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Summary of Comments Received from the Federal Register Notice of Voluntary Standards for EPP - Independent SDOs

Key Policy, Guidance Documents

EPA's Final Guidance on EPP

Executive Orders

Federal Acquisition Regulation

Green Purchasing Guides

Information on Standards for Green Products, Services

Independent Standards Developing Organization (SDOs)

ASTM
Underwriters Laboratories, Inc.
Green Seal
NSF International

[EPA Questions answered: 1, 2, 3, 4, 5, 6, 7, 8 ]

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.
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.

[EPA Questions answered: 1, 2, 3, 4, 5, 6, 7, 8]

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 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.

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[EPA Questions answered: 1, 2, 3, 4, 5, 6, 7]

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

[EPA Questions answered: 1, 2, 3, 4, 5, 6, 7, 8 ]

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.

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