Environmentally
Preferable
Purchasing
­
Side
by
Side
Summary
Page
1
of
14
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frside2side.
htm
6/
20/
2003
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Preferable
Purchasing
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Side
by
Side
Summary
About
EPP
EPP
Guidance
Federal
Efforts
EPP
Tool
Suite
EPP
Documents
EPP
Links
Side
by
side
summary
of
the
comments
received
in
response
to
the
Federal
Register
notice
on
developing
voluntary
standards
for
Environmentally
Preferable
Products
and
Services
Independent
Standards
Developing
Organizations
(
SDOs)
The
Five
Guiding
Principles
EPA's
Final
Guidance
Standards
Development
Top
20
Priorities
Commenter
ASTM
Products/
Sectors
Represented
Diverse
materials,
products,
systems,
and
services
in
over
100
industries
Standards
Activities
l
Develops
standards
l
ANSI
accredited
l
Does
not
perform
certifications
Environmental
Attribute
Activities
Subcommittee
E06.71
is
addressing
environmental
attributes
of
buildings
Market
Needs
Assessment
Building
and
constructions
sector
needs
assessed
Recommendations
EPA
should
participate
in
Committee
on
Performance
of
Buildings
Other
Issues
ASTM
interested
in
helping
implement
E.
O.
13101
with
respect
to
sustainability
of
built
environmen
Commenter
Green
Seal
(
501(
c)(
3)
nonprofit)

Products/
Sectors
Represented
All
manufactured
goods
and
services
Standards
Activities
Develops
standards
and
performs
certification
Environmental
Attribute
Activities
Develops
attributes
based
on
lifecyle
impacts
and
includes
environmental
attributes
in
all
standards
Market
Needs
Assessment
Not
addressed
RECEIVED
OPPT
NCIC
2003
JUN20
7:
42AM
OPPT­
2003­
0032­
0008
Environmentally
Preferable
Purchasing
­
Side
by
Side
Summary
Page
2
of
14
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frside2side.
htm
6/
20/
2003
Recommendations
l
EPA
should
not
require
consensus
standards;
consensus
requirement
will
lead
to
no
standards
or
weak
standards.

l
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.

Other
Issues
EPA
has
no
authority
to
require
or
adopt
consensus
standards
Commenter
NSF
International
Products/
Sectors
Represented
Drinking
water,
water
treatment,
commercial
food
equipment,
wastewater
treatment,
and
others
Standards
Activities
l
Develops
standards
and
certifies
health
and
environmental
products
l
ANSI
accredited
Environmental
Attribute
Activities
Plans
to
incorporate
new
criteria
for
environmental
protection
Market
Needs
Assessment
Examining
market
needs
at
present
time
Recommendations
l
Best
approach
should
involve
a
consensus
generating
process
that
has
a
strong
scientific
basis
and
can
reflect
changes
in
knowledge.

l
EPA
should
provide
initial
seed
funding
support
to
pilots.

Other
Issues
l
The
standards
development
process
is
particularly
expensive.

l
The
definitions
of
environmental
preferability
are
very
complex
and
not
obvious,
and
therefore
not
easily
determined.

Commenter
Underwriters
Laboratories,
Inc.

(
nonprofit)

Products/
Sectors
Represented
Not
all
specified,
but
includes
refrigerant
and
halon
recovery
and
recycling
equipment,
emission
reduction
equipment,
cooking
equipment,
underground
storage
tanks,
and
excavation
liners.

Standards
Activities
l
Develops
and
publishes
safety
standards
and
performs
conformity
assessments
l
ANSI
accredited
Environmentally
Preferable
Purchasing
­
Side
by
Side
Summary
Page
3
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epa.
gov/
opptintr/
epp/
guidance/
frside2side.
htm
6/
20/
2003
Back
to
top
Purchasers
l
ANSI
accredited
Environmental
Attribute
Activities
Develops
standards
with
public
safety,
human
well
being,
and
the
environment
in
mind
Market
Needs
Assessment
Not
addressed
Recommendations
EPA
should
continue
data
gathering
in
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.

Commenter
Department
of
the
Navy
Products/
Sectors
Represented
Supplies,
equipment,
and
services
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
EPA
should
first
establish
minimum
criteria
for
voluntary
consensus
standards
for
EPP
and
organizations
that
test
EPP.

l
Voluntary
standards
adopted
by
EPA
should
meet
the
following
criteria:
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
­
Side
by
Side
Summary
Page
4
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epa.
gov/
opptintr/
epp/
guidance/
frside2side.
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6/
20/
2003
Manufacturers/
Vendors
Proposing
Pilot
Project
Candidates
Other
Issues
See
Recommendations
Commenter
North
American
Insulation
Manufacturers
Association
(
NAIMA)

Products/
Sectors
Represented
Fiber
glass,
slag
wool,
and
rock
wool
insulation
products
Standards
Activities
Developed
standards
for
specific
types
of
insulation
products
Environmental
Attribute
Activities
Determined
energy
efficiency
and
developed
lifecycle
analysis
tool
for
competing
products
Market
Needs
Assessment
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.

Other
Issues
See
Recommendations
Commenter
Reusable
Industrial
Packaging
Association
(
RIPA)

Products/
Sectors
Represented
Reusable
industrial
packaging
Standards
Activities
l
Developed
standards
for
industrial
packaging
l
Has
worked
with
ASTM
and
ANSI
Environmental
Attribute
Activities
Identified
environmental
attributes
of
reusable
industrial
packaging
Market
Needs
Assessment
Identified
federal
government
as
major
user
of
industrial
packaging
Recommendations
l
Urges
establishment
of
a
voluntary
standard
specifying
that
industrial
containers
be
manufactured
or
reconditioned
to
DOT
requirements
for
reusable/
reconditionable
containers.

l
EPA
should
examine
standards
promoting
reuse
followed
by
recycling.

Other
Issues
l
Concerned
with
EPA's
greater
focus
on
the
recycled
content
of
new
containers
than
on
the
benefits
of
container
reuse.
Environmentally
Preferable
Purchasing
­
Side
by
Side
Summary
Page
5
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14
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epa.
gov/
opptintr/
epp/
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frside2side.
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6/
20/
2003
Back
to
top
Back
to
top
Manufacturers/
Vendors
Not
Proposing
Pilot
Project
Candidates
benefits
of
container
reuse.

l
Is
willing
to
develop
or
help
to
develop
standards
for
reusable
industrial
containers.

Commenter
Terresolve
Technologies,
Inc.

Products/
Sectors
Represented
Various
oils,
greases,
fluids,
and
lubricants
Standards
Activities
l
Does
not
develop
specific
business
or
industry
standards
l
Has,
in
place,
standard
development
activities
Environmental
Attribute
Activities
l
Standard
development
activities
integrate
environmental
attributes
l
Uses
various
environmentally
responsible
definitions
for
products
Market
Needs
Assessment
Is
aware
of
market
needs
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).

Other
Issues
Commenter
American
Forest
&
Paper
Association
(
AF&
PA)

Products/
Sectors
Represented
Forest,
paper,
and
solid
wood
products
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
See
Georgia­
Pacific
summary
Other
Issues
l
The
tools
available
for
identifying
"
environmentally
preferable"
are
limited
and
cannot
be
used
universally
because
the
environment
is
local.

l
EPP
could
create
unanticipated,
devastating
distortions
in
the
market.

l
Added
costs
in
ordering
and
processing
could
Environmentally
Preferable
Purchasing
­
Side
by
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Summary
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6
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epa.
gov/
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20/
2003
l
Added
costs
in
ordering
and
processing
could
affect
global
competitiveness.
See
also
Georgia­
Pacific
summary
Commenter
American
Wood
Preservers
Institute
Products/
Sectors
Represented
Pressure­
treated
wood
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
None
described
Other
Issues
l
Selective
claims
about
environmental
impacts
can
be
misleading.

l
Lifecycle
analysis
will
identify
few
clearly
preferable
products.

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

l
Regulation
of
disposal
of
preserved
wood
increases
its
cost.

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

Commenter
Amway
Corporation
Products/
Sectors
Represented
Consumer
products
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
l
Federal
endorsement
of
third­
party
product
specification
schemes
could
discourage
innovative
improvement
in
product
performance
and
safety.

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

l
See
also
Georgia­
Pacific
summary
l
See
also
CSMA
summary
Environmentally
Preferable
Purchasing
­
Side
by
Side
Summary
Page
7
of
14
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www.
epa.
gov/
opptintr/
epp/
guidance/
frside2side.
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6/
20/
2003
l
See
also
CSMA
summary
Other
Issues
l
U.
S.
government
is
best
served
by
continuing
to
support
development
of
sound
scientific
approaches
to
measure
environmental
impacts
on
well­
defined
endpoints.

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

l
EPP
could
create
unanticipated,
devastating
distortions
in
the
market.

l
Added
costs
in
ordering
and
processing
could
affect
global
competitiveness.

l
See
also
Georgia­
Pacific
summary
l
See
also
CSMA
summary
Commenter
Chemical
Specialties
Manufacturers
Association
(
CSMA)

Products/
Sectors
Represented
Products
for
household,
institutional,
and
industrial
use
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
l
CSMA
recommends
an
information­
based
EPP
model
under
which
suppliers
voluntarily
disclose
verified
claims
about
environmental
characteristics
of
goods
and
services.

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

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

l
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.

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

l
The
determination
and
need
for
standards
should
be
left
up
to
specific
industry
sectors.

l
Third­
party
certification
programs
should
not
be
used
to
judge
relative
environmental
preferability.
Environmentally
Preferable
Purchasing
­
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by
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Summary
Page
8
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epa.
gov/
opptintr/
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frside2side.
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20/
2003
Other
Issues
l
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.

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

l
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].

l
Expense
of
obtaining
third­
party
verification.

l
Can
certifiers
be
conflict­
free
consultants
under
government
contracts.

Commenter
Chlorine
Chemistry
Council
Products/
Sectors
Represented
Thousands
of
products
including
pharmaceuticals,
medical
devices,
construction
materials,
and
electronics
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
l
EPA
should
consult
with
other
parties,
particularly
organizations
interested
in
engaging
in
pilot
projects.

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

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

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

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

l
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.

l
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.

l
EPA
should
promote
awareness
of
FTC
Guidelines
among
federal
procurement
officials
and
participants
in
pilot
projects.
Environmentally
Preferable
Purchasing
­
Side
by
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Summary
Page
9
of
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epa.
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opptintr/
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6/
20/
2003
and
participants
in
pilot
projects.

Other
Issues
See
Recommendations
Commenter
Coalition
for
Truth
in
Environmental
Marketing,
Inc.

Products/
Sectors
Represented
Represents
producers
and
vendors
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
l
Specific
industry
sectors
should
decide
whether
product
standards
are
needed,
based
on
feedback
from
the
marketplace.

l
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
ecolabeling
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
l
The
criteria
available
to
identify
EPP
are
crude
at
best.

l
Avoiding
adverse
impacts
on
private
markets
by
federal
endorsement
of
specific
products.

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

l
Can
certifiers
be
conflict­
free
consultants
under
government
advisory
and
assistance
contracts?
Environmentally
Preferable
Purchasing
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10
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epa.
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6/
20/
2003
Commenter
Eastman­
Kodak
Company
Products/
Sectors
Represented
Products
that
may
be
affected
by
the
EPP
initiative
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
EPA
might
consider
collecting
data
from
other
programs
involving
voluntary
consensus
processes
to
compare
with
EPP
pilot
projects.
See
also
Georgia­
Pacific
Other
Issues
See
also
Georgia­
Pacific
Commenter
Edison
Electric
Institute
(
EEI)

Products/
Sectors
Represented
Shareholder­
owned
electric
utilities
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
l
Avoid
categorically
excluding
or
steering
agencies
toward
or
away
from
particular
goods
and
services.

l
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
­
Side
by
Side
Summary
Page
11
of
14
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frside2side.
htm
6/
20/
2003
Commenter
Georgia­
Pacific
Products/
Sectors
Represented
Paper
and
wood
products
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
l
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.

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

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

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

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

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

l
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
l
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.

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

l
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
­
Side
by
Side
Summary
Page
12
of
14
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frside2side.
htm
6/
20/
2003
Back
to
top
Other
requirements
on
its
use.

Commenter
Chemical
Compliance
Systems,
Inc.

Products/
Sectors
Represented
Not
described
Standards
Activities
l
Internal
standards
development
for
academic,
government,
and
industry
clients
l
Not
ANSI
accredited
Environmental
Attribute
Activities
l
Performs
hazard
assessments
for
consulting
clients
l
Has
been
discussing
prospective
computerized
tool
for
EPP
with
DCA,
GSA,
and
EPA
Market
Needs
Assessment
l
Has
extensively
discussed
market
needs
with
numerous
organizations.

l
High
interest
in
paints,
cleaners,
oils
and
lubricants,
adhesives,
and
inks.

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

Recommendations
None
described
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.

Commenter
Consumer's
Choice
Council
Products/
Sectors
Represented
Consumer
products
Standards
Activities
None
described
Environmental
Attribute
Activities
None
described
Market
Needs
Assessment
None
described
Recommendations
l
EPA
should
encourage
federal
agencies
to
take
advantage
of
the
existing
expertise
of
Environmentally
Preferable
Purchasing
­
Side
by
Side
Summary
Page
13
of
14
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frside2side.
htm
6/
20/
2003
Back
to
top
advantage
of
the
existing
expertise
of
organizations
(
e.
g.,
GreenSeal,
the
Forest
Stewardship
Council,
and
Canada's
Environmental
Choice
Program)
that
use
"
leadership
standards."

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

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

l
NTTAA,
OMB
A­
119,
and
ISO
14024
do
not
require
use
of
consensus
standards.

Commenter
Logistics
Management
Institute
Products/
Sectors
Represented
Not
described
Standards
Activities
Does
not
develop
voluntary
standards
Environmental
Attribute
Activities
Works
with
clients
to
"
green"
their
product
specifications
and
to
incorporate
environmental
considerations
into
their
daily
practices
Market
Needs
Assessment
Not
addressed
Recommendations
l
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.

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

l
EPA
could
develop
standards
for
the
process
of
evaluating
products.

Other
Issues
l
The
time
it
takes
to
develop
standards.

l
The
complexity
of
environmental
attributes
to
consider
over
the
product
lifecycle.

l
Lack
of
agreement
on
the
criteria
and
the
process
for
weighing
those
criteria.

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

l
Waiting
for
standards
could
seriously
delay
the
government's
progress
in
green
purchasing.
Environmentally
Preferable
Purchasing
­
Side
by
Side
Summary
Page
14
of
14
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frside2side.
htm
6/
20/
2003
Pollution
Prevention
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on
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9th,
2003
URL:
http://
www.
epa.
gov/
opptintr/
epp/
guidance/
frside2side.
htm
