Summary of Comments Received from the Federal Register Notice of Voluntary Standards for EPP - Purchasers
[EPA Questions answered: 1]
| 1. |
Name
|
Department of the Navy
|
|
Washington, DC
|
|
Contact Info
|
Gregory Schirf
(703) 604-5424
|
|
Nature of Organization
|
Government agency that procures large quantifies
of supplies, equipment, and services.
|
|
Recommendations:
|
EPA should first establish minimum criteria for
voluntary consensus standards for EPP and organizations that
test EPP.
Voluntary standards adopted by EPA should meet the following
criteria:
- public forum that allows all stakeholders to participate
- provide a single list of preferable attributes
- compare products within the context of their intended use
and current
practices
- consider incremental cost increases relative to environmental
benefits
- resolve competing environmental concerns and values quantitatively
- require independent verification of claims
- independence from existing regulatory concerns
- not pose undue burden on business
- available at reasonable or no cost
- consider occupational safety and health
|
Top of page