United States
Environmental Protection
Polllution Prevention
and Toxics
EPA742-R-97-002
February 1997
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Environmentally Preferable
Purchasing Program
Environmentally Preferable Purchasing (EPP) ensures that envi-
ronmental considerations are included in purchasing decisions,
along with traditional factors, such as product price and perfor-
mance. The EPP program provides guidance for federal agencies
to facilitate purchases of goods and services that pose fewer bur-
dens on the environment.
For more information about EPP contact:
Pollution Prevention Information Clearinghouse (PPIC)
202260-1023
e-mail: PPIC@EPAMAIL.EPA.GOV
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.*
Foreword
ji^fihe Federal government purchases more than $200 billion worth of goods and services each
year. Recognizing that purchasing decisions have large environmental consequences, the
.^K Federal government is beginning to incorporate environmental considerations into its pur-
chasing practices. As directed in Executive Order 12873 on Federal Acquisition, Recycling, and Waste
Prevention, the U.S. Environmental Protection Agency (EPA) issued its proposed Guidance on
Acquisition of Environmentally Preferable Products and Services to help federal agencies include these
considerations when making purchasing decisions. The proposed Guidance establishes guiding
principles to help identify products and services that have a lesser or reduced effect on human
health and the environment.
EPA's proposed Guidance acknowledges that environmentally preferable purchasing (EPP) is a
dynamic concept that, depending on the product category, will not necessarily be implemented in
the same manner from agency to agency, or even within a specific agency. In order to demon-
strate some of the ways EPP principles are being applied, EPA is documenting various pilot
procurement projects undertaken by Executive agencies, state and local governments, and the
private sector.
The Cleaning Products Pilot Project case study documents the first of these projects. It is a
three-year collaborative effort between the U.S. General Services Administration (GSA) and EPA
to develop a framework for identifying and comparing environmentally preferable commercial
cleaning products. This case study provides an in-depth look at the choices and decisions made by
the GSA/EPA team in implementing this project. It contains useful information about the project
and lessons learned while implementing an EPP framework. More importantly, it demonstrates
the feasibility of including a product's environmental performance into purchasing decisions and
examines the benefits for both Federal customers and private sector manufacturers. We hope that
the lessons and insights documented in this case study will help you and your organization as you
begin incorporating environmental preferability into your purchasing decisions.
111
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Contents
Introduction 1
History of the Cleaning Products Pilot Project 2
Origin 2
Results of the Philadelphia Pilot Project 4
Executive Order 12873 4
Selecting and Evaluating the Environmental Attributes 6
The Great Compromise 7
The GSA Commercial Cleaning Supplies Catalog 9
Current Status of the Cleaning Products Pilot Project 12
Future of the Cleaning Products Pilot Project 13
Lessons Learned 13
Interagency Teamwork Works 13
Be Patient as New Stakeholders Are Introduced 14
Satisfy the Customer 14
Adopt Well-Defined Objectives and Be Pragmatic 14
Additional Product Experience Is Important 15
Does the Informational (Matrix) Model Work? 15
Change Is Slow 15
Vendor Cooperation Is Mutually Beneficial 15
EPA^ Non-Regulatory Role 15
Environmentally Preferable Purchasing and Reinventing Government
Share Important Goals 16
Government Procurement Flexibility Is Important 16
Appendices 17
Appendix I—Cleaning Products Pilot Project Time Line 19
Appendix II—GSA/EPA Memorandum of Understanding 20
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Cleaning Products Pilot Project Case Study
INTRODUCTION
^^Nhe Cleaning Products Pilot Project is a cooperative interagency effort between
the U.S. General Services Administration (GSA) and the U.S. Environmental
.M. Protection Agency (EPA) to establish a framework for identifying and compar-
ing environmentally preferable commercial cleaning products. GSA and EPA began
the project in February 1993, to identify cleaning products with reduced human
health and safety impacts for use in federal buildings. The project originally focused
on identifying the relevant environmental attributes and comparative effectiveness of
various cleaning products. In the early stages of the project's development, President
Clinton issued Executive Order 12873 on Federal Acquisition, Recycling, and Waste
Prevention and the project became the first environmentally preferable product pilot
project under the Executive Order. GSA and EPA are currently measuring the success
of the program and are seeking ways it can be improved.
Although not a project objective, as the first pilot project designed and conducted
to identify and compare environmentally preferable products, the Cleaning Products
Pilot Project is likely to influence the direction of similar pilot projects. Some of the
lessons learned from this pilot may be specific to cleaning products, while others may
be relevant for other product categories. Each environmentally preferable pilot pro-
ject will be unique due to the differences among the product categories examined and
the stakeholders involved in the procurement process.
The project is the
first EPP pilot
under Executive
Order 12873.
Environmentally preferable products are "products and services
[that] have a lesser or reduced effect on human health and the envi-
ronment when compared to other products and services that serve
the same purpose."
—Executive Order 12873 on Federal Acquisition, Recycling, and Waste Prevention
October 20, 1993
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History of the Cleaning Products Pilot Project
The project
began with a
GSA request for
environmentally
preferable
cleaning
products.
A complete
life-cycle
assessment was
impractical.
Origin
GSA's Public Buildings Service (PBS) began the Cleaning Products Pilot Project in
February 1993.1 At that time, the goal was to identify specific cleaning products with
reduced human health and safety concerns for use in cleaning the over 7,700 federal
buildings that PBS oversees. Officials at PBS wanted to develop a list of environmen-
tally preferable cleaning products in five product categories: (1) daily-use products,
(2) floor care systems, (3) carpet cleaners, (4) sweeping compounds, and (5) de-icing
compounds. Unfortunately, most of the publicly available environmental information
on such products consisted of unsubstantiated vendor claims or "home remedies,"
such as cleaning solutions made with lemon juice or vinegar.
PBS officials contacted other GSA officials to help define "green" cleaning prod-
ucts and a team was organized to address the problem. The team met with members
of the Federal Trade Commission (FTC) to explore the possibility of using FTC's
Guide for Use of Environmental Marketing Claims (57 FR 36363, August 13, 1992) to
guide purchasers towards specific cleaning products. After determining that the FTC
guidelines were not intended to be used for this purpose and that identifying environ-
mentally preferable products was outside the scope of FTC's mission, the GSA team
contacted EPA's Office of Pollution Prevention and Toxics (OPPT) for assistance.
OPPT staff explained that as a government agency, EPA is prohibited from endors-
ing or recommending specific commercial products or brand names, even as a cour-
tesy to another government agency. As a result, OPPT declined to recommend
specific products, but agreed to join GSA team members in developing characteristics
that could be used to identify environmentally preferable cleaning products. The pre-
liminary characteristics identified by the GSA/EPA team were: packaging and source
reduction; impact to human health, air, and water; and disposal. In addition, the team
agreed that EPA should, if feasible, examine the life-cycle impacts of cleaning prod-
ucts through a life-cycle assessment.2
While examining the preliminary characteristics, the GSA/EPA team realized that a
complete product life-cycle assessment would be difficult. Such an analysis involves
examining the environmental effects across five different product stages: (1) premanu-
facturing, (2) manufacturing, (3) distribution and packaging, (4) use, and (5) waste dis-
posal. The time required for a complete, or even abbreviated, life-cycle assessment
exceeded GSAk need to implement the program quickly and better serve its customers.
As a result, the GSA/EPA team decided to focus primarily on one stage in the life-
cycle—product use. Product use was selected because the greatest direct health risk
from cleaning products to janitorial workers and building occupants occurs during use.
1 While the Cleaning Products Pilot Project did not begin until 1993, it builds upon work completed by
GSAs Biodegradable Cleaners/Degreasers Project, which began in 1988.
2 A life-cycle assessment (LCA) is a process for evaluating the environmental burdens associated with a
product, process, or activity. LCAs identify and quantify energy and material uses and releases to the
environment. The assessment covers the entire life-cycle of the product, process, or activity, including
extracting and processing the raw materials; manufacturing, transporting, and distributing the product;
product use, reuse, and maintenance; recycling; and final disposition.
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Reinventing the Way Government Does Business
Under the Reinventing Government initiative launched by President Clinton
and Vice President Gore, GSA was tasked with improving government procure-
ment methods. Under this initiative, GSXs Commercial Products Acquisition Lab
(CPAL) is developing procedures to allow GSA customers to purchase commer-
cially available items in addition to products based on government specifications.
Cleaning products are among the first commercially available items under this
reinvention program.
Additional GSA reinvention efforts include improving the GSA Advantage!
system, an electronic shopping service available to Federal purchasers over the
Internet, and facilitating government use of commercial credit cards, which are
intended to streamline procurement and payment procedures.
In addition to product use, the GSA/EPA team also agreed to examine product
packaging because the packaging used to deliver cleaning products affects its use and
resulting exposure. Some cleaning products, for example, are purchased as concen-
trates to minimize storage requirements. Concentrated cleaning solutions can increase
worker exposure and the associated human health risks. There are packaging and
delivery systems available, however, that minimize storage requirements, reduce
worker exposure, and reduce environmental impact during product distribution and
disposal.
The GSA/EPA team brought the preliminary environmental product characteris-
tics to the attention of the Federal Supply Service (FSS), GSA's procurement and sup-
ply division, to determine if they could be incorporated into their Supply Catalog.
Coincidentally, as part of President Clinton's Reinventing Government initiative,
FSS's Paint and Chemical Commodity Center was already working on a similar pro-
ject, which was based on GSXs Biodegradable Cleaners/Degreasers Project that
began in 1988. The Federal Supply Schedule Contract for Biodegradable
Cleaners/Degreasers (solicitation number FTC-92-MT-7906B) was already underway
to identify commercially available biodegradable cleaners and degreasers. GSA^ rein-
vention initiatives provided the flexibility necessary for FSS members to join the pro-
ject team and help evaluate the preliminary environmentally preferable product
characteristics.
Over a five month period, from November 1993 to March 1994, the GSA/EPA
team met with numerous commercial cleaning stakeholders, including manufacturers,
vendors, public interest groups, commercial janitorial companies, industry trade asso-
ciations, and unions to help identify cleaning product attributes that result in fewer
burdens on human health and the environment. The stakeholders included: 3M, Abel
Industries, Inc., AFL-CIO, Amway Corporation, Buckeye International, Chemical
Manufacturers Association, Chemical Specialties Manufacturers Association, Cotto-
Waxo Co., Earth Friendly Products, Ecolab, Environmental Choice Program
(Canada), Fragrance Materials Association, Gotham Building Maintenance, Green
Seal, Hillgard Industries, International Sanitary Supply Association, L&F Products,
National Aerosol Association, Ossian, Inc., Procter and Gamble, Rochester Midland,
SC Johnson & Son, Service Employees International Union, Soap and Detergent
Association, Sunshine Makers (Simple Green), Vista Chemical Company, and the
Washington Toxics Coalition.
Over 25
stakeholders
were involved.
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Nineteen
cleaning
products were
evaluated in a
field test.
Results of the Philadelphia Pilot Project
In May 1993, while team meetings continued, GSA and EPA began a small scale
pilot project at the James A. Byrne Federal Courthouse in Philadelphia to examine
the performance, human health, and environmental safety effects of a variety of clean-
ing products. Nineteen cleaning products (including all purpose cleaners, glass and
toilet bowl cleaners, disinfectants, and degreasers) were divided into four test groups.
The first three groups included alternative cleaning products that were believed to be
less harmful to human health or the environment based on product literature and
information obtained from Material Safety Data Sheets (MSDSs). The fourth group
was used as a baseline and included a subsample of the cleaning products previously
used by the courthouse custodial staff.
Each group of products was used for a one month cycle. At the end of each cycle,
the 45 member custodial staff was surveyed to measure the cleaning effectiveness of
each product on each of the surfaces typically found in government buildings. The
staff was asked to rate each of the products on a scale from one (poor performance) to
five (superior performance). The staff was also surveyed to determine if the products
could be linked to any adverse health factors including headaches, dizziness, upset
stomach, coughing, or throat, eye, or skin irritation.
The results of the survey suggested that the alternative cleaning products in cycle
three were more effective than the other alternative cleaning products and were near-
ly as effective, in terms of cleaning effectiveness, as the baseline products. The base-
line cleaning products had an average efficacy rating of 3.75 (on the five point scale
described above), while the alternative cleaners in cycle three had an efficacy rating of
3.59. Although the baseline cleaning products were slightly more effective, according
to the survey respondents, the health problems associated with them were significant-
ly higher. Sixteen percent of the staff reported health problems with the baseline
products, while only nine percent reported health problems with the alternative clean-
ing products in cycle three.
Executive Order
12873 was
issued eight
months into the
project.
Executive Order 12873
In October 1993, while the Philadelphia pilot was being conducted, President
Clinton issued Executive Order 12873 on Federal Acquisition, Recycling, and Waste
Prevention. Although the Executive Order supported the type of project that the
GSA/EPA team was developing, the Executive Order also temporarily disrupted the
project's momentum. Several sections of the Executive Order increased EPA^ respon-
sibilities for shaping federal agency procurement programs for environmentally
preferable products. Specifically, section 503 mandated that EPA "issue guidance that
recommends principles that Executive agencies should use in making determinations
for the preference and purchase of environmentally preferable products."
Pursuant to the Executive Order mandate, an EPA team, which included some
members of the GSA/EPA cleaning products project, was assigned to draft environ-
mentally preferable guidance for use by Executive agencies. Some of the initial guid-
ance proposals, however, conflicted with proposals being considered by the cleaning
products project team. As a result, progress stalled on the GSA/EPA cleaning prod-
ucts project while EPA was developing the section 503 guidance.
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EPA's Environmentally Preferable Guidance
EPA established seven guiding principles to help federal agencies incorporate envi-
ronmental preferability into their procurement practices. These principles were
proposed in EPA^ Guidance on Acquisition of Environmentally Preferable Products and
Services (60 FR 50722):
1) Consideration of environmental preferability should begin early in the acquisi-
tion process and be rooted in the ethic of pollution prevention, which strives
to eliminate or reduce, up front, potential risks to human health and the envi-
ronment.
2) A product or service's environmental preferability is a function of multiple
attributes.
3) Environmental preferability should reflect life-cycle considerations of prod-
ucts and services to the extent feasible.
4) Environmental preferability should consider the scale (global versus local) and
temporal reversibility aspects of the impact.
5) Environmental preferability should be tailored to local conditions where
appropriate.
6) Environmental objectives of products or services should be a factor or subfactor
in competition among vendors, when appropriate.
7) Agencies need to examine product attribute claims carefully.
Meanwhile, the GSA and EPA Administrators signed a memorandum of under-
standing (MOU), which had been under development before the Executive Order was
signed, formalizing their cooperation on the cleaning project. After resolving incon-
sistencies between the EPA environmentally preferable guidance and the GSA/EPA
cleaning products project, the GSA/EPA cleaning products project became the first
environmentally preferable product pilot project under the Executive Order.
While the GSA/EPA project was integrating the principles of the EPA environ-
mentally preferable products guidance, some of the vendors that had voluntarily
cooperated with the cleaning project became alarmed by some of the language in
EPA's proposed guidance. They feared that EPA, as a result of the Executive Order,
would initiate additional regulations for the cleaning industry. This misunderstanding
temporarily reduced the willingness of some vendors and trade associations to
cooperate.
GSA and EPA
signed an MOU
formalizing their
cooperation.
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EPA examined
numerous
environmental
attributes.
Selecting and Evaluating the Environmental Attributes
Following the completion of the Philadelphia pilot project, EPA initiated a com-
parative risk management assessment of the 19 cleaning products, known as an RM1
assessment.3 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 expo-
sure 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 (VOCs)—VOCs are known to con-
tribute to smog formation.
• Amount of product packaging—Products with reduced packaging (sold as con-
centrates) decrease the volume of waste that must be disposed of.
• Presence of ozone depleters—Ozone depleting components should be mini-
mized.
• Potential exposure to the concentrated cleaning solution—The product dis-
pensing method should include safety precautions designed to minimize exposure
to the concentrated solution.
• Flammability—Non-flammable products are preferable.
• Presence of cosmetic additives (fragrances and dyes)—Cosmetic additives can
be considered unnecessary additives that increase overall life-cycle impacts and that
could increase health and safety and ecological concerns. However, cosmetic addi-
tives 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 con-
sumption.
An RM1 is a preliminary risk management assessment to determine if the human health or environ-
mental risks associated with product components warrant further investigation. The RM1 conducted as
part of the Cleaning Products Pilot Project was different from traditional RM1 assessments because
attributes other than those directly associated with risk, like product packaging, were also evaluated.
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EPA encountered several limitations while conducting their comparative assess-
ment of the 19 cleaning products. The limitations included: difficulties in obtaining
complete product formulation information; incomplete hazard and pharmacokinetics
information for most product components; and 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 Cleaning Products Pilot Project.
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 deter-
mined 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 cri-
teria 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 environ-
mental 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 Cleaning Products Pilot Project.
Second, because the information being examined was to be used by federal pur-
chasers, 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 EPAk recommendations, that information that
fails to distinguish one product from another is not useful for comparing environmen-
tal preferability.
EPA narrowed
the list of
attributes.
The Great Compromise
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 Cleaning Products Pilot Project 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 debated
several
ways to
distribute the
information.
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The team
debated between
a "green dot"
and an attribute
matrix.
The GSA/EPA team considered two primary methods of identifying environmen-
tally 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 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 predeter-
mined 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 environ-
mental 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 prefer-
able products a "green dot" makes it easier for buyers, it also obscures vital environ-
mental 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 clean-
ing 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 pro-
vides 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 cri-
teria. Providing Federal purchasers with environmental attribute information for each
cleaning product, however, allows them to select those products with the environmen-
tal 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 contin-
ually improve the environmental performance of their products.
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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 GSAk Biodegradable Cleaners/Degreasers solic-
itation (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 promi-
nently 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 seven environmental attributes — skin
irritation, food chain exposure, air pollution potential, fragrances, dyes, packaging,
and potential concentrate exposure. These attributes are listed in a matrix, which
allows purchasers to compare products based on the environmental attributes most
critical for their geographic region and intended use.
The GSA Commercial Cleaning Supplies Catalog
Commercial Cleaning Supplies catalog contains hundreds of commercially
available cleaning supplies, ranging from soaps and disinfectants to mops and buckets.
The February 1996 edition of the catalog introduced a 13 -page section devoted to
biodegradable cleaners and degreasers, including 48 cleaning and degreasing products
from 30 suppliers. In addition, 28 of the 48 products are listed in a matrix that pro-
vides additional information on the seven environmental attributes for each product,
voluntarily provided by the manufacturers and suppliers. The catalog explains the
environmental and human health and safety significance of each attribute and GSA
customers are encouraged to consult the matrix to balance environmental, health and
safety, performance, and cost tradeoffs when selecting a cleaning product. The origi-
nal matrix is reprinted on pages 10 and 11.
Following publication of the original environmental attribute matrix, more than 60
manufacturers and suppliers contacted GSA to ask about being included in future
matrix updates. Manufacturers provided environmental attribute information for
three additional products, which were added to the matrix and published in the
March 1997 catalog. GSA also expanded the matrix to include all of the products
listed in the biodegradable cleaners and degreasers section of the catalog. In addition,
the updated matrix also includes the National Stock Numbers for each product,
which makes ordering easier for government buyers. (Call 800 241-7246 to request
the most recent catalog.)
The final
approach
combines both
methods.
The matrix was
introduced in the
February 1996
GSA catalog.
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BIODEGRADABLE CLEANERS AND DEGREASERS
Product Attribute
Product
Alfa Kleen
AK-020
Allied Clean Free
ASP Alpine Cleaner
Caljen Fast Clean
Charlie
Chemco
Enviro-Chem 09SA
Chemco Kleenzol 148
Cooke Tuff Job
Cooke Easy Job
Earth Clean
Systems Degrease
Electro ECD- 101
ERL E-Z Does It
ERL Grease Cutter
Gaylord Formula
G-S10
L&B (Arrowak)
Klean E-Z
L&B (Arrowak)
Klean E-Z Concentrate
PCIHurrisafe9010
PCI Hurrisafe 9030
PCI Hurrisafe 9040
Rochester Biogenic
377C
Sunshine Simple Green
SOQ Ecomate
Webaco Scuzz-RTU
Webaco Scuzz
West Penetone
Citrikleen Aerosol
West Penetone Citrikleen
West Penetone
Citrikleen HD
West Penetone
PenairHD-1
Matrix
Food Chain
Exposure Air Pollution
Skin (Bio concentration Potential
Irritation factor) (% VOC)
Not Reported
ST
Not Reported
ST
M
M
SL
M
SL
N-SL
SL
M
M
Exempt
Not Reported
Not Reported
N-SL
SL
SL
SL
N-SL
SL
ST
ST
M
M
M
M
Not Reported
Not Reported
Not Reported
12000
Exempt
Not Reported
Not Reported
12000
Exempt
Exempt
Exempt
Not Reported
Not Reported
8165
Exempt
Exempt
Exempt
Exempt
Exempt
Exempt
Exempt
Exempt
Exempt
Exempt
Exempt
Exempt
Exempt
Exempt
N/A
N/A
N/A
3.5
Not Reported
8
10
4.2
NA
NA
NA
12.7
12.7
2
8
15
1
0.8
NA
3.3
31
6
10.5
10
Contains
Fragrance
No
Yes
No
No
No
No
No
No
No
No
No
Yes
No
No
Yes
Yes
No
No
No
No
Yes
No
No
No
No
No
No
No
Contains
Dye
No
Yes
No
No
No
Yes
Yes
Yes
No
No
No
Yes
No
No
Yes
Yes
No
No
No
No
Yes
No
No
No
No
No
No
No
Reduced/
Recyclable
Packaging
Yes/Yes
Yes/Yes
Yes/Yes
Yes/Yes
No/NA
Yes/Yes
Yes/Yes
Yes/Yes
Yes/Yes
Yes/NA
No/Yes
No/NA
No/NA
Yes/Yes
Yes/Yes
Yes/Yes
No/NA
Yes/NA
Yes/NA
Yes/NA
Yes/Yes
Yes/Yes
No/NA
Yes/NA
No/NA
Yes/NA
Yes/NA
No/NA
Product
Minimizes
Exposure to
Concentrate?
-
-
-
NA
-
-
NA
NA
NA
NA
-
+
0, Larger units,
(— ) smaller units
-
NA
-
NA
-
NA
10
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Ratings by Various Attributes
1. Skin Irritation
fl^ Some ready-to-use cleaning products may contain
^ chemicals that will cause redness or swelling of
Jfc \ skin. If possible skin irritation is a concern, prod-
^^^/^"^ ucts rated as negligible (none to slight) would be
most preferable for this attribute. From most
preferable to least preferable, select negligible (N),
slight (SL), moderate (M), or strong (ST), in that order. An
"Exempt" means that all chemical components in the ready-to-
use product are less than 5% by weight.
2. Food Chain Exposure
Some ready-to-use cleaning products may contain
ingredients that will be taken up by smaller aquat-
ic plants and animals and increase in concentra-
tion through the food chain as these plants and
animals are consumed by larger animals. If you
intend to use these products in areas where wastewater
is adequately treated, this attribute may be less important as an
environmental impact. If you intend to use these products in
areas where wastewater treatment is less efficient, this attribute
may be more important to you. We measure this attribute by
recording its bioconcentration factor (BCF). Products with a
BCF less than 1000 and products for which this attribute is
"exempt"are more preferable for this attribute.
3. Air Pollution Potential
Products may contain volatile organic compounds
(VOCs). When these products are used, the
I VOCs may escape to the atmosphere and react to
form smog. Smog and other atmospheric pollu-
tants have been shown to cause irritation of the
eyes, nose, throat and lungs and to cause asthma
attacks. Many state and local authorities have restrictions on the
use of VOCs. The numbers reported refer to the percent by
weight of VOCs in the ready-to-use product. "NA" (not applic-
able) indicates that there are no VOCs of concern present. The
lower the number, the more preferable the product. An "NA"
would be most preferable for this attribute.
4. Fragrances
This attribute does not refer to natural odors which
k are associated with cleaning agents (e.g., a lemon
odor in a citrus-based cleaner). It refers instead to
fragrances that are added to the formulation to
improve its odor or to mask an offensive odor.
While fragrances added to a formulation have little
cleaning value, they may provide aesthetic benefits important to
many users. On the other hand, some people prefer products
without added fragrances. A basic principle of pollution preven-
tion is to avoid additives that are unnecessary. A "Yes" indicates
that fragrances have been added; a "No" indicates that they
have not been added.
5. Dyes
This attribute refers to dyes that have been added
to a formulation to enhance or change the color
of the product. While the addition of these dyes
contributes little to the cleaning value of the
product, it may be important for safety reasons.
These additives may help end users differentiate
between products by color or to prevent misidentification as
other liquids, such as water. Again, a basic principle of pollution
prevention is to avoid unnecessary additives. If dyes are present
not as a safety feature but for aesthetic reasons, they may not be
providing a necessary function. End users must decide what is
necessary in their specific situations. A "Yes" indicates that dyes
have been added to the product; a "No" indicates that they
have not been added.
6. Packaging-Reduced/Recyclable
A product's packaging can account for a significant
portion of the product's contribution to munici-
pal solid waste. Packaging is a large component
of municipal solid waste landfills. The EPAs rec-
ommended approach to managing solid waste is,
first, reduce packaging of products and, second, recycle
packaging materials. The EPA has issued guidelines for this
attribute for vendors to follow. This is a two-part answer. For
the first part, a "Yes" signifies that the product is packaged as a
concentrate; a "No signifies that it is not. The second part is
applicable only if paper packaging is used. Paper packaging
should be consistent with applicable recovered materials recom-
mendations set forth in 60 FR 21386, 5/1/95 or draft recovered
materials recommendations found in 60 FR 14190, 3/15/95. A
"Yes" signifies that the vendor has met EPA guidelines for this
attribute. These products would be more preferable for this
attribute. An "NA" indicates that no paper packaging was used.
Because the product may be shipped as a concentrate,
please also consider the next attribute.
7. Product Includes Features to Minimize Exposure
to Concentrate
Although packaging a product in concentrated
form may result in reduced packaging, it raises
the potential that the end users of the product
will be exposed to the concentrate. Exposure to
the concentrate may place the end user at greater
health risk than exposure to the ready-to-use product.
A "+" in this column indicates that the concentrate is part of a
system by which chemicals are transferred only among closed
containers. This offers less exposure potential. A "0" in the col-
umn indicates that the concentrate is premeasured and
prepackaged but not designed to be transferred among closed
containers. A "-" in the column indicates that the concentrate is
shipped without specific exposure controls. This offers greater
exposure potential. "NA" means that the product is not a con-
centrate.
Because the information on these attributes is intended only for
purposes of relative comparison, it does not substitute for other
guidance on safe product usage. The information on environ-
mental attributes should help you decide which products to
buy; it does not provide guidance on HOW to use the prod-
ucts. You should continue to carefully follow guidance on
Material Safety Data Sheets, labels and other product-specific
information to ensure safe usage.
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Current Status of the Cleaning Products Pilot Project
Sales of
environmentally
preferable
cleaners have
increased.
Over 30,000 copies of GSAs Commercial Cleaning Supplies catalog have been
distributed. Based on limited anecdotal evidence, the reaction from customers
and vendors has been very positive. GSA and EPA are currently conducting a
study to further evaluate their responses. The purpose of the study is to determine if
the matrix is useful to federal consumers when they make purchasing decisions. The
study will also determine if the current list of attributes meets government buyers'
needs.
GSA and EPA are beginning extensive outreach efforts to explain how the use of
the environmental attribute matrix can help federal agencies select appropriate envi-
ronmentally preferable cleaning products. At a recent meeting of PBS purchasing
staff, attendees expressed their appreciation for the information provided in the
matrix. They believe that the matrix will allow them to respond to the health and
safety and environmental concerns of their custodial staffs without reducing effective-
ness or increasing cost.
The GSA/EPA team is also attempting to quantify the effect their efforts have had
on the sale of environmentally preferable, biodegradable cleaning products. The sale
of such products has steadily increased since the project began. The federal govern-
ment has contributed to this increase by procuring over $12.2 million worth of
biodegradable cleaning products since 1993. It is unknown at this point how much of
the recent procurement increases can be attributed to the successes of the Cleaning
Products Pilot Project or to general increased sensitivities about the environmental
impacts of procurement practices. The GSA/EPA team believes, however, that these
positive trends will continue due, in part, to the success of the project.
In addition to quantifying increased sales, the GSA/EPA team is attempting to
quantify the environmental benefits associated with the increased use of environmen-
tally preferable cleaning products. Several methods of quantifying this data are being
considered, including working with the Service Industry Employees Union (SIEU) or
the American Association of Poison Control Centers to obtain information on custo-
dial health complaints.
EPA is helping FTC promote the existence and use of FTC's Guides for the Use of
Environmental Marketing Claims. The guidelines are designed to prevent the false and
misleading use of environmental terms such as "recyclable," "degradable," and "envi-
ronmentally friendly" in the advertising and labeling of products. EPA is promoting
their use among all manufacturers because it provides customers with accurate infor-
mation regarding the environmental impact of their purchasing decisions. EPA is pro-
moting use of the guidelines among cleaning product manufacturers so that the
information they voluntarily provide for use in the environmental attributes matrix is
accurate. EPA is also promoting their use among federal customers and suppliers to
facilitate a general understanding of environmental marketing terminology.
Finally, the GSA/EPA team has initiated discussions with research teams at the
University of California at Los Angeles (UCLA) and the City of Santa Monica, both
of which are working on projects to quantify the advantages of using environmentally
preferable cleaning products.
12
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Future of the Cleaning Products Pilot Project
In addition to promoting and quantifying the use of the environmental attribute
matrix, the GSA/EPA team is working to refine it. The team will be evaluating
customer and vendor feedback to identify and remove attributes that have only
minimal impacts on procurement decisions. Additional attributes related to human
health impacts are also being considered, including increased dermal sensitization,
chronic health risks, birth defects, and cancer risks.
Federal contracting officials are revising contract language and procedures to facili-
tate environmentally preferable purchasing by contractors. When new PBS cleaning
service contracts are negotiated, for example, contractors are advised to consult the
environmental attribute matrix in GSXs Commercial Cleaning Supplies catalog during
pre-bid and post-award meetings with PBS officials.
GSA and EPA are also working closely with other Executive agencies and the U.S.
Postal Service (USPS) to incorporate environmentally preferable cleaning products
into existing procurement programs. In addition, the GSA/EPA team has provided
information to USPS to develop a procurement training module emphasizing the
environmental effects of procurement decisions, using the results of the Cleaning
Products Pilot Project as a starting point.
GSA is also interested in expanding its customer base because it must be financially
self-supporting and is no longer a mandatory source for government purchases. The
Federal Acquisition Streamlining Act (FASA) of 1995 allows GSA to expand their cus-
tomer base by permitting state and local governments to buy products and services
from GSA^ FSS schedules. Although implementation of this section of FASA is cur-
rently on hold, if the GSA schedule is opened to non-federal customers, the environ-
mental attribute matrix developed by the GSA/EPA Cleaning Products Pilot Project
will enjoy greater visibility, which will likely increase GSA's cleaning product sales.
EPP is being
incorporated into
new contracts.
Lessons Learned
^^Whe Cleaning Products Pilot Project is the first pilot project under the proposed
Guidance for Acquisition of Environmentally Preferable Products under Executive
M. Order 12873. As a result, many of the lessons learned could help guide future
pilot projects. The following are highlights of some of the most important lessons
learned:
Interagency Partnership Works
Interagency teamwork is not always easy due to different agency missions and cul-
tures. In the Cleaning Products Pilot Project, for example, PBS officials were origi-
nally hoping for a list of environmentally preferable cleaning products that it could
immediately begin using in the 7,700 Federal buildings it oversees. At times, PBS
13
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officials felt that EPA was taking too long to reach consensus with manufacturers,
trade associations, and vendors. PBS officials would have preferred to "just do it" and
at times felt that things would have progressed more rapidly without EPA's participa-
tion. Similarly, GSA^ ESS was primarily concerned with the demands of their cus-
tomers—the federal purchasers—and feared that some of EPA^ technical proposals
were too difficult to convey and would be ineffective.
EPA, on the other hand, wanted to accomplish three goals—(1) ground environ-
mentally preferable determinations in hard science, (2) provide the customer with as
much environmentally relevant information as possible, and (3) satisfy the needs of
GSA, EPA, and the requirements of Executive Order 12873, while taking into consid-
eration the diverse views of the stakeholders.
Despite these differences, GSA and EPA's collaborative effort produced a more
effective and scientifically sound approach to the pilot project than would have been
developed if the agencies had acted independently. GSA contributed extensive clean-
ing product and procurement experience and EPA brought significant scientific, tech-
nical, and environmental expertise to the project. As a result, the project developed an
approach that successfully meets the objectives of a broad audience, including clean-
ing product trade associations, manufacturers, unions, vendors, janitorial contractors,
and users.
Be Patient as New Stakeholders Are Introduced
One of the unexpected difficulties encountered by the Cleaning Products Pilot
Project team was identifying all of the stakeholders. Although attempts were made to
identify all potential stakeholders before the project began, new stakeholders appeared
at various times throughout its development. Each new stakeholder presented their
own understanding of environmentally preferable purchasing and these understand-
ings were not always compatible with the previous consensus. As a result, significant
time was spent explaining, defending, and modifying decisions that had been made
earlier in the process.
Satisfy the Customer
The customers in the Cleaning Products Pilot Project are Executive agency per-
sonnel who purchase cleaning products through GSA. Procedures for identifying
environmentally preferable products must be easy for them to follow. Otherwise, the
ultimate goal to increase the purchase of such products will not be achieved.
While the environmental attribute matrix was under development, the GSA/EPA
team consulted with some of the government purchasers who would be using it.
Their input was invaluable. For example, the language used in the catalog to explain
how to use the matrix was crafted with the help of purchasing agents. Customer input
helped guide the direction of the project and will help ensure its success.
Adopt Weil-Defined Objectives and Be Pragmatic
The Cleaning Products Pilot Project has been successful, in part, because the pro-
ject began with a narrow, but well-defined scope. The project was not designed to
develop criteria for evaluating the environmental preferability of all cleaning products
purchased by the government. Instead, the team decided to focus on evaluating a par-
ticular subset of cleaning products—daily-use general purpose cleaners and
14
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degreasers—and identifying specific environmental attributes that would allow pur-
chasers to select appropriate products. Additional cleaning products, such as floor care
systems, carpet cleaners, sweeping compounds, and de-icing compounds, were not
included in the pilot project because the additional attributes necessary for evaluating
their environmental preferability were too numerous to include in one pilot project.
Additional Product Experience Is Important
The information gathered during the Cleaning Products Pilot Project's small-scale
Philadelphia pilot project and the RM1 provided an objective framework for compar-
ing the relevant environmental attributes. Direct product experience is invaluable and
necessary for adequately understanding the environmental and health and safety issues
that must be considered when evaluating a product's environmental preferability. This
further illustrates the importance of bringing together a team that includes the prod-
uct's end user, along with procurement and environmental experts.
Does the Informational (Matrix) Model Work?
One of the earliest debates within the Cleaning Products Pilot Project was whether
to use a "green dot" to identify environmentally preferable cleaning products or
whether to adopt an informational (matrix) model. The supporters of the "green dot"
approach were concerned that customers would not use additional environmental
information if it were provided. Initial responses to an informal customer survey sug-
gests otherwise. Customers have found the information "very useful." The GSA/EPA
team is continuing efforts to assess the effectiveness of the informational approach
through more formal means.
Change Is Slow
At the time this report was written, the GSA Commercial Cleaning Supplies catalog
had been available for less than a year. While sales of biodegradable cleaners have
steadily increased, they are still only a small part of the overall cleaning products mar-
ket, even among government customers. Information dissemination is slow because
government procurement is so decentralized. One GSA official compared changing
the government's procurement procedures with turning the Queen Mary cruise ship
in a bathtub, "It's not impossible, it just takes time and patience."
Vendor Cooperation Is Mutually Beneficial
Despite constraints limiting GSA and EPA's ability to gather complete cleaning
product formulations, the Cleaning Products Pilot Project succeeded in developing
practical and effective methods that allow purchasers to make environmentally prefer-
able decisions based on information voluntarily provided by vendors. While not all
vendors cooperated equally, those that provided information for the matrix have
enjoyed increased visibility in GSAk Commercial Cleaning Supplies catalog.
EPA's Non-Regulatory Role
While the GSA/EPA team members acknowledge that EPA^ involvement with the
Cleaning Products Pilot Project was a crucial component in its success, some manu-
facturers and vendors were reluctant to voluntarily provide product information
because of concerns that EPA was preparing to regulate the industry. These fears
15
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were alleviated once they understood EPA's non-regulatory role and realized that the
project was for their benefit, as well as the benefit of government customers, the gen-
eral public, and the environment.
Environmentally Preferable Purchasing and Reinventing
Government Share Important Goals
The Clinton Administration's Reinventing Government initiative is intended to
improve federal government efficiency and responsiveness. Consistent with those
goals, the Cleaning Products Pilot Project developed simplified methods that can be
used by thousands of federal government purchasers worldwide to identify and buy
environmentally preferable cleaning products. The matrix developed by the
GSA/EPA team also allows the procurement agents to be more responsive to building
tenants, custodial staffs, and local communities' environmental needs.
Government Procurement Flexibility Is Important
One of the most important reasons for the continued success of the Cleaning
Products Pilot Project is a recent change in the way in which products and services
can be purchased. Under President Clinton's Reinventing Government initiative, fed-
eral agencies are allowed to purchase commercially available products. This change
allowed GSA to introduce environmentally preferable cleaning products to federal
buyers faster than it could have under the previous system. It used to be necessary to
develop government specifications for each cleaning product, a process that required
significant time and resources. The increased flexibility under the new procurement
procedures allows government buyers to immediately switch to environmentally
preferable cleaning products.
The additional flexibility has also allowed GSA to expand its role beyond managing
government contracts and overseeing supply. GSA is becoming a vital source of prod-
uct information. GSXs Commercial Products Acquisition Laboratory (CPAL), for
example, is currently investigating numerous commercially available products that
could be made available to government customers at GSAs discounted rates. The per-
formance and attribute information GSA is collecting will be made available to gov-
ernment customers to help them select products appropriate for their needs. GSA^
new role will save federal buyers significant time and money because they will not
have to independently collect the information necessary to compare products.
A more general benefit of the federal government's increased purchasing flexibility
and emphasis on environmentally preferable purchasing results from the influence the
government's purchasing preferences have on the consumer market. The government
market is large enough that manufacturers will begin developing additional products
with beneficial environmental attributes. These products will also be available to the
public, which will result in an increase in the availability and use of environmentally
preferable products.
16
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Appendices
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Appendix I: Cleaning Products Pilot Project Timeline
February 1993
May - December 1993
October 20, 1993
November 20, 1993
November 1993 -
March 1994
June 1994
December 13, 1994
June 5, 1995
June 9, 1995
July 1995
August 1995
August 1995
September 29, 1995
October 26, 1995
March 8, 1996
GSA and EPA begin a cooperative project to develop procedures for
identifying environmentally preferable cleaning products.
A small scale pilot project begins examining 19 cleaning products in
Philadelphia, PA.
President Clinton signs Executive Order 12873.
A Memorandum of Understanding is signed between EPA and GSA that
outlines their efforts on the Cleaning Products Pilot Project.
GSA and EPA hold a series of stakeholder meetings with industry groups,
labor unions, manufacturers, and vendors to discuss environmental
procurement.
The Final Report East Philadelphia Field Office Pilot Study on Cleaning
Systems is released.
GSA and EPA hold an interagency focus group meeting to discuss
environmental procurement issues.
GSA/EPA hold a series of meetings and briefings on the pilot project.
GSA sponsors a meeting with 12 affected vendors and trade associations to
discuss information requests.
EPA formats the environmental attribute information in a matrix that will
be modified by the GSA/EPA team and published in the GSA catalog.
EPA completes the RM1 for the 19 GSA cleaning products tested as part
of the Philadelphia experiment.
GSA/EPA complete the Draft Guidance Document for Reporting
Information on Environmental Attributes of Cleaning Products and Their
Components.
EPA publishes a Federal Register notice announcing proposed Guidance
for Acquisition of Environmentally Preferable Products and Services and
establishes seven guiding principles.
EPA holds a public meeting on the proposed general guidance on
environmentally preferable products.
GSA Commercial Cleaning Supplies catalog is published, which includes
the Biodegradable Cleaners and Degreasers section and environmental
attributes matrix.
Dates that are not bolded reflect events that occurred independently of the Cleaning Products Pilot Project.
They are included as reference points.
19
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r
Appendix II: GSA/EPA Memorandum of Understanding
MEMORANDUM OF UNDERSTANDING AND AGREEMENT
BETWEEN
THE ENVIRONMENTAL PROTECTION AGENCY
AND
THE GENERAL SERVICES ADMINISTRATION
IN THE SPIRIT OF COOPERATION AND TO IMPROVE WORK ENVIRONMENTS IN
THE FEDERAL COMMUNITY an understanding and agreement is hereby established
between the Environmental Protection Agency (EPA) and the General Services
Administration (GSA) to examine materials used in the operation of Federal buildings.
IT IS UNDERSTOOD THAT AN INTERAGENCY AGREEMENT PURSUANT TO THE
ECONOMY ACT (31 U.S.C. 1535) is hereby authorized and will be executed between
the two agencies for the purpose of implementing the goals and objectives of this
Understanding and Agreement.
THROUGH THE INTERAGENCY AGREEMENT, the EPA and the GSA will work
together to provide quality work environments within the Federal workplace and take a
proactive role regarding environmental quality issues as they relate to the Federal
community; distribute information obtained through the efforts of this collaboration;
raise awareness among the general population concerning environmental quality
issues and building safety issues; an^i promote the environmentally preferred
technologies in the Federal workplace.
Administrator
Environmental Protection
Agency
1993
Date (
Admini
Genera
Date
of
ervices
20
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We want to hear from you! Please tell us about your EPP activities and
efforts. We are collecting and sharing information, tools, and hints
about what works and what doesn't, as environmentally preferable pur-
chasing evolves and expands. Please contact the EPP program by e-mail,
regular mail, or fax:
Eun-Sook Goidel
Environmentally Preferable Purchasing Program
U.S. Environmental Protection Agency
401 M Street, SW (7409)
Washington, DC 20460
e-mail: goidel.eunsook@epamail.epa.gov
FAX: 202 260-0178
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&EPA
United States
Environmental Protection Agency
(7409)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
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