Selecting and Evaluating Environmental Attributes
Cleaning Products Pilot Project (CPPP)
Following the completion of the Philadelphia pilot project, EPA initiated a comparative risk management assessment of the 19 cleaning products, known as an RM1 assessment. (An RM1 is a preliminary risk management assessment to determine if the human health or environmental risks associated with product components warrant further investigation. The RM1 conducted as part of the CPPP was different from traditional RM1 assessments because attributes other than those directly associated with risk, like product packaging, were also evaluated.) EPA and GSA encouraged manufacturers to voluntarily provide product formulation data, but this approach was not uniformly successful. As a result, the RM1 relied primarily on publicly available information derived from MSDSs and product literature.
The primary goal of the RM1 was to develop specific environmental attributes that could be used to help assess the environmental preferability of commercially available cleaning products. These attributes included:
- Irritation potential: The potential for adverse skin reactions from dermal exposure to the product.
- Chronic health risks: The likely chronic health risks from dermal and inhalation exposure to the product.
- Time to ultimate biodegradation: Toxic chemicals usually degrade to less toxic forms. The faster a chemical degrades, the lower the exposure potential.
- Bioconcentration factor (BCF): The higher the BCF value, the more likely the ingredient is to accumulate in the food chain.
- Percentage of volatile organic compounds (VOC): VOCs are known to contribute to smog formation.
- Amount of product packaging: Products with reduced packaging (sold as concentrates) decrease the volume of waste that must be disposed of.
- Presence of ozone depleters: Ozone-depleting components should be minimized.
- Potential exposure to the concentrated cleaning solution: The product dispensing method should include safety precautions designed to minimize exposure to the concentrated solution.
- Flammability: Nonflammable products are preferable.
- Presence of cosmetic additives (fragrances and dyes): Cosmetic additives can be considered unnecessary additives that increase overall lifecycle impacts and that could increase health and safety and ecological concerns. However, cosmetic additives may be required to help custodians distinguish among cleaning products and determine proper dilution strengths.
- Energy needs: Products that work effectively in cold water reduce energy consumption.
EPA encountered several limitations while conducting their comparative assessment of the 19 cleaning products. The limitations included:
- Difficulties in obtaining complete product formulation information.
- Incomplete hazard and pharmacokinetics information for most product components.
- Incomplete data on actual releases and exposures.
As a result, EPA was unable to completely assess the chronic health risks associated with the cleaning products, although it is hoped that these risks can be quantified in future phases of the CPPP.
EPA also chose not to include the presence of ozone depleters or energy needs in its assessment because none of the 19 cleaning products included ozone-depleting compounds or specified hot water use. Following the RM1 assessment, EPA determined that flammability did not differ significantly among the cleaning products and, therefore, recommended that flammability be excluded as an environmental attribute under the Cleaning Products Pilot Project.
Based on the results of the RM1 assessment and other considerations, such as the ability of small vendors to supply the necessary information, EPA narrowed the list of environmental attributes that could be used to identify environmentally preferable cleaning products. In addition to the existing acute toxicity and biodegradability criteria detailed in the Federal Supply Schedule Contract for Biodegradable Cleaners/Degreasers, EPA suggested other attributes including: skin irritation factors, BCF value, VOC concentration, product packaging, use of cosmetic additives, and the likelihood of concentrate exposure.
EPA did not recommend providing government purchasers with the impact of every conceivable environmental attribute for two reasons. First, most of the environmental attributes associated with cleaning products did not differ significantly from one product to another. If new cleaning products are introduced that differ from other cleaners in an important environmental attribute, EPA might recommend including the attribute in a future phase of the CPPP. Second, because the information being examined was to be used by federal purchasers, EPA wanted to avoid over-burdening them with information that would not facilitate their evaluation of the environmental preferability of a given product. The GSA/EPA team determined, based on EPA's recommendations, that information that fails to distinguish one product from another is not useful for comparing environmental preferability.
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