Guidelines for the Assessment of Environmental Performance Standards and Ecolabels for Federal Procurement
The Guidelines, developed through a stakeholder consensus process, provide a transparent, fair, and consistent approach to assessing marketplace standards and ecolabels for EPA’s Recommendations to federal purchasers. The Guidelines encourage continuous improvement of both standards and ecolabels and the products and services that those standards and ecolabels address, while providing flexibility to accommodate the variety of approaches to and types of standards and ecolabels that exist in the marketplace today.
- The goals of the Guidelines are to:
- Leverage existing private sector standards and ecolabels to create positive and measurable change in the environmental performance attributes of the products and services procured by the US Government.
- Develop a framework that recognizes environmental performance that is better than standard industry practice and further distinguishes higher performance.
- Develop a framework that filters out standards or ecolabels that are not appropriate for federal procurement and/or do not support environmentally preferable purchasing and/or do not address the key environmental or health impacts of a particular product category.
- What is the purpose of the Guidelines?
There are over 460 standards and ecolabels in the marketplace claiming to validate environmental and human health benefits. This presents the federal acquisition community both great opportunities and challenges. EPA's goal in developing the guidelines is to create an efficient way for purchasers to easily identify environmentally preferable products. The Guidelines provide a transparent, fair, and consistent approach to selecting environmental performance standards and ecolabels to support the agency's mission and federal sustainable acquisition mandates. The fundamental aim of the guidelines is to establish a cross-sector framework to be used in evaluating and recognizing non-governmental environmental standards and ecolabels (and consequently, environmentally preferable products meeting these standards) for use in federal procurement.
The Federal Acquisition Regulations (FAR) at 48 CFR 23.703(b)(1) – directs Agencies to "Maximize the utilization of environmentally preferable products and services (based on EPA-issued guidance)." The Guidelines are the basis for developing the Recommendations, which serve as the “EPA-issued guidance”.
The ability to evaluate and use private sector standards to meet federal policy and procurement objectives aligns with the mandates in the National Technology Transfer and Advancement Act (NTTAA) (Section 12d) and OMB Circular A119.
- What do the Guidelines address?
The Guidelines are actually four sets of guidelines that address various aspects of product environmental performance standards and ecolabels:
- Section I: Process for Developing the Standard — Are the procedures to develop, maintain, and update an environmental standard transparent? Do they allow for a balance of different stakeholder interests? Is there an appeals process for disputes?
- Section II: Environmental Effectiveness of the Standard —Do the environmental criteria in the standard/ecolabel meaningfully and measurably address the issue? Do they differentiate among products? Does the standard address key stages in the product lifecycle that may pose environmental and human health risks?
- Section III: Conformity Assessment — Are the procedures and practices by which products are assessed transparent? Are there provisions for independent verification that products meet the standard, if necessary?
- Section IV: Management of Ecolabeling Programs — Do the organizational and management practices provide for dispute resolution? Are the practices and fees transparent?
- How were the Guidelines developed?
Interagency Effort: In 2011, EPA, the General Services Administration (GSA), and other federal agencies, including the Department of Defense and the Department of Commerce, following several listening sessions with a wide range of stakeholders came together with the goal of a fair, consistent, and effective way to assess and use private sector standards and ecolabels in federal purchasing. The interagency group developed an initial set of draft guidelines, and tested their feasibility and appropriateness. This included conducting a survey of a subset of government and non-governmental environmental performance standards and ecolabel developers. Based on the results of the study and external stakeholder input from more than 30 listening sessions and discussions, EPA took the lead in completing the draft guidelines and framing a pilot.
Public Comment: From November 20, 2013 through April 25, 2014, EPA received input from more than 75 individuals and organizations on its proposed Draft Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement to help federal purchasers select greener products and meet sustainability purchasing goals.
The majority of public comments supported EPA undertaking—with key external entity and stakeholder participation—additional work to further refine the Guidelines and test a potential approach to assessing standards and ecolabels.
Based on comments, Section II (Environmental Effectiveness) and Sections I, III, and IV of the Draft Guidelines were revised.
2015-2016 EPA Guidelines Pilot: EPA contracted with Resolve Inc. to convene a multi-stakeholder Governance Committee and purchase category-specific panels to develop and pilot test an approach in a few sectors. EPA chose the following three product categories to pilot–furniture, flooring, and paints/coatings.
These sectors were chosen because they meet some or all of the following criteria:
- Potentially significant environmental and/or human health impact (based on lifecycle assessments and hazard and risk assessments)
- Opportunity for environmental and/or human health improvement through private sector standards/ecolabels
- Significant volume of federal purchases
- Current federal sustainable acquisition mandates in the category are limited, out-of-date, and/or could be augmented with private sector standards
Each of the Product Category panels and the Service Sector Panel included a set of experts, with balanced participation from the following stakeholder groups: Producers, Users, Environmental and Public Health/Regulatory, and the Standards and Ecolabel Community.
The primary role of each of the three product category panels was to work collaboratively with other panel members to develop product-category-specific criteria for evaluating standards and ecolabels (based on the guidelines), consider related issues such as scoring and weighting, and then review and provide comments on the assessment results.
The primary role of the Service Sector Panel was to help identify key issues and then make preliminary recommendations on the potential future application of the guidelines to service sector standards and ecolabel.
The criteria for Panel membership included:
- Knowledge of the environmental and/or human health impacts of the particular product category.
- Experience working with diverse stakeholders towards consensus.
- Familiarity with the draft guidelines and federal sustainable acquisition mandates.
- Familiarity with standards development and conformity assessment approaches.
- Ability to devote the necessary time to the panel.
Governance Committee (GC)
The GC included representatives from the panels (one from each of the four panels), elected by the panels, as well as additional individuals who were not Panel members, but instead focused on the pilot’s broader objectives while adding balance and credibility to the GC.
The primary roles of the Governance Committee (GC) were to: develop criteria and sources of evidence for Sections I, III, and IV of the Draft Guidelines; coordinate, guide, and advise the panels; ensure consistency among the panels where appropriate; make recommendations on key pilot phases; add insight and perspective on the pilot’s value and post-pilot scalability questions. As such, the GC played a key role supporting the pilot’s immediate goals, as well as built momentum and leadership beyond the pilot.
All applicants were asked to disclose any potential conflict of interest; a conflict of interest did not preclude participation, but transparency was essential.
Governance Committee Members:
- Angie Fyfe ICLEI Local Governments for Sustainability, USA
- Bill Perdue American Home Furnishings Alliance
- Brad Miller Business & Institutional Furniture Manufacturers Association (Furniture Panel Representative)
- Bridgett Luther Cradle to Cradle Products Innovation Institute
- Charleen Fain-Keslar State of California, Department of General Services, Procurement Division (Services Sector Panel Representative)
- David Alderman National Institute of Standards and Technology
- Deborah Prince Underwriters Laboratories Inc.
- Don Horn U.S. General Services Administration
- Jason Pearson Sustainable Purchasing Leadership Council
- Jeff Bradley American Wood Council
- Karyn Schmidt American Chemistry Council
- Kirsten Ritchie Gensler
- Linda Brown SCS Global Services
- Mark Petruzzi Green Seal (Paints, Coatings and Removers Panel Representative)
- Martha Stevenson World Wildlife Fund
- Reinaldo Figueiredo American National Standards Institute
- Sara Cederberg U.S. Green Building Council
- Saskia Anders Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH
- Shabnam Fardanesh U.S. Department of Energy
- Steven Baer thinkstep
- Timothy Smith University of Minnesota
- Wayne Rifer/Melanie Bowers Green Electronics Council
Paints/Coatings Panel Members:
- Boma Brown West Environmental Defense Fund
- Bradley Fleckner UL Environment
- Daniel Garza State of California – Department of General Services – Procurement Division
- David Rivkin Sustainable Methods Institute
- Doug Mazeffa Sherwin-Williams
- Elizabeth Wagner CalRecycle (California Department of Resources Recycling and Recovery)
- Joanne Rodriguez Tremco, Inc.
- Karl Bruskotter City of Santa Monica
- Kate Lewis U.S. Department of Agriculture
- Keleigh McAllister DSM
- Kelly Scanlon Environmental Protection Agency, OAR, Indoor Environments Division
- Mark Petruzzi Green Seal (Governance Committee Representative)
- Peter Pohlot Brookhaven National Laboratory – U.S. Department of Energy
- Raymond Paulson U.S. Department of Navy
- Rebecca Stevens U.S. General Services Administration – Public Buildings Service
- Stephen Wieroniey American Coatings Association
- Stowe Beam SCS Global Services
Flooring Panel Members:
- Alicia Culver Center for Environmental Health
- Annika Terrana World Wildlife Fund, Inc.
- Bill Brodt NASA
- Bill Freeman Resilient Floor Covering Institute
- Bill Griese Tile Council of North America
- Brian Sause Hardwood Plywood and Veneer Association
- Fareed Ferhut CalRecycle (California Department of Resources Recycling and Recovery)
- James Connelly International Living Future Institute
- John Forbes National Wood Flooring Association
- Larissa Oaks U.S. Green Building Council
- Nadine Block Sustainable Forestry Initiative Inc.
- Paul Firth UL
- Sandra Cannon U.S. Department of Energy
- Sarah Morris-Benavides Ames Laboratory
- Tad Radzinski GreenCircle Certified, LLC
Furniture Panel Members:
- Alex Stone Washington Department of Ecology
- Brad Miller Business & Institutional Furniture Manufacturers Association (Governance Committee Representative)
- Brianna Durkin Battelle Memorial Institute, PNWD
- Chris Geiger San Francisco Department of the Environment
- Fallight Xu TÜV Rheinland
- Jessica Slomka NSF International
- Josh Hosen HPVA Laboratories
- Judy Levin Center for Environmental Health
- Laureen Burton Environmental Protection Agency, Office of Radiation and Indoor Air
- Lynda Rankin Province of Nova Scotia, Internal Services Department, Procurement Services
- Mike Italiano Institute for Market Transformation to Sustainability
- Rita McBride U.S. General Services Administration – Heartland Acquisition Center
- Robert Luedeka Polyurethane Foam Association
- Susan Inglis Sustainable Furnishings Council
- Susan Klosterhaus Cradle to Cradle Products Innovation Institute
- Yalmaz Siddiqui formerly with Office Depot (now with MGM)
Service Sector Panel Members:
- Brennan Conaway U.S. General Services Administration
- Charleen Fain-Keslar State of California, Department of General Services, Procurement Division (Governance Committee Representative)
- Charles Franklin Akin Gump Strauss Hauer & Feld, LLP
- Christina Macken Sustainable Purchasing Leadership Council
- Colleen Olphert Boston College Center for Corporate Citizenship
- David Burdick Sustainable Steps
- Heather Burns Connecticut Sustainable Business Council
- Lindsay Arell Arell Logic
- Marcia Kinter Specialty Graphic Imaging Association
- Margaret Whittaker ToxServices LLC
- Mark Sajbel U.S. Department of Agriculture
- Priya Patel Canadian Standards Association
- Stephen Ashkin Green Cleaning Network & The Ashkin Group LLC
- Thomas Witt Code Earth
- Tobias Schultz SCS Global Services
- Todd Jones Center for Resource Solutions
- William Balek ISSA
- Final Pilot Guidelines
Based on lessons learned from the initial pilot assessments, EPA made slight adjustments to and finalized the pilot Guidelines.
The multi-stakeholder pilot panel and governance committee members also shared their feedback and support with EPA regarding how to provide a more streamlined approach to assessing standards and ecolabels post-pilot. EPA is currently considering options for additional improvements to the Guidelines and the assessment of standards and ecolabels in the future.
- Supplementary Materials
- Executive Order 13834 Regarding Efficient Federal Operations.
- EPA’s Draft Options Paper for the Pilot Governance Committee (October 2016).
- November 2013 Federal Register Notice on the Draft Guidelines.
- Technical Questions and Answers regarding the Draft Guidelines (from November 2013).
- Draft Guidelines – Sections I, III, and IV (November 2013) and Revised Section II (December 2014).
- Briefing on the Draft Guidelines and December 12, 2014 webinar recording.
- Federal Register Notice to launch a pilot to assess standards and ecolabels against Draft Guidelines in three product categories: furniture; flooring; and paints/coatings (March 19, 2015).
- Independent Assessment Entity (IAE) Initial Pilot Assessment Findings and Recommendations.
- For more information on the pilot assessment of standards and ecolabels, please visit Resolve's website. Exit
- Summary Report Assessment for the Product Standards and Labeling Interagency Workgroup (GSA Contractor Report, November 2011). The report summarizes an assessment of relevant ecolabels and environmental standards against an initial set of draft guidelines.