Jump to main content.


Summary of Comments Received from the Federal Register Notice of Voluntary Standards for EPP - Manufacturers/Vendors

A. Vendors Offering to be Pilot Candidates

B. Other Vendors/Manufacturers

A. Vendors Offering to be Pilot Candidates

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

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 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).

>

Top of page

[EPA Questions answered: 1, 2]

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 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.

Top of page

[EPA Questions answered: 1, 2, 4, 8]

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 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.

Top of page

B. Other Vendors/Manufacturers

[EPA Questions answered: 1]

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.

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.

Top of page

[EPA Questions answered: 1]

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.

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.

Top of page

[EPA Questions answered: 1]

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.

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.

Top of page

[EPA Questions answered: 1]

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.

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.

Top of page

[EPA Questions answered: 1]

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.

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.

Top of page

[EPA Questions answered: 1]

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.

Top of page

[EPA Questions answered: 1]

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.

Top of page

 

[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:

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

  • Use definitions and procedures in OMB Circular A-119 and principles and procedures in ISO eco-labeling standards

  • Only organizations with an established history and widely recognized ability to develop standards (e.g., ASTM, ANSI, UL, and NSF) should lead the effort.

  • Environmental attributes should have a strong scientific basis.

  • 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 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.

 

Top of page

 

[EPA Questions answered: 1]

1. Name

American Wood Preservers Institute

Address

Fairfax, Virginia

Contact Info

George Parrris

Nature of Organization

Trade association representing the pressure-treated 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.

Top of page

Return to Summary of Comments Menu

Local Navigation


Jump to main content.