
purchasing
decisions.

EPA
must
ensure
that
EPP
standards
development
conforms
to
ISO
standards
including
(
1)
reasonable
effort
to
achieve
consensus;
(
2)
verifiable
scientific
basis;
(
3)
based
on
lifecycle
analysis,
subject
to
critical
review;
and
(
4)
avoid
establishing
unfair
barriers
to
trade.

Other
issues:
The
tools
available
for
identifying
"
environmentally
preferable"
are
limited
and
cannot
be
used
universally
because
the
environment
is
local.

EPP
could
create
unanticipated,
devastating
distortions
in
the
market.

Added
costs
in
ordering
and
processing
could
affect
global
competitiveness.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
7
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1]
Continued
proposal
and
changes
in
environmental
attributes
creates
a
"
moving
target"
situation
for
products
and
customers
that
is
costly,
confusing,
and
interfering
with
normal
trading
practices.

E.
O.
13101
limits
EPA's
evaluation
of
the
use
of
standards­
developing
organizations
to
pilot
projects.

If
lifecycle
assessment
is
to
be
used,
the
tool
has
many
limitations,
and
international
standards
and
good
practices
impose
strict
requirements
on
its
use.

1.
Name
Amway
Corporation
Address
Ada,
Michigan
Contact
Info
Daniel
Edwards
Nature
of
Organization
Major
manufacturer
and
worldwide
marketer
of
consumer
products.

Recommendations:
Federal
endorsement
of
third­
party
product
specification
schemes
could
discourage
innovative
improvement
in
product
performance
and
safety.

Object
to
generation
of
lists
of
"
environmentally
preferred"
products
that
imply
government
endorsement.

EPA
should
focus
its
use
of
voluntary
standards
development
on
pre­
selected
pilot
projects
supported
by
a
consensus
of
a
sector
responsible
for
the
product
category
under
review.

EPA
must
clearly
identify
the
process
and
the
scientific
basis
it
will
use
to
determine
which
products
are
to
be
considered
"
environmentally
preferable."

EPA
should
issue
a
new
public
notice
after
consulting
with
organizations
interested
in
pilot
projects.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
8
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1]
EPA
should
not
initiate
new
EPP
pilot
projects
on
products
that
are
already
being
addressed
through
other
programs
(
e.
g.,
paper
and
wood
products).

To
comply
with
the
NTTAA
and
OMB
Circular
A­
119,
EPA
should
first
identify
pilot
projects
and
project
participants
before
initiating
a
standards
process.

EPP
must
meet
the
same
standards
of
accuracy,
scientific
substantiation,
and
nondeception
that
apply
to
private
sector
product
declarations
affecting
purchasing
decisions.

EPA
must
ensure
that
EPP
standards
development
conforms
to
ISO
standards
including
(
1)
reasonable
effort
to
achieve
consensus;
(
2)
verifiable
scientific
basis;
(
3)
based
on
lifecycle
analysis,
subject
to
critical
review;
and
(
4)
avoid
establishing
unfair
barriers
to
trade.

Other
issues:
U.
S.
government
is
best
served
by
continuing
to
support
development
of
sound
scientific
approaches
to
measure
environmental
impacts
on
well­
defined
endpoints.

See
also
Georgia­
Pacific
comment
summary
and
CSMA
comment
summary.

The
tools
available
for
identifying
"
environmentally
preferable"
are
limited
and
cannot
be
used
universally
because
the
environment
is
local.

EPP
could
create
unanticipated,
devastating
distortions
in
the
market.

Added
costs
in
ordering
and
processing
could
affect
global
competitiveness.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
9
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
1.
Name
Eastman­
Kodak
Company
Address
Rochester,
New
York
Contact
Info
Thomas
Dragon
(
716)
722­
4489
Nature
of
Organization
Makes
and
markets
products
that
may
be
affected
by
the
EPP
initiative.

Recommendations:
EPA
might
consider
collecting
data
from
other
programs
involving
voluntary
consensus
processes
to
compare
with
EPP
pilot
projects.

EPA
should
focus
its
use
of
voluntary
standards
development
on
pre­
selected
pilot
projects
supported
by
a
consensus
of
a
sector
responsible
for
the
product
category
under
review.

EPA
must
clearly
identify
the
process
and
the
scientific
basis
it
will
use
to
determine
which
products
are
to
be
considered
"
environmentally
preferable."

EPA
should
issue
a
new
public
notice
after
consulting
with
organizations
interested
in
pilot
projects.

EPA
should
not
initiate
new
EPP
pilot
projects
on
products
that
are
already
being
addressed
through
other
programs
(
e.
g.,
paper
and
wood
products).

To
comply
with
the
NTTAA
and
OMB
Circular
A­
119,
EPA
should
first
identify
pilot
projects
and
project
participants
before
initiating
a
standards
process.

EPP
must
meet
the
same
standards
of
accuracy,
scientific
substantiation,
and
nondeception
that
apply
to
private
sector
product
declarations
affecting
purchasing
decisions.

EPA
must
ensure
that
EPP
standards
development
conforms
to
ISO
standards
including
(
1)
reasonable
effort
to
achieve
consensus;
(
2)
verifiable
scientific
basis;
(
3)
based
on
lifecycle
analysis,
subject
to
critical
review;
and
(
4)
avoid
establishing
unfair
barriers
to
trade.

Other
issues:
Continued
proposal
and
changes
in
environmental
attributes
creates
a
"
moving
target"
situation
for
products
and
customers
that
is
costly,
confusing,
and
interfering
with
normal
trading
practices.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
10
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1]
trading
practices.

E.
O.
13101
limits
EPA's
evaluation
of
the
use
of
standards­
developing
organizations
to
pilot
projects.

If
lifecycle
assessment
is
to
be
used,
the
tool
has
many
limitations,
and
international
standards
and
good
practices
impose
strict
requirements
on
its
use.

1.
Name
Chemical
Specialties
Manufacturers
Association
(
CSMA)

Address
Washington,
D.
C.

Contact
Info
Robert
Kiefer
(
202)
872­
8110
Nature
of
Organization
Nonprofit
trade
association
representing
companies
that
manufacture
and
market
products
for
household,
institutional,
and
industrial
use.

Recommendations:
CSMA
recommends
an
information­
based
EPP
model
under
which
suppliers
voluntarily
disclose
verified
claims
about
environmental
characteristics
of
goods
and
services.

The
federal
government
should
accept
an
offeror's
environmental
attribute
claim
on
the
basis
of
possession
of
competent
and
reliable
evidence.

Any
voluntary
consensus
standards
considered
by
EPA
should
not
include
broad
environmental
terms.

EPA
should
not
drive
the
development
of
new
voluntary
consensus
standards.
EPA
should
first
identify
a
pilot
project
before
considering
what
might
be
an
appropriate
standards
organization
to
use.

EPA
should
follow
the
FTC
Guides,
NTTAA,
OMB
A­
119,
and
ISO
standards.

The
determination
and
need
for
standards
should
be
left
up
to
specific
industry
sectors.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
11
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1]
Third­
party
certification
programs
should
not
be
used
to
judge
relative
environmental
preferability.

Other
issues:
CSMA
does
not
support
the
use
of
such
terms
as
"
environmentally
preferable"
because
no
scientific
criteria
currently
exist,
including
lifecycle
assessment,
to
support
such
terms.

The
[
EPP
program
development]
process
has
not
been
transparent
and
industry's
comments
have
been
largely
ignored.

CSMA
member
companies
want
to
assist
in
EPP
program
development
and
have
the
opportunity
to
provide
environmental
information
that
is
both
accurate
and
meaningful
[
emphasis
in
original].

Expense
of
obtaining
third­
party
verification.

Can
certifiers
be
conflict­
free
consultants
under
government
contracts.

1.
Name
Edison
Electric
Institute
(
EEI)

Address
Washington,
D.
C.

Contact
Info
Alice
Mayer
(
202)
508­
5710,
Rich
Bozek
(
202)
508­
5641,
Chuck
Foster
(
202)
508­
5554,
Henri
Bartholomot
(
202)
508­
5622
Nature
of
Organization
Association
of
U.
S.
shareholder
owned
electric
utilities
and
affiliates.

Recommendations:
Avoid
categorically
excluding
or
steering
agencies
toward
or
away
from
particular
goods
and
services.

Standards
should
be
relevant;
set
using
an
inclusive,
consensus­
based
process;
based
on
sound
scientific
and
representative
data;
reasonable
and
objective;
and
well
accepted
in
the
marketplace.

Other
issues:
EPA
appears
to
be
promoting
the
development
of
standards
for
environmentally
preferable
goods
and
services,
rather
than
pilot
projects.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
12
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1]

Back
to
top
1.
Name
Chlorine
Chemistry
Council
Address
Arlington,
Virginia
Contact
Info
Jeff
Sloan
(
703)
741­
5183
Nature
of
Organization
A
business
council
of
the
Chemical
Manufacturers
Association
Recommendations:
EPA
should
consult
with
other
parties,
particularly
organizations
interested
in
engaging
in
pilot
projects.

EPA
should
provide
up­
front
guidance
on
the
standards
development
process
and
the
appropriate
uses
of
such
standards.

EPA
should
clearly
define
"
voluntary
consensus
standards"
and
"
standards
developers."

EPA
should
limit
the
scope
of
"
voluntary
consensus
standard
organization"
to
the
definition
in
OMB
Circular
A­
119.

EPA
should
focus
on
promoting
voluntary
consensus
standards
for
specific
pilot
projects.

Once
completed,
pilot
projects
should
be
reviewed,
with
input
from
all
stakeholders,
to
learn
what
practical
value
voluntary
consensus
standards
may
have
in
broader
EPP
efforts.

EPA
should
ensure
that
any
EPP
standards
developer
can
satisfy
ISO
standards
including
reasonable
effort
to
achieve
consensus;
verifiable
scientific
basis;
lifecycle
analysis,
subject
to
critical
review;
no
unfair
barriers
to
trade.

EPA
should
promote
awareness
of
FTC
Guidelines
among
federal
procurement
officials
and
participants
in
pilot
projects.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
13
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
[
EPA
Questions
answered:
1]

1.
Name
Coalition
for
Truth
in
Environmental
Marketing
Information,
Inc.

Address
Washington,
D.
C.

Contact
Info
Karil
Kochenderfer
(
202)
337­
9400
Nature
of
Organization
Represents
producers
and
vendors
who
support
market­
based
approaches
which
encourage
manufacturers
to
provide
environmental
information
about
their
products
attributes.

Recommendations:
Specific
industry
sectors
should
decide
whether
product
standards
are
needed,
based
on
feedback
from
the
marketplace.

EPA
should
first
explore
the
use
of
voluntary
consensus
standards
on
an
experimental
basis,
subject
to
the
following
conditions:

l
Standards
development
process
should
balance
environmental
considerations
with
needs
of
purchasers
for
performance
and
cost.

l
Use
definitions
and
procedures
in
OMB
Circular
A­
119
and
principles
and
procedures
in
ISO
eco­
labeling
standards
l
Only
organizations
with
an
established
history
and
widely
recognized
ability
to
develop
standards
(
e.
g.,
ASTM,
ANSI,
UL,
and
NSF)
should
lead
the
effort.

l
Environmental
attributes
should
have
a
strong
scientific
basis.

l
The
development
of
voluntary
consensus
standards
should
be
informed
by
market
research
on
the
expectations
and
needs
of
government
purchasers
(
e.
g.,
priority
of
environmental
attributes,
how
they
are
balanced
with
cost
and
performance,
and
whether
information
will
be
understood
and
interpreted
correctly).

Other
issues:
The
criteria
available
to
identify
EPP
are
crude
at
best.

Avoiding
adverse
impacts
on
private
markets
by
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
14
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1]

Back
to
top
Avoiding
adverse
impacts
on
private
markets
by
federal
endorsement
of
specific
products.

Support
the
use
of
third
parties
to
help
"
verify"
products
sold
to
the
government
or
help
agencies
set
up
verification
programs.

Can
certifiers
be
conflict­
free
consultants
under
government
advisory
and
assistance
contracts.

1.
Name
American
Wood
Preservers
Institute
Address
Fairfax,
Virginia
Contact
Info
George
Parrris
Nature
of
Organization
Trade
association
representing
the
pressuretreated
wood
industry
throughout
the
United
States.

Other
issues:
Selective
claims
about
environmental
impacts
can
be
misleading.

Lifecycle
analysis
will
identify
few
clearly
preferable
products.

Cost
in
service
is
probably
the
best
universal
measure
of
integrated
net
environmental
impact.

Regulation
of
disposal
of
preserved
wood
increases
its
cost.

The
concept
of
"
environmentally
preferred
product"
has
been
misused
to
imply
that
the
federal
government
will
ignore
all
other
factors
in
making
purchasing
decisions.

Return
to
Summary
of
Comments
Menu
Return
to
Standards
Development
Menu
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Manufacturers/
Vendors
Page
15
of
15
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
6/
20/
2003
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on
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May
9th,
2003
URL:
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum3.
htm
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Other
Page
1
of
4
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum4.
htm
6/
20/
2003
Environmentally
Preferable
Purchasing
Recent
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EPA
Home
>
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&
Toxic
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>
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Preferable
Purchasing
>
EPP
Guidance
>
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Development
>
Summary
of
Comments
­
Other
About
EPP
EPP
Guidance
Federal
Efforts
EPP
Tool
Suite
EPP
Documents
EPP
Links
Summary
of
Comments
Received
from
the
Federal
Register
Notice
of
Voluntary
Standards
for
EPP
­
Other
Other
l
Chemical
Compliance
Systems,
Inc.

l
Consumer's
Choice
Council
l
Logistics
Management
Institute
[
EPA
Questions
answered:
1,
2,
3,
4,
5,
6,
7,
8
]
The
Five
Guiding
Principles
EPA's
Final
Guidance
Standards
Development
Top
20
Priorities
1.
Name
Chemical
Compliance
Systems,
Inc.

Address
Lake
Hopatcong,
New
Jersey
Contact
Info
George
Thompson
(
973)
663­
2148
Nature
of
Organization
Consulting
firm.

2.
Standards
Development
Activities
for
Which
Sectors?
Internal
standards
for
wide
range
of
clients:
academic,
government,
and
industry.

3.
Procedures
Has
extensive
written
SOPs.
Not
a
certified
ANSI
affiliate.

4.
Environmental
Attributes
in
Scope
of
Standards?
Has
been
discussing
prospective
computerized
tool
for
EPP
with
DLA,
GSA,
and
EPA.

5.
Perform
Product
Certification?
No.
Performs
hazard
assessments.

6.
Perform
Product
Attribute
Development?
No.
Performs
hazard
assessments.

7.
Nature
of
Government
Participation,
If
Any:
None
to
date.

8.
EPP
Market
Needs:
Has
extensively
discussed
market
needs
with
numerous
organizations.

High
interest
in
paints,
cleaners,
oils
and
lubricants,
adhesives,
and
inks.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Other
Page
2
of
4
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum4.
htm
6/
20/
2003
Back
to
top
[
EPA
Questions
answered:
1]

Back
to
top
Since
EPP
is
a
regulatory­
driven
concept,
the
"
need'
within
market
sectors
will
be
as
broad
and
as
deep
as
the
regulatory
agencies
demand.

Other
issues:
CCS
is
prepared
to
work
either
with
EPA
and
other
appropriate
federal
agencies,
or
with
a
nongovernmental
standards
development
organization,
to
refine
its
computerized
resources
and
software
to
support
environmentally
preferable
purchasing.

1.
Name
Consumer's
Choice
Council
Address
Washington,
D.
C.

Contact
Info
Cameron
Griffith
(
202)
785­
1950
Nature
of
Organization
Coalition
of
environmental,
labor,
and
human
rights
organizations
that
works
to
facilitate
the
identification
of
environmentally
and
socially
responsible
products
through
third­
party
certification.

Recommendations:
EPA
should
encourage
federal
agencies
to
take
advantage
of
the
existing
expertise
of
organizations
(
e.
g.,
GreenSeal,
the
Forest
Stewardship
Council,
and
Canada's
Environmental
Choice
Program)
that
use
"
leadership
standards."

Environmental
preferability
should
be
determined
through
leadership
standards,
not
consensus
standards.

Other
issues:
Use
of
consensus
standards
is
inconsistent
with
E.
O.
13101
and
would
delay
federal
agencies'
implementation
of
their
EPP
responsibilities.

NTTAA,
OMB
A­
119,
and
ISO
14024
do
not
require
use
of
consensus
standards.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Other
Page
3
of
4
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum4.
htm
6/
20/
2003
[
EPA
Questions
answered:
1,
2,
6]

1.
Name
Logistics
Management
Institute
Address
McLean,
Virginia
Contact
Info
Raheem
Cash
703/
917­
7377
Nature
of
Organization
Nonprofit
research
and
consulting
organization.

2.
Standards
Development
Activities
for
Which
Sectors?
Not
a
voluntary
standards
development
organization.

3.
Procedures
Not
addressed.

4.
Environmental
Attributes
in
Scope
of
Standards?
Not
addressed.
See
6
below.

5.
Perform
Product
Certification?
Not
addressed.
See
6
below.

6.
Perform
Product
Attribute
Development?
Worked
with
various
clients
to
"
green"
their
product
specifications
and
to
incorporate
environmental
considerations
into
their
daily
practices.

7.
Nature
of
Government
Participation,
If
Any:
Not
addressed.

8.
EPP
Market
Needs:
Not
addressed.

Recommendations:
Reviewing
and
using
existing
standards
is
an
excellent
starting
point
because
it
allows
the
government
to
determine
which
markets
are
most
suited
for
consensus
based
standards.

EPA
should
convene
key
stakeholders
to
explore
this
very
complex
issue
further.

EPA
could
develop
standards
for
the
process
of
evaluating
products.

EPA
should
consider
using
a
Type
III
labeling
scheme.

Organizations
should
be
assigned
to
stay
abreast
of
changes
in
technology
and
practices
and
report
regularly
to
standards
developers.

Other
issues:
The
time
it
takes
to
develop
standards.

The
complexity
of
environmental
attributes
to
consider
over
the
product
lifecycle.
Environmentally
Preferable
Purchasing
­
Summary
of
Comments
­
Other
Page
4
of
4
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum4.
htm
6/
20/
2003
Back
to
top
Lack
of
agreement
on
the
criteria
and
the
process
for
weighing
those
criteria.

The
potential
to
hinder
flexibility
and
innovation
because
standards
are
difficult
to
change
and
are
viewed
as
endpoints.

Waiting
for
standards
could
seriousl
delay
the
government's
progress
in
green
purchasing.

Return
to
Summary
of
Comments
Menu
Return
to
Standards
Development
Menu
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Prevention
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|
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Home
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and
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Last
updated
on
Friday,
May
9th,
2003
URL:
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frsum4.
htm
