The Great Compromise
Cleaning Products Pilot Project (CPPP)
Following the results of the Philadelphia pilot project and the RM1 assessment, the GSA/EPA team debated the merits of several different approaches for identifying environmentally preferable cleaning products. While the PBS officials who initiated what became the CPPP were originally hoping to use an EPA-approved list of cleaning products, it was clear from the beginning that such a list was outside the authority of GSA and EPA. Furthermore, the GSA/EPA team concluded that an "approved product list" was not necessarily the most beneficial solution because it would not allow government buyers to incorporate the varying needs of building tenants and cleaning staff or local environmental needs. Environmental needs, for example, could differ from one community to another. For example, some communities that do not have adequate water treatment facilities might be more concerned with water than air emissions.
The GSA/EPA team considered two primary methods of identifying environmentally preferable cleaning products. The first involved establishing thresholds for each of the environmental attributes identified during the Philadelphia pilot project and the RM1 assessment. Products that met these thresholds would be placed in a list of "green" cleaning products or be identified by a "green dot". The second method would provide procuring agents with selected environmental attribute information in a matrix (see pages 33-36 of GSA's catalog) (PDF) (36 pp, 781KB, About PDF) and allow them to decide which products met their environmental needs.
Proponents of the first method lobbied for the adoption of a "green dot" that could be placed next to cleaning products in the GSA product catalog that meet predetermined environmental standards. For example, only products with BCFs and VOC concentrations below an established threshold would be eligible to receive the "green dot". They argued that the alternative, providing a matrix of environmental attributes, was too burdensome and complicated for purchasers, and was, therefore, unlikely to be used effectively.
The GSA/EPA team identified two primary advantages with the "green dot" approach. First, it eliminates the need for purchasers to sort through detailed environmental information. Second, manufacturers would know exactly what characteristics their products must include (or exclude) and could design and manufacture products to meet those requirements.
Opponents of the "green dot" approach felt that its greatest strengths were also its greatest weaknesses. First, they argued that although issuing environmentally preferable products a "green dot" makes it easier for buyers, it also obscures vital environmental information including which environmental attribute(s) warranted the "green dot". GSA has millions of customers ranging from individuals in remote forest service outposts to entire military bases. Each group of customers has unique environmental and performance needs. For example, if a customer normally discharges waste cleaning water directly to surface water, a biodegradable cleaning product might be the most important environmental consideration. If, however, a customer discharges waste water to a water treatment facility, biodegradability may be less of a concern than reduced product packaging.
Some members of the GSA/EPA team also suggested that the "green dot" approach would absolve purchasers from fully examining the environmental impact of their procurement decisions. The matrix advocates argued for an approach that provides purchasers with sufficient information to balance the independent and combined impacts of each environmental attribute along with cost and product performance.
The matrix advocates also felt that if minimum environmental performance criteria were established, manufacturers would have no incentive to exceed the minimum criteria. Providing Federal purchasers with environmental attribute information for each cleaning product, however, allows them to select those products with the environmental attributes they determine are most important. In order to remain competitive, manufacturers will supply products with the environmental attributes favored by the Federal purchasers. As a result, market forces will encourage manufacturers to continually improve the environmental performance of their products.
The GSA/EPA team determined that the existing schedule for biodegradable cleaners provided an opportunity to combine the "green dot" and environmental attribute matrix. The method that was ultimately adopted and published in the GSA Commercial Cleaning Supplies catalog reflects a two step process that incorporates both approaches. GSA continues to identify products that meet the acute toxicity and biodegradability standards defined in GSA's Biodegradable Cleaners/Degreasers solicitation (FTC-92-MT-7906B), as it had done in previous catalogs. These products, however, are now grouped together in the front section of the catalog and are prominently displayed in a way that reflects the advantages of the "green dot" approach.
Suppliers of biodegradable products listed in the GSA catalog are then asked to voluntarily contribute additional information on environmental attributes:
- Skin irritation
- Food chain exposure
- Air pollution potential
- Potential concentrate exposure
GSA's catalog for Cleaning Equipment, Accessories, Janitorial Supplies, Cleaning Chemicals, and Sorbents (PDF) (36 pp, 781KB, About PDF) defines and lists these attributes in a matrix (see pages 33-36 of GSA's catalog) which allows purchasers to compare products based on the environmental attributes most critical for their geographic region and intended use.
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