United States
Environmental Protection
Pollution Prevention
and Toxics
November 1999
Environmentally Preferable Purchasing Program

Painting the Town Green

Aberdeen Proving Ground's
Paint Pilot Project
  > Printed on paper that contains at least 30 percent postconsumer fiber.


                          Environmentally  Preferable

                               Purchasing Program

                         Environmentally preferable purchasing ensures that
                      environmental considerations are included in purchasing
                      decisions along with traditional factors such as product
                      price and performance. The EPP program provides guid-
                      ance for federal agencies to facilitate purchases of goods
                      and services that pose fewer burdens on the environment.
        For more information about environmentally preferable purchasing or EPA's EPP Program,
               please visit our Web site at , or contact:
                       Pollution Prevention Information Clearinghouse (PPIC)
                                    e-mail: PPIC@EPA.GOV

      This document provides an overview of a federal government EPP initiative and includes references to
  specific products and companies. These references are included to provide additional detail and do not constitute
endorsement or recommendation for use by the U.S. Environmental Protection Agency or the Department of Defense.

      The federal government purchases more than $200 billion worth of goods and
      services each year. Recognizing that purchasing decisions can have environmen-
      tal consequences, the federal government is incorporating environmental con-
siderations into  its purchasing practices. As mandated in Executive Order 13101,
Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition,
the U.S. Environmental Protection Agency (EPA) issued guidance to help federal
agencies consider environmental concerns when making purchasing decisions. The
guidance establishes principles to help identify products and services that have a
reduced impact  on human health and the environment.

   EPA also issued a policy statement describing how federal agencies could make
environmentally preferable purchasing (EPP) decisions based, in part, on information
provided by nongovernmental entities such as third-party environmental standards or
certification organizations.  In its policy statement, EPA emphasizes that federal agen-
cies must make  all final determinations regarding environmental preferability and pur-
chasing decisions and cannot rely on nongovernmental entities to make such

   EPA, through its guidance and policy statements, recognizes that EPP is a dynamic
concept that, depending on the product category  or other product- or case-specific
criteria, will not necessarily be implemented in the same manner from agency to
agency or even within a specific agency. To demonstrate some of the ways EPP princi-
ples are being applied, EPA is documenting pilot projects undertaken by executive
agencies, state and local governments, and the private sector.
  This case study documents one of those pro-
jects. It describes efforts by the U.S. Department
of Army's Aberdeen Proving Ground (APG) to
purchase paint it deems environmentally prefer-
able. As part of its overall pollution prevention
strategy, APG worked closely with a third-party,
nongovernmental environmental standards organi-
zation to examine its paint purchases and to identi-
fy the multiple environmental attributes relevant
when purchasing paint. This case study examines
APG's EPP strategy, the assistance provided by the
environmental standards organization, the result-
ing cost savings and environmental benefits,
lessons learned, and next steps. It also highlights
another successful strategy for incorporating envi-
ronmental concerns into federal purchasing deci-
sions. Perhaps most importantly, it demonstrates that EPP can be an integral part of
the government's overall pollution prevention  efforts. We hope the lessons and
insights documented in this case  study will help you and your organization as you
begin including environmental preferability into your purchasing decisions.
  Environmentally preferable products are
"products and services [that] have a lesser or
reduced effect on human health and the environ-
ment when compared to other products and ser-
vices that serve the same purpose." This
comparison may consider raw materials acquisi-
tion, production, manufacturing, packaging, dis-
tribution, reuse, operation, maintenance, or
disposal of the product or service.
                        —Executive Order 13101,
        Greening the Government Through Waste Prevention,
                      Recycling, and Federal Acquisition

       Foreword	i
       Contents	ii
       Introduction	1
       Project Background	3
             Developing APG's Paint Standards	4
                  Considering Recycled-Content Options	4
                  Finalizing the Standards	5
             Applying the Standards	6
                 Phase 1	6
                 Phase II	8
             Making the Switch	9
       Lessons Learned	11
             APG's Environmentally Preferable Paints Are Less Expensive	11
             Using a Nongovernmental Environmental Standards Organization Can Make
                Environmentally Preferable Purchasing Easier	11
             Significant Competition Exists Within the Current Market	12
             Companies Will Reformulate Products To Meet the Standards	12
             It Is Important To Verify Environmental Attribute Claims	12
             Environmental Champions Are Important	13
             Persistence Is Important	14
             Environmentally Preferable Purchasing Is a Natural Part of Any Pollution
                Prevention Strategy	14
       Next Steps	15
             Adopting a Just-in-Time Purchasing Process	15
             Promoting the Project	15
             Including the Standards in All Contracts	16
             Minimizing the Use of Noncompliant Paint from Off-Installation Sources	16
             Learning from Other Agencies	16
             Improving Pollution Prevention by Further Reducing Painting Requirements	17
             Using a Similar Process To Evaluate  Degreasers	17
             Appendix A—Green Seal	18
             Appendix B—Examples of Paints Meeting APG Standards (As of October 1, 1999)....20
             Appendix C—Other Environmentally Preferable Paint Pilot Projects	23
ii    +   Contents

        As a result of a recent series of Executive Orders, Department of Defense
        (DoD) policies, and an obligation to "do the right thing," the U.S. Army's
       .Aberdeen Proving Ground (APG), an installation in Harford County,
Maryland, has adopted a variety of pollution prevention strategies. Its numerous pro-
jects to minimize the installation's adverse environmental impacts include purchasing
alternatively fueled vehicles, reducing solvent use, minimizing packaging require-
ments, using rechargeable batteries, reducing aerosol use, adopting integrated pest
management methods, implementing a "green building" policy, installing energy effi-
cient lights and equipment, and training its work force in proper hazardous materials
handling and pollution prevention techniques. APG's efforts have been so effective
that the installation won the Secretary of the Army's 1998 Pollution Prevention Award
in the nonindustrial installation category and second place in the National Pollution
Prevention Roundtable's 1999 MVP2 (Most Valuable Pollution Prevention) Awards
Program, a national award open to public and private sector participants.

  Of the many pollution prevention initiatives adopted by APG, one of the most
interesting is its approach to minimizing the adverse environmental impacts associated
with its purchase of interior and exterior architectural and anticorrosive paints. APG
began examining pollution preven-
tion opportunities associated with its
paint purchases for two important
reasons—cost savings and air quality.
                                         The Executive Orders listed below provided incentives for
                                       APG to institute an EPP program for paint. To obtain copies of
                                       the Executive Orders, please visit .
                                       Environmental Executive Orders
  The large quantity of paints used
at APG presented an opportunity to
substantially reduce the installation's
hazardous materials handling and
disposal costs. Before modifying its
purchasing practices, APG used or
stored 2,200 different paints and
coatings, excluding color differences.
Of those, 565 were architectural and
anticorrosive paints used to maintain
the more than 2,100 buildings on the
installation. The remaining paints
and coatings included spray paints
and reflective paints or speciality
paints used on military equipment.
In addition, many of the paints
stored on the installation were out-
dated or no longer needed.
                                         Executive Order 12856, Federal Compliance with Right-To-
                                         Know Laws and Pollution Prevention Requirements, August 3,
                                         1993: Directs agencies to cut toxic emissions 50  percent to
                                         improve indoor and outdoor air quality.

                                         Executive Order 13101, Greening the Government Through
                                         Waste Prevention, Recycling, and Federal Acquisition,
                                         September 14, 1998: Strengthened and replaced an earlier
                                         order, Executive Order 12873, Federal Acquisition,
                                         Recycling, and Waste Prevention. Executive Order 12873
                                         required federal agencies to purchase recycled-content
                                         products designated by EPA and to buy other environmen-
                                         tally preferable products according to guidance  developed
                                         by EPA's EPP Program.
  Air quality is a concern at APG
because the installation is located in
an ozone nonattainment area, meaning the ground-level ozone concentration in the
region surrounding the installation exceeds the safety thresholds established in the Clean
Air Act. While stratospheric ozone, commonly referred to as the ozone layer, protects
the Earth from excessive ultraviolet radiation and helps maintain the global climate,

                   ground-level ozone is a health hazard that can irritate lungs and make breathing
                   difficult. Also known as smog, ground-level ozone is caused by a chain reaction between
                   volatile organic compounds (VOCs) and nitrogen oxides in the presence of sunlight.

                     While a large portion of ground-level ozone is produced by combustion engines
                   such as those powering automobiles, lawn mowers, and boats, many consumer prod-
                   ucts such as paint contain significant quantities of VOCs that also contribute to the
                   problem. As part of Maryland's State Implementation Plan (SIP), the state encourages
                   facilities and residents in nonattainment areas to minimize activities that contribute to
                   ground-level ozone formation, including minimizing the use of high-VOC paints and
                   solvents. APG is in a nonattainment area.
DoD Policy Statement

  According to DoD Instruction 4715.4 on pollution
prevention, "It is DoD policy to...reduce the use of
hazardous materials, the generation or release of pollu-
tants, and the adverse effects on human health and the
environment caused by DoD activities."

  A copy of the policy is available at .
  Aware of the potentially adverse environ-
mental effects associated with paint prod-
ucts, APG investigated ways to properly
deplete stocks of paints it no longer uses
and to reduce the number of paints it pur-
chases so as to minimize the environmental
effects of hazards such as VOC emissions.
As part of its investigation, APG learned
that Green Seal, a nonprofit environmental
standards organization, had developed envi-
ronmental standards for  paint. After review-
ing the standards, APG invited Green Seal
to help develop an EPP plan for paint and
to review the installation's paint purchases.
                     After developing its standards, APG reduced its architectural and anticorrosive
                   paint purchases from 565 types of paint to 73, all of which meet both its environmen-
                   tal and performance standards. APG officials, who expect to expand this list over time,
                   estimate APG's modified paint purchasing process will save the installation $60,000
                   annually while improving environmental performance. This case study documents the
                   development of APG's paint standards, Green Seal's advisory role, the success of the
                   effort, lessons learned, and future steps.

Project Background
       Under the Emergency Planning and Community Right-To-Know Act (EPCRA)
       and Executive Order 12856, APG is required to report its use, storage, and
       disposal of more than 600 Toxic Release Inventory (TRI) chemicals that have
potentially adverse environmental effects. Several of the reportable chemicals are rou-
tinely included in architectural and anticorrosive paints, which then must be handled
and disposed of as hazardous materials. Although the 2,200 paints used  or stored at
APG represented less than 5 percent of the 50,000 reportable hazardous chemicals
and chemical products APG uses and tracks, APG faced significant reporting and dis-
posal requirements due to its paint  purchases.
  In an attempt to reduce reporting require-
ments, APG began investigating ways to
reduce the number of paints stored and used
at the installation. It also researched ways to
purchase paints without hazardous compo-
nents that need to be reported. APG's empha-
sis on the purchasing process reflects the
installation's understanding  that its purchasing
practices are an integral part of its pollution
prevention program.

  Since APG is in an ozone nonattainment
area, it recognized VOCs as  a significant con-
cern. As part of its initial search for low-VOC
paint, APG learned that many states, including
California, New York, and New Jersey, have
imposed VOC limits for paints due to concerns
about its links with ground-level ozone forma-
tion. Its research into the environmental
impacts of paint also revealed that many scien-
tists were equally concerned about other poten-
tially hazardous paint components, including
lead.1 Most importantly, APG's  research
revealed that as a result of these and other envi-
ronmental concerns, many companies are
reformulating paints to minimize adverse envi-
ronmental effects.

  After learning that Green Seal,  an indepen-
dent, nonprofit environmental product certifi-
cation and consumer education  organization,
had developed environmental standards for
paint, APG sought additional information from
them to develop similar standards for the
installation. After a review of the Green Seal
Overview of Aberdeen Proving Ground

  APG is the U.S. Army's oldest active proving
ground. It was established in October 1917,
6 months after the United States entered World War
I, to test army vehicles and munitions. Every tank
and wheeled vehicle used by the U.S. armed forces in
the past 50 years was tested for performance and
durability at APG. The installation also conducts
research to help defend U.S. troops and soil against
chemical, biological, and radiological weapons.

  The installation employs 7,600 federal employees,
4,500 assigned military personnel, and 3,000 private
sector contract personnel. It comprises 72,500 acres
in Harford County, Maryland. More than 2,100
buildings with more than 14 million square feet of
floor space occupy the installation, including 1,200
housing units in which 2,900 military family mem-
bers live.

  APG is, in reality, a small town. It includes:
  •  300 miles of road.
  •  30 miles of railroad.
    An airport with 567,000 square feet of paved
    A 7-million-gallon per day water distribution
    1,000 vehicles of all types and sizes.
    Its own police and fire departments.
1 Although lead was banned from residential paints in 1978, "lead-free" paint can include up to 0.06 percent
lead (16 CFR Part 1303). Many scientists are concerned that even these low levels of lead in paint still pose a
danger to small children.
                                                                             Project Background

           standards—Environmental Standards for Household Paints (GS-11) and Environmental
           Standards for Anticorrosive Paint (GC-03)—and a series of meetings, a working rela-
           tionship was established.

           Developing APG's Paint Standards

             When developing its paint standards, APG began by reviewing Green Seal's exist-
           ing standards.2 The Green Seal standards include strict VOC limits, prohibit 25
           organic and inorganic materials,  and include product performance and packaging
           requirements. APG determined that Green Seal's VOC limits and its list of prohibited
           materials were reasonable and scientifically valid. The VOC limits were based on the
           lowest VOC levels achieved by at least 15 percent of the paint market. Green Seal
           prohibits the organic and inorganic materials because of their known or suspected
           adverse impacts on human health, including liver and kidney damage, central nervous
           system depression, pulmonary and neurological problems, anemia, cancer, and infertil-
           ity. APG also noted that eight of the prohibited materials were among the 17 priority
           chemicals targeted by EPA's 33/50 program, which attempts to discourage releases and
           transfers of the most hazardous chemicals.

             After completing its review, APG incorporated Green Seal's VOC limits and list of
           prohibited materials into its own environmental standards for paint. APG believed
           adopting the standards would significantly reduce both the toxicity of APG's paint
           purchases and its associated reporting requirements under EPCRA and Executive
           Order 12856.

             APG chose not to incorporate Green Seal's performance and packaging require-
           ments into its standards because  the installation was  already aware of and satisfied with
           the performance and packaging of the paints being purchased for use on the installa-
           tion. (The installation, for example, already prohibited the use of lead in paint cans.)
           As a result, APG did not feel it needed to modify its  own performance and packaging
           requirements. APG decided, however, to compare its newly developed VOC limits
           and list of prohibited materials with the installation's paint supplies to determine
           which paints met its environmental standards. Based on the results of the comparison,
           APG would continue buying the paints it traditionally used with the confidence that
           the paints also met its new environmental standards.

           Considering Recycled-Content Options

             In addition to examining hazardous constituents, APG considered, but decided
           against, including a recycled-content requirement in its paint standards. Federal gov-
           ernment agencies are required under Section 6002 of the Resource Conservation and
           Recovery Act to purchase recycled-content products designated by EPA. In 1997,
           EPA^ Comprehensive Procurement Guidelines (CPG) program designated recycled-
           content latex paint, which means federal agencies purchasing latex paint are required
           to purchase recycled-content latex paint if it meets the agency's price, performance,
           and availability requirements.3 Other federal, state, and local government agencies also
           promote the use  of recycled-content latex paint.
            2 Additional information on Green Seal, including a description of how Green Seal developed its standards, is included
            in Appendix A.
            ' For additional information on CPG's paint designation and recommended recycled-content levels, please visit
Project Background

  Recycled-content paint includes both consolidated and reprocessed paint. Consolid-
ated paint is recovered paint that has been sorted by a variety of characteristics such as
type (interior or exterior), color, and finish (high-gloss versus flat). After sorting, it is
consolidated and sold in a limited variety of colors as 100 percent recycled-content
paint. Reprocessed paint, like consolidated paint, is recovered paint that has been sorted
by type, color, and finish. After sorting, the recovered paint is consolidated and blended
with new paint as part of the paint manufacturing process to produce a large variety of
colors. The resulting paint has a recycled content between 1 and 99 percent.

  Unlike traditional paints, recycled-content paints vary slightly from one batch to
the next because the components of each batch are dependent on the ingredients of
the consolidated paints. As a result, it would be impossible to know if a recycled-
content paint met APG's environmental standards unless each batch was tested,
a prohibitively expensive proposition. Because APG is located in an ozone non-
attainment area and VOCs contribute to unsafe ground-level ozone concentrations,
APG  thought it was very important to ensure that paints meet the installation's strict
VOC-content levels. Furthermore, one of APG's objectives was to  minimize the
purchase of toxic materials that must be reported as hazardous; without testing each
batch of recycled-content paint, APG would be unable to verify VOC-content levels
or the absence of toxic materials.

  As  a result of the limited local availability of recycled-content paint, the limited
color  selection, and the limited feasibility of verifying VOC and prohibited materials
content, APG decided not to include  a recycled-content requirement as part of its
environmentally preferable paint standards. This means that APG can consider
paints to be environmentally preferable even if they do not contain recycled content;
it does not mean that the installation will refuse to use all recycled-content paints,
only those that fail to meet its standards. Any paint meeting APG's environmentally
preferable paint standards and its other price, performance, and availability require-
ments will be considered for use on the installation.

  The installation, however, does support paint recycling and consolidates its unused
paint  for transfer to a nonprofit organization that distributes it to low-income resi-
dents. In October 1998, as part  of an installationwide cleanup effort to eliminate
unneeded or outdated stock, 400 gallons of paint were consolidated for reuse by the
local community. It was transferred
to the county recycling center under
a no-cost contract and was transport-
ed by a licensed hazardous materials
commercial driver.

Finalizing the Standards

  After reviewing and modifying
Green Seal's standards, APG
finalized the environmental require-
ments for its paint purchases, as
described in Tables 1 and 2.
Table 1. Maximum Acceptable VOC Levels
Type of Paint
Interior Architectural
Exterior Architectural






                                                                        Project Background

Table 2.  Prohibited Materials
Inorganic Materials:
                 Hexavalent chromium
Organic Compounds:
     Butyl benzyl phthalate
     Di (2-ethylhexyl) phthalate
                 Di-n-butyl phthalate
                 Di-n-octyl phthalate
                 Diethyl phthalate
                 Dimethyl phthalate
Methyl ethyl ketone
Methyl isobutyl ketone
Methylene chloride
Toluene (methylbenzene)
Vinyl chloride
                   Applying the Standards
                     After developing its standards, APG wanted to determine which paints previously
                   purchased for use on the installation already met the standards. APG evaluated its
                   existing paint purchases in two phases, as described below.

                   Phase I
                     To ensure its paint standards were not so strict as to eliminate all of the paints used
                   on the installation, APG provided Green Seal with a list of 178 randomly selected
                   architectural and anticorrosive paints. It  asked Green Seal to review each paints'
                   Material Safety Data Sheet (MSDS), which lists ingredients and can include VOC
                   content, and to call manufacturers to obtain VOC information if it was not provided
                   on the MSDS. Based on the results of this review, APG asked Green  Seal to deter-
                   mine which paints would be acceptable under APG's standards.
                             After reviewing the information, Green Seal found
                          that 36 of the 178 paints appeared to meet the APG
                          paint standards. It also reported that 21 of the paints,
                          including 5 of the ones that appeared to meet the APG
                          standards, were no longer available because the manu-
                          facturers had gone out of business or the products were
                          no longer manufactured. Green Seal purchased pure-
                          white samples of the remaining 31 paints and delivered
                          them to APG for testing.
            V^ A|            White paint samples were used because it is the basis
          p.               for all other paint colors. Yellow paint, for example, is
                          created by adding drops of yellow pigment to a gallon  of
                          white paint. The more drops of yellow tint added to the
                          base paint, the more intense the resulting color.
According to Green Seal, the additional environmental impacts associated with the
color-tinted paint are generally too minor to be of concern.
        Project Background

  APG arranged to have the VOC levels of the 31 remaining paints verified by the
Maryland Environmental Technology Demonstration Center (METDC) at APG,
which was less expensive than the testing facilities available to Green Seal. Using
EPA Reference Test Method 24, Determination on Volatile Matter Content, Water
Content, Density Volume Solids, and Weight Solids of Surface Coating (40 CFR Part 60,
Appendix A), a standard VOC test method, the test center determined that 24 of the
31 paints had acceptable VOC levels. Unfortunately, none of the anticorrosive paints
tested had acceptable VOC levels. The table below summarizes the Phase I results.
 Table 3.  Phase I Testing Results

  Paints evaluated
  Paints eliminated due to unacceptable ingredients
  or reported VOC levels
  Paints no longer manufactured
  Paints tested for VOC levels


 Percentage of
Paints Evaluated
  Paints meeting APG's paint standards                        24*            13.5

  * Note: None of the anticorrosive paints tested had acceptable VOC levels, but APG later identified two anticorrosive paints
   meeting the standards.
  To ensure that the 24 paints meeting the APG environmental standards performed
well, APG shared the findings with some of the paint contractors on the installation.
"Although there was some concern that the painters wouldn't like the product, the amaz-
ing thing," according to Robert Solyan, Pollution
Prevention Program Manager at APG, "is that the
paints meeting our environmental standards were
already some of the most widely used paints. The
environmentally preferable products turned out to
be the higher quality products."
Maryland Environmental Technology
Demonstration Center
   Some painters, however, were wary about
using the products. Low-VOC paints have higher
percentages of particulate matter, which tends to
clog some paint guns. Other painters explained
that the problem could be avoided by changing
the mesh size in the paint gun's filters and by
increasing the nozzle size. A local paint supplier
had similar concerns about particulate size. He
was concerned he would have to invest in expen-
sive new equipment to mix the paint colors but
was happy to discover that he was already selling
many of the paints APG deemed environmentally
preferable. "Once folks learned that environmen-
tally friendly didn't mean a clogged paint gun or
expensive new equipment," explained Barry
Decker, Directorate of Public Works at APG,
"they were really excited about the products."
  The Maryland Environmental Technology
Demonstration Center (METDC) combines the
facilities and expertise of federal, state, and private
agencies to demonstrate, test, verify, and evaluate
environmental technologies for government and
                         industry customers.
                         With top-of-the-line
                         testing equipment and
                         knowledgeable experts,
                         METDC can satisfy
                         almost any environ-
                         mental research need.

  For additional information, please contact Roy
Weismiller at 410 278-5294 or , or William Newton at 410 278-7460
or .
                                                                      Project Background

                      An APG contractor who buys paint for the installation and whose wife is highly
                    sensitive to traditional paint fumes tried one of the paints meeting the APG standards
                    in his home. When his wife returned home about an hour after he finished painting,
                    she could not tell he had been painting until she saw the repainted room. As a result
                    of his success with the paint, he now purchases it for use at APG and for projects off
                    the installation where he does not have to use APG-approved paints.

                    Phase II

                      Based on the promising results of the first phase, APG decided to evaluate all of its
                    architectural and anticorrosive paints against its paint standards. APG provided Green
                    Seal with a list of approximately 2,200 paints stored or used on the installation and
                    asked Green Seal to determine which of the paints met the APG standards.

                      During its evaluation, Green Seal discovered numerous instances in which multiple
                    stock numbers had been assigned to the same paint. After eliminating the duplicate
                    stock numbers and paints not covered  by the standards (e.g., spray paint and reflective
                    paint), 565 paints remained to be evaluated. Green Seal collected and reviewed the
                    MSDS for each one—frequently discovering that the MSDS was missing or out-
                    dated—and called manufacturers to  obtain VOC information.

                      When reviewing the  565 remaining paints, Green Seal discovered that several
                    paints stored at APG were no longer manufactured. Green Seal also learned that some
                    manufacturers were not immediately able  to provide VOC information and some were
                    not even aware they made low-VOC paints. "Traditionally, manufacturers only worry
                    about performance, and low-VOC paints perform very well. It's only recently that
                    they've become concerned about environmental attributes," explained Mark Petruzzi
                    of Green Seal,  "which might be why some manufacturers were unaware of their paint's
                    VOC content."

                      After eliminating the paints that were no longer available and reviewing the MSDSs for
                    the remaining paints to remove those  that did not meet the APG standards, 107 paints
                    remained. Green Seal obtained pure-white samples of each paint and provided them to
                    APG for VOC testing. METDC conducted the tests and 71 of the 107 paints tested
                    passed. The table below summarizes the combined Phase I and Phase n results.
Table 4.  Combined Test Results
Paints evaluated
Paints eliminated due to unacceptable ingredients
  or reported VOC levels
Paints no longer manufactured
Paints unavailable for testing
Paints tested for VOC levels

 Percentage of
Paints Evaluated
Paints meeting APG's paint standards                      71*               12.6

* Note: None of the anticorrosive paints tested had acceptable VOC levels, but APG later identified two anticorrosive paints
 meeting the standards.
         Project Background

  The 71 paints include interior and exterior architectural paints in all finishes from
13 different manufacturers. None of the anticorrosive paints traditionally used at APG
met its standards, but APG continued looking. In October 1999, more than 2 years
after completing the testing, APG located two competitively priced, anticorrosive
paints meeting the standards. The addition of the two anticorrosive paints increased
the number of paints meeting the standards to 73.

Making the Switch

  Based on the Phase II results, APG prepared a list of the paints it tested that met its
environmental performance standards and required all APG personnel, residents, and
contractors to purchase and use them. It promoted the standards by distributing them
along with a list of the 73 paints meeting the standards to everyone on the installation
who uses,  orders, or supplies paint. APG also labeled every can of paint on the instal-
lation meeting its standards with an APG Pollution Prevention sticker. People at APG
already were familiar with the sticker because it is used at the Self Service Supply
Center (the installation's PX or general store) to identify products that APG has deter-
mined are environmentally preferable. (See text box below.)
   Self Service Supply Center

     APG's Self Service Supply Center encourages environmentally preferable purchasing decisions
   throughout the store. Products that APG has determined to be environmentally preferable are identi-
   fied with the APG Pollution Prevention (P2) sticker. Generally, products are eligible for the P2 sticker
   if they have any of the following environmental attributes:

     •  Include recycled content
     •  Are reusable or more durable than similar products
     •  Have reduced or zero VOCs
     •  Do not contain any materials reportable under the Superfund Amendments and Reauthorization Act
     •  Minimize chemical content
     •  Are available in nonaerosol  bottles (for products traditionally available in aerosol cans)

     Feather dusters and fly swatters, for example, display the APG P2 sticker, while dust and bug sprays
   do not. Similarly, WD-40™, an oil-based lubricant available in both pump sprays and aerosol cans, is
   labeled with a sticker when sold in the pump spray but not when sold in an aerosol can.

     The Self Service Supply Center is self-supporting, which means it relies on profits to pay its oper-
   ating expenses. As a result, it continues to sell products that do not meet APG's environmentally
   preferable criteria even when  alternatives are available because it does not want to alienate potential
   customers. APG hopes that exposing customers to the more environmentally preferable alternatives
   will raise demand for such products. Based on sales, this strategy appears to be working.

     In addition, APG recently awarded a new contract to Blind Industries to run the Self Service Supply
   Center beginning in October 1999. As part of the memorandum of understanding, APG incorporated a
   statement ensuring that Blind Industries will not stock hazardous materials without the consent of the
   APG Pollution Prevention Program Office. The Pollution Prevention Program Office will help identi-
   fy environmentally preferable alternatives.
                                                                       Project Background

                     In December 1998, the APG garrison commander signed a policy stating that all
                  architectural paints purchased by the garrison and its contractors must meet APG's
                  environmental standards. Acknowledging that there could be situations in which the
                  standards would be inappropriate, APG developed an exception form that can be used
                  to justify the purchase of noncompliant paint. The form must be approved by the
                  APG Directorate of Safety, Health, and Environment prior to the purchase. In the
                  more than 2 years since the paint standards were developed, no one has submitted an
                  exception form.

                     When the paint standards were first instituted in 1998, some personnel were con-
                  cerned that APG was limiting paint choices unfairly. The residents in the 1,200 houses
                  on the installation were particularly concerned that color selections and other quality
                  concerns would be compromised. Resistance dissipated as the residents learned that
                  the same color options existed and that APG's environmentally preferable paints per-
                  formed better in many instances and were safer to use than traditional paints.
Re-Nu-It Center

  APG's Re-Nu-It
Center is similar to the
large home improve-
ment centers located in
suburban shopping cen-
ters. The center makes
products such as touch-
up paint, light bulbs,
and lawn mowers avail-
able free to the  installa-
tion's residents.
                                 As part of its pollution prevention efforts, four times a year APG
                               encourages individuals to take any unused paint to the installation's
                               Re-Nu-It Center rather than storing it themselves. Traditionally, many
                               people keep unused paints for future touch-up jobs. In fact, although
                               APG is working to change the contract language, many of the installa-
                               tion's painting contracts require the painters to leave 5 to 10 percent of
                               the paint for future touch-up work. This practice poses significant dis-
                               posal costs because the paint typically dries out before it is needed and
                               then must be disposed of properly. The Re-Nu-It Center eliminates this
                               problem by  collecting and consolidating excess paint for recycling.
       Project Background

Lessons Learned
A       PC's environmentally preferable paint project has
       successfully worked with a nongovernmental environ-
       mental standards organization, developed its own envi-
ronmental purchasing standards, purchased paints meeting the
standards, saved money, and improved its environmental perfor-
mance. This section highlights some of the lessons learned.

APG's Environmentally Preferable
Paints Are Less Expensive

  To the delight of the project's participants, paints meeting
the APG paint standards are an average of $1.76 less expen-
sive per gallon based on a review of prices for compliant and
noncompliant paints from the  three most frequent suppliers. "We purchase an aver-
age of 300 gallons of paint a month," explained Robert Solyan, "which means we
can enjoy an immediate monthly savings of $528."

  Additional savings accrue from decreased disposal costs. The paints meeting APG's
environmentally preferable standards do not generate hazardous wastes and do not
require hazardous materials to clean paint brushes and paint guns. According to
Solyan, "This saves $25,000 annually in avoided disposal costs. If all of DoD adopted
our standards, it could avoid more than $1 million a year in disposal costs."

  The new importance placed on the Re-Nu-It Center, where individuals can drop
off excess paint or pick up free  paint for touch-up work, reduces paint purchases by
$10,000 a year. Based on APG's experience, individuals typically do not purchase paint
when they can get it free from the Re-Nu-It Center. The center also further reduces
disposal costs because paint that would have been disposed of is reused instead.

  Even more savings result from lower administrative costs to track the paints. "We
used to have to track the paints for inventory purposes and because they were  consid-
ered a hazardous material," explained Solyan. "We were tracking hundreds and hun-
dreds of different architectural  paints. Now we only have 73 to track, and they do not
have to be reported as hazardous materials."

  Overall, Solyan estimates first-year savings of $60,000. According to his estimates,
the one-time costs of developing the environmentally preferable paint standards were
recovered in 1.5 years.

Using a Nongovernmental Environmental
Standards Organization Can  Make Environmentally
Preferable Purchasing Easier

  When APG began investigating ways to improve the environmental performance of
its paints, it was concerned that it did not have sufficient personnel with the appropri-
ate expertise and available time to adequately review the literature on the subject.
Locating a nongovernmental environmental standards organization with the appropri-
ate expertise made APG's challenge easier.
                                                                  Lessons Learned

                      As detailed in EPA's April 1998 policy letter on the use of nongovernmental entities
                    such as environmental certification and standards organizations, APG was conscious of
                    its responsibility to make the final purchasing decisions.4 Green Seal's role was to
                    assist APG in developing its own environmentally preferable paint standards and to
                    review APG's paint inventory for paints meeting the APG standards. Green Seal did
                    not make any purchasing recommendations; it simply provided APG with the techni-
                    cal information necessary to make its own decisions.

                      While APG's paint standards are similar to Green Seal's, it is important to note that
                    paints do not need to display the Green Seal Certification Mark (Green Seal of
                    Approval) to meet APG's standards. Paints with the Green Seal certification label will
                    meet APG's standards, but paint manufacturers do not need to seek Green Seal  certifi-
                    cation in order to meet the APG standards. Manufacturers simply have to provide
                    independent certification that their products meet APG standards. At its discretion,
                    APG can verify the information independently by reviewing the product's MSDS and
                    testing VOC levels.

                    Significant Competition Exists Within the
                    Current Market

                      Initial skeptics of APG's paint standards argued that there would be insufficient
                    competition among vendors of the paints meeting its environmentally preferable paint
                    standards. After completing its review of the paints used on the installation, however,
                    APG identified 71 paints meeting the standards, which are produced by 13 different
                    manufacturers and are available from numerous distributors. The 71 paints include
                    interior and exterior architectural paints in all finishes. It later identified two anticor-
                    rosive paints meeting the standards, which brought the total number of paints to 73.

                    Companies Will Reformulate Products To
                    Meet the Standards

                      APG  and Green Seal have both heard anecdotal evidence that paint manufacturers
                    are reformulating their products to meet the increasing demand for environmentally
                    preferable paints.  For example, Lasting Paint Company, Inc., an Aberdeen area  paint
                    manufacturer and distributor, reports that it is reformulating products  to meet the
                    increasing demand. "We're not just changing because of the Aberdeen standards,"
                    explained Jason Puig, a company sales representative, "but because we see a growing
                    market for environmentally friendly paints, especially in the health care field—hospi-
                    tals, nursing homes, and doctors' offices."

                    It Is Important To Verify Environmental
                    Attribute Claims

                      Based on the information reported on MSDSs and provided by the manufacturers,
                    107 of the paints to be tested appeared to be within APG's VOC limits. After testing,
                    however, only 66 percent (71) were within acceptable limits. Reported VOC levels
                    were frequently different from the VOC levels as measured by APG. Of the 107 test-
                    ed paints, 40 percent were at least 10 percent or more above their reported VOC lev-
                    4 For a copy of EPAjs policy recommendations, please visit the EPP Web site at .

12   ^    Lessons Learned

els and 41 percent were at least 10
percent below stated VOC levels.
Only 19 percent were within 10
percent of their reported levels.
Alarmingly, 18 percent were more
than 50 percent above their report-
ed VOC levels and 8 percent were
more than 50 percent below
reported levels. The levels for two
of the tested paints were more than
300 percent higher than reported
by the manufacturers.

  Two manufacturers wrote to sug-
gest that APG's testing methodolo-
gies might be inaccurate; however,
upon learning that the METDC
was using a gas chromatograph to
determine VOC levels, the manu-
facturers did not raise any addition-
al concerns. This strongly suggests
the need to verify environmental
information for products. Like
APG, several nongovernmental
environmental  certification and
standards organizations, including
Green Seal, verify environmental
information before certifying a
product. Some, like Green Seal,
also include regular site visits to
manufacturers to ensure they con-
tinue to provide products meeting
the certification standards.
         Actual Versus Reported VOC Levels
            Within 10 Percent of Reported Levels
Below Reported
                                              Above Reported
                                         Within Reported
            Within 50 Percent of Reported Levels
            Above Reported
 Below Reported
Within Reported
    Only 19 percent of the 107 paints' actual VOC levels were within
  10 percent of the levels reported by the manufacturers (see top chart).
  Eighteen percent of the actual VOC levels were more than 50 percent
  above the levels reported by the manufacturers  (see bottom chart). The
  VOC levels for two of the tested paints were more than 300 percent
  higher than reported by the manufacturers.
  In addition, APG and EPA are investigating the legal consequences for manufactur-
ers providing inaccurate MSDS information.

Environmental Champions Are  Important

  According to Alike Shor, Green Seal's Vice President for Marketing who has
worked on numerous environmental purchasing projects, the APG project was suc-
cessful because of the involvement of several strong environmental champions.
"People don't like to change," Shor suggested, "which means you really have to show
them that environmental purchasing can be easy and that the products work."

  "The APG team really went out of its way to demonstrate the economic and envi-
ronmental advantages of environmentally preferable products. They were willing to
get their hands dirty, to consolidate the paints for reuse, to collect the outdated paints
for proper disposal, to work with the painters to demonstrate the products, [and] to
test VOC levels. They are an amazing team," explained Shor.
                                                                        Lessons Learned

                      Both the APG team and Shor agree on the following four general roles for an envi-
                    ronmental champion:

                          •  Identify areas for continual improvement in environmental performance
                          •  Promote the initiative heavily
                          •  Make it fun
                          •  Get others involved

                      "I was amazed at how excited some people got once they realized the inherent
                    advantages of the approach," explained Elizabeth Longenecker, an APG pollution
                    prevention specialist. "It was really rewarding to see people take the ideas and make
                    them work."

                    Persistence Is Important

                      When APG compared the paints in its inventory against its environmental paint
                    standards, it identified 71 interior and exterior architectural paints meeting the stan-
                    dards but no anticorrosive paints. Rather than exempting anticorrosive paints from the
                    standards, APG looked beyond the paints it traditionally purchased to locate anticor-
                    rosive paints that would comply. Throughout its search, APG depleted its supply of
                    noncompliant anticorrosive paints and ordered limited additional supplies as needed,
                    but it never stopped looking. APG's persistence paid off and, more than 2 years after
                    the initial testing, it began purchasing two anticorrosive paints meeting its environ-
                    mentally preferable purchasing standards.

                      APG was confident its environmental standards were sound. It just needed to locate
                    anticorrosive paints meeting the standards. The results of APG's persistence prove
                    that you do not have to lower environmental preferability standards to locate compli-
                    ant products. Sometimes, you just have to look a little harder.

                    Environmentally Preferable Purchasing Is a Natural
                    Part of Any Pollution Prevention Strategy

                      Like many other EPP pilot projects, APG's paint project was initiated to meet a
                    number  of pollution prevention objectives, only one of which was complying with
                    Executive Order 13101. APG adopted the EPP approach because it was a useful tool
                    for meeting its pollution prevention goals. Examining the environmental attributes
                    associated with its paint purchases allowed APG to select products that save money,
                    perform better, and prevent pollution. As APG's pilot and others have demonstrated,
                    EPP can be an important component of any pollution prevention initiative.
14   ^    Lessons Learned

    ext Steps
           Wile the APG paint pilot project has enjoyed many successes, the installa-
           on is constantly seeking ways to improve its environmentally preferable
         x aint program as well as its overall pollution prevention efforts. This sec-
tion describes some of APG's future goals.

Adopting a Just-in-Time Purchasing Process

  To further decrease the volume of paints stored on the installation,
APG is adopting a "just-in-time" purchasing approach. Traditionally,
APG purchased large volumes of paint several times a year to benefit
from the high-volume price discounts. Although the installation
received a volume  discount, the disposal costs of the unused and expired
paint more than offset the initial savings.

  Just-in-time purchasing will allow APG to order only the quantities
needed and to avoid disposal costs associated with outdated stock. To
implement the new purchasing system, APG is tracking its paint pur-
chases in its Hazardous Inventory Tracking System (HITS) even though
paints meeting the APG standards are not hazardous. HITS makes
tracking paint and  other product purchases easier. It is a user-friendly,
Windows-based program that maintains chemical constituent data,
chemical hazard information, MSDSs, and available quantities. The soft-
ware notifies users when a product is within 90, 60, and 30 days of its
expiration date so it can be used before it expires and becomes unusable.

  APG also is considering centralizing its paint purchases so they can
be controlled from a single location. Currently, paint is purchased by a
variety of offices, making coordination a challenge and potentially leading to unneces-
sary purchases.

Promoting the Project

  APG is promoting its success with its paint standards throughout DoD and the
rest of the federal  government. It is encouraging others to examine its research,
methodologies,  and successes and to implement similar projects. As a result of its
efforts, others outside of the federal government also are learning about the installa-
tion's success. One example cited by both APG and Green Seal is the April 1999
issue of Pollution Engineering, with a circulation of 59,000, which includes an article
on the APG paint standards.

  The installation also is promoting the project in the communities surrounding
APG. Some local manufacturers and distributors are reluctant to promote the APG
standards fearing they will lead to decreased sales. However, Jason Puig, a sales repre-
sentative for Lasting Paint Company, Inc., explained that his sales have not changed as
a result of the APG standards. "Sales of some products rose, while [sales of] other
products fell," explained Puig. "Overall, our sales remained about the same." The
company, however, is developing additional paints to meet the standards in an attempt
to further increase its share of the environmentally preferable paint market.
                                                                             Next Steps

                    Including the Standards in All Contracts

                      Most of the current painting contracts at APG do not include specific language
                    requiring the use of paints meeting the environmentally preferable paint standards
                    because the contracts were awarded before the standards were developed. As a result,
                    some contractors could be using noncompliant paints. APG is working with its con-
                    tracting office to ensure that all future contracts include specific language addressing
                    its environmental paint standards. It also is investigating the challenges associated with
                    modifying the existing contracts to include adherence to the APG paint standards as a
                    requirement. Including specific language in the contracts will help ensure everyone is
                    complying with the standards and make compliance enforceable.

                    Minimizing the Use of Noncompliant Paint from
                    Off-Installation Sources

                      APG is aware that installation residents might not find all of the household
                    products a homeowner needs at its Self Service Supply or Re-Nu-It Centers. As a
                    result, installation residents might also shop at large, convenient home improve-
                    ment retail centers and unintentionally purchase paint that  does not comply with
                    APG's standards.

                      APG also is concerned about the potential affects of the government IMPAC
                    cards, government credit cards that will soon have purchase  limits up to $25,000 for
                    selected government purchasers and $2,500 for most government purchasers. The
                    IMPAC cards make it easier for designated government purchasers to buy products
                    without going through the  central government purchasing system. They also
                    increase the number of government purchasers who must understand and abide by
                    the APG paint standards.

                      To minimize the purchase of noncompliant paint, APG is increasing its educa-
                    tional efforts installationwide to explain the importance of its environmental stan-
                    dards. APG also is incorporating its paint standards into the training provided to all
                    IMPAC card users.

                    Learning from  Other Agencies

                      While exploring additional pollution prevention opportunities, APG learned that
                    the National Aeronautics and Space Administration (NASA) was developing environ-
                    mental standards for powder paint coatings and for cleaning products. APG and
                    NASA are sharing information about their environmentally preferable product stan-
                    dards and each might soon adopt the other's standards. NASA also is examining APG's
                    HITS software and might modify it to limit the overall quantity of hazardous materi-
                    als stored onsite. APG provided its HITS software to NASA free of charge, and, in
                    exchange, NASA will provide APG with copies of any improvements it develops.
16   4   Next Steps

Improving Pollution Prevention by Further
Reducing Painting Requirements

  In the true spirit of EPP, APG also is examining ways to minimize its overall paint
purchases. The installation encourages the use of vinyl coverings or paneling on interi-
or walls in high-traffic areas and the use of brick or vinyl siding for exterior walls to
eliminate the need for repainting. The alternative wall coverings might be easier to
maintain and more durable than painted walls.  "Just as importantly, the wall coverings
can be made with recycled content, which further improves their environmental prefer-
ability," suggested Sheila Jones, a pollution prevention specialist with Dynamac, an
APG contractor. APG is investigating the use of plastic lumber for similar reasons.

Using a Similar Process To Evaluate

  Perhaps the most important indicator of the overall success of
APG's environmentally preferable paint project is that the instal-
lation is using the same process and is working with Green Seal
to develop environmental standards for its degreasing
products and operations.
                                                                        Next Steps   ^  17

         Appendix  A—Green Seal
             rounded in 1989, Green Seal is an independent, nonprofit organization whose mis-
             sion is to encourage the purchase of environmentally responsible products and ser-
             vices. It also assists businesses and governments with green purchasing issues
         through its Environmental Partners Program. It shares environmental product informa-
         tion on its Web site  and in its monthly Choose Green Report, which
         has more than 490,000 readers.

         Product Standards and Certification
            Green Seal's primary purpose is to establish voluntary environmental standards and
         to award the Green Seal Certification Mark (Green Seal of Approval) to products that
         meet its standards. More than 300 products have been certified.
Green Seal Standards
  Green Seal standards are available on its Web site . They are available
currently for the following product categories:
   Alternatively Fueled Vehicles
   Anticorrosive Paints
   Clothes Dryers
   Clothes Washers
   Coated Printing Paper
   Compact Fluorescent Lamps
   Ductless Heat Pumps
   Fleet Vehicle Maintenance
   General Purpose Cleaners
   Lodging Properties
   Paper Products Used to Prepare Food
   Paper Towels and Paper Napkins
                                                      Photo Voltaic Modules
                                                      Plastics Labeling Systems
                                                      Pollution-Reducing Vehicles
                                                      Powdered Laundry Bleach
                                                      Printing and Writing Paper
                                                      Re-Refined Engine Oil
                                                      Residential Air-Conditioning Systems
                                                      Residential Heat Pumps
                                                      Reusable Utility Bags
                                                      Tissue Paper
                                                      Water Efficient Fixtures
                                                      Water Heaters
                                                      Watering Hoses
                                                      Window Films
Appendix A — Green Seal

  Green Seal establishes environmental product standards in an open, collaborative
process. It actively seeks input from all stakeholders including facility managers, man-
ufacturers, government agencies, academic researchers, trade associations, environ-
mental and consumer groups, and the general public. Once a product, such as paint, is
selected for study, Green Seal takes a lifecycle approach in its assessment. It examines
material extraction, manufacturing processes, use, and the ultimate recycling or dis-
posal of the product to define the environmental effects and to determine if significant
measures can be taken to reduce them.

  When developing environmental standards, Green Seal recognizes that it is extreme-
ly important that a product work at least as well as others  in its class.  If a product con-
tains toxic components integral to a product's performance, for which nontoxic
substitutes are unavailable, the components are not prohibited under Green Seal's stan-
dards. Product performance is the most important criteria.

  Upon completing its research, Green Seal releases draft standards, which are circu-
lated widely for public review and comment. After reviewing the comments, publicly
responding to all comments, and making any necessary changes, Green Seal publishes
final standards. A formal appeals process is available. At the time of publication, approx-
imately 15 to 20 percent of the market can meet the standards. If a larger percentage of
the market is able to meet them at some point in the  future, Green Seal reserves the
right to modify the standards so they remain a means to identify industry-leading, envi-
ronmentally responsible products.

  APG's use of Green Seal's technical expertise  is consistent with the April 1998 poli-
cy on the use of nongovernmental  environmental certification and standards organiza-
tions issued by EPA and the Office of the Federal Environmental Executive. For a
copy of the policy, please visit the EPP Web site at .

Product Certification  Process

  Green Seal offers certification to all products meeting its standards. To become
certified, a manufacturer must submit the product for evaluation and agree to a site visit
and annual monitoring to ensure continued compliance. If the product meets its stan-
dards, Green Seal will grant the manufacturer the right to  use the Green Seal of
Approval, subject to ongoing testing and inspection. Should a product fail to meet the
standards on evaluation, Green Seal informs the manufacturer of the reasons and will
work with it to make the changes needed to meet the  standards.
                                                                  Appendix A—Green Seal   +   19

Appendix  B—Examples  of Paints
Meeting APG  Standards*
  Interior Flat
  Benjamin Moore
  Benjamin Moore
  Coronado Paint
  Dutch Boy
  Kurfee's Coatings - Servistar
  PPG Industries
  Sherwin Williams
  United Coatings
                                                    APG Standard VOC Limit = 50 g/L
                                                Product Name
                                                 Pristine Flat
                                           Moore's Ceiling White Flat
                                         Super Kote 1000 Vinyl Latex Flat
                                               Texture Paint Flat
                                   Builder's Masterpiece Interior Vinyl Latex Flat
                                         Fashion Fresh Interior Latex Flat
                                  Supreme Interior Odor Free Latex Primer-Sealer
                                          8 Year Interior Wall  Deep Base
                                               Style Perfect Flat
                                     Interior Latex Texture Paint Sand Texture
VOC Level (g/L)
  Interior Semigloss
  Benjamin Moore
  Benjamin Moore
  Benjamin Moore
  Benjamin Moore
  Benjamin Moore
  Benjamin Moore
  Benjamin Moore
  Benjamin Moore
  Bruning Paint
  Bruning Paint
  Dutch Boy
  Glidden Paint
                                                   APG Standard VOC Limit = 150 g/L
                                                Product Name
                                         Pristine Interior Latex Semigloss
                                          Pristine Interior Latex Eggshell
                                          K&B Acrylic Latex Satin Finish
                                                 Pristine Egg
                                               Pristine Semigloss
                                                 Regal Satin
                                           Moore Kitchen & Bath Satin
                                   Moorcraft Super Hide Latex Semigloss Enamel
                                  Paeon Supreme Latex Semi-Lustre Midtone Base
                                     Paeon Supreme Latex Semi-Lustre Enamel
                                       Plastic Kote Interior Acrylic Semigloss
                                        Pro Kote Interior Acrylic Semigloss
                                 Ultra Deluxe Interior Acrylic Latex Semigloss Enamel
                                    Fresh Look Interior Latex Semigloss Enamel
                                        3400 Spread Satin  Latex Wall Paint
VOC Level (g/L)
k This appendix was accurate as of November IS, 1999. The paints identified in these tables were chosen for analysis against the Aberdeen
 Proving Ground standard primarily because they were readily available in the Aberdeen Proving Ground stock. Therefore, this list serves only
 as an example of products that meet the Aberdeen Proving Ground architectural paint standard. Aberdeen Proving Ground does not endorse
 any particular brand, manufacturer, or distributor of paint.
     Appendix B — Examples of Paints Meeting APG Standards

Interior Semigloss (continued) APG Standard VOC Limit = 150 g/L
Lasting Paints
Lasting Paints
Lasting Paints
PPG Industries
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Product Name
Acrylic Latex Tint Base Eggshell
Acrylic Latex Pastal Base Eggshell Base
Latex Semigloss Pastel Base
Lucite Interior Latex Semigloss Natural
Easy Living Semigloss Wall & Trim
Super Paint Interior Semigloss
ProMar Semigloss
Classic 99 Interior Semigloss
ProMar 700 Semigloss
Style Perfect Semigloss
ProMar 200 Semigloss
ProMar 400 Semigloss
Style Perfect
ProMar 200 Interior Latex Semigloss
ProMar 400 Interior Latex Semigloss
Style Perfect Interior Latex Semigloss
Style Perfect Interior Satin
ProMar 200 Interior Latex Egg-Shell
Classic 99 Interior Satin Latex
VOC Level (g/L)
Interior Gloss
                     APG Standard VOC Limit = 150 g/L
                  Product Name
                    Deluxe Gloss
VOC Level (g/L)
Exterior Flat
Benjamin Moore
Benjamin Moore
Benjamin Moore
Benjamin Moore
Benjamin Moore
United Paint Mfg. Co.
                     APG Standard VOC Limit = 100 g/L
                  Product Name              VOC Level (g/L)
                Moore's Latex Exterior                 44
   Moorcraft Super Special Premium Latex Exterior Flat     54
                   Moorcraft Flat                    80
              Fresh Start Exterior Primer               92
Moorcraft Super Special Premium Latex Exterior House & Trim  67
              Exterior Latex House Paint               18
              Appendix B — Examples of Paints Meeting APG Standards

Exterior Semigloss
Benjamin Moore
Benjamin Moore
Benjamin Moore
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
United Coatings
APG Standard VOC Limit
Product Name VOC
Moorcraft Satin
Moore Exterior Floor and Patio
Moorglo House & Trim Exterior Non-Flat
Super Kote 3000 Latex Semigloss 74
Acrylic House Paint 12 Semigloss
Weathershield Semigloss
Weathershield Exterior 100% Acrylic Latex Satin
Ultra Deluxe Exterior 100% Acrylic Latex Semigloss
Weathershield Exterior Acrylic Semigloss
Super Paint Exterior Satin Latex
Super Paint Latex Satin
A-100 Exterior Satin
Exterior Satin Latex
Weather Perfect Exterior Satin Latex
Wal-Mart 1 5 Year Semigloss Accent Base
= 200g/L
Level (g/L)

Exterior Gloss
Dutch Boy
Sherwin Williams
Sherwin Williams
Sherwin Williams
United Coatings
APG Standard VOC Limit
Product Name VOC
Performer Exterior Latex Gloss
Super Paint Exterior Gloss Latex
A-100 Gloss
A-100 Exterior Gloss Latex
Wal-Mart Accent Base Exterior Gloss House & Trim
= 200 g/L
Level (g/L)

Sherwin Williams
Sherwin Williams
APG Standard VOC Limit
Product Name VOC
Krylon - Rough Tough Latex - 1
Krylon - Rough Tough Latex - 2
= 250 g/L
Level (g/L)
Appendix B — Examples of Paints Meeting APG Standards

Appendix  C—Other Environmentally

Preferable Paint Pilot  Projects

          Wile this case study highlights a very effective means of increasing the envi-
          3nmental preferability of paint purchases, it is not the only EPP paint
          litiative. This appendix provides a brief overview and contact information
for three additional ongoing projects seeking to identity environmentally preferable
paint alternatives.

GSA's Paint Attribute Matrix

  The U.S. General Services Administration (GSA), with technical assistance from
EPA, is developing an environmental attribute matrix for interior and exterior latex
paints. Similar to the environmental attribute matrix GSA and EPA developed for
cleaning products*, the paint matrix will provide users with additional environmental
and performance information about specific products available through GSA. The
matrix will help customers determine which products to purchase but will not include
any purchasing recommendations.

  The matrix will include information on the following environmental and perfor-
mance factors:

    Environmental Factors

      • Air Pollution Potential—based on the calculated VOC-content levels using a
       formula provided to manufacturers.

      • Product Packaging—whether a manufacturer's product is distributed in mini-
       mal or reduced packaging,  packaging containing recycled-content materials,
       or packaging that is recyclable.

      • Product Take-Back—whether a manufacturer participates in a product take-
       back program in which it or a designated third-party collects unused paint for
       reuse or recycling.

    Performance Factors

      • Dry Film Thickness—the manufacturer's recommended paint application

      • Theoretical Spread Rate—the size of the area 1 gallon of paint will cover when
       applied at the recommended  dry film thickness.
* For additional information on the GSA and EPA cleaning products attribute matrix, please see the following
 EPA publications: Environmentally Preferable Purchasing in Action—Cleaning Products Pilot Project Fact Sheet
 (EPA742-F-97-001), a 4-page fact sheet describing the project, and Cleaning Products Pilot Project—An
 Environmentally Preferable Purchasing Case Study (EPA742-R-97-002), a 20-page project case study. Both publi-
 cations are available from the EPP Web site  or by calling the Pollution
 Prevention Information Clearinghouse at 202 260-1023.
                         Appendix C—Other Environmentally Preferable Paint Pilot Projects    +   23

                           •  Drying Time—the maximum amount of time it will take the paint to dry
                             when applied at the recommended dry film thickness.

                           •  Shelf Life—the length of time a can of paint can be left undisturbed on a shelf
                             at normal room temperature.

                           •  Application—the methods that can be used successfully to apply the paint
                             (brush, roller,  or sprayer) and the thinning requirements necessary for each

                           •  Warranty Information—details of the manufacturer's product warranty.

                       To obtain the matrix information, GSA distributed a voluntary survey to paint man-
                     ufacturers selling products through GSA. Paint manufacturers are not required to pro-
                     vide any of the environmental or product performance information requested by GSA,
                     but GSA will publish the information provided in its product catalogs. As of October
                     1999, GSA was still collecting product information and the publication date for the
                     matrix had not been determined.

                       For additional information, please contact Irving J. Ostrich of GSA's Hardware and
                     Appliance Center at 816 823-3087 or ; or Conrad Flessner of
                     EPA^ Exposure Assessment Branch within the Office of Pollution Prevention and
                     Toxics at 202 260-3918 or .

                     U.S.  Air Force's New Paint Products

                       Since 1995, the U.S. Air Force Research Lab at Wright Patterson Air Force Base in
                     Ohio has been developing a more  durable airplane paint that does not contain chro-
                     mates. The Air Force's maintenance costs for paint-related  activities are more than
                     $700 million per year. Aircraft painting, stripping, and repainting represents approxi-
                     mately 75 percent of the hazardous waste materials generated by the U.S. Air Force.
                     As a result, the Air Force would consider a more durable, less toxic paint to be envi-
                     ronmentally, and economically, preferable.

                       A fleet of C-17 aircraft proved a good test for developing a new paint product. The
                     anticorrosive paint traditionally used on the C-17's contains chromium,  which is
                     potentially hazardous to humans, and begins peeling and fading after only 18 months,
                     requiring significant touch-up painting that can be time consuming and costly. In
                     addition, the touch-up  frequently results in mismatched colors, making the coating
                     appear mottled, which  could make detecting damage to the aircraft more difficult. As
                     a result, the entire aircraft must be stripped and repainted.

                       When deciding to investigate a  more durable paint, the Air Force also decided to
                     seek a paint that did not include chromium. The Air Force  Research Lab asked its
                     contractor, McDonald-Douglas, to approach the paint vendors with their problem.
                     With the Air Force willing to pay  a little extra for a more durable, less hazardous
                     paint, McDonald-Douglas researched and identified a paint vendor that could develop
                     such  a product.

                       The Air Force began testing the new paint on the C-17 aircraft in February 1998.
                     Thus far, the chromate-free paint  appears to accomplish the dual objectives of increas-
                     ing durability and lowering toxicity. After more than a year in the field, the test
                     C-17's topcoat had maintained its  properties, showing few signs of peeling or fading.
                     The coating proved easier to touch up, and the reduced painting-related maintenance
24   +   Appendix C—Other Environmentally Preferable Paint Pilot Projects

helped reduce the frequency and the costs of hazardous waste cleanup. Although the
new paint has a different chemistry than standard paint, it is compatible with existing
Air Force paint equipment. The new paint potentially could allow the Air Force to
reduce touch-up work, increase the time between repainting, and save more than $1.6
million per year per aircraft.

  The Air Force Materials Lab is exploring other environmentally preferable paint
opportunities. Using a preexisting contract with Battelle Columbus, an Air Force
team composed of the Materials Lab, Air Combat Command, the Logistics Centers,
and the Systems Program Offices responsible for procuring airplanes, the Air Force
Material Lab developed new environmentally preferable paint specifications. The
contractor forwarded the specifications to approximately 15 paint vendors, seeking
paints that might satisfy the new requirements. Vendors sent samples of their prod-
ucts to Battelle for initial testing. Battelle submitted the test results and the Air
Force has a list of products it will test further.

  For more information, contact Steve Szaruga of the U.S. Air Force Research
Lab, Wright Patterson Air Force Base, Ohio, at 937 255-9064 or .

U.S. Army's New Painting Technology

  The U.S.  Army's Tank Automotive Research and Development Center (TARDEC)
in Warren, Michigan, has been developing a new painting process that saves time,
money, and paint and reduces VOC emissions. Reducing VOC emissions became an
important TARDEC goal for two reasons. First, California's limits for VOC content
in paint were lower than what was currently available to the Army, and other states
appear to be adopting similar limits. Second, Department of Natural Resources offices
around the country began requiring Army facilities to purchase and operate  scrubbers
to limit VOC emissions. As a result of these challenges, the Army began seeking paint
products that would meet state VOC limits and eliminate the need to purchase costly
scrubbing equipment.

  While attending a trade show, TARDEC learned about UNICARB, the Union
Carbide Super Critical Carbon Dioxide Application Process, which mixes paint with
carbon dioxide (CO2) instead of solvent to create a lower-VOC coating. TARDEC
approached the manufacturer about testing the system for possible use by the Army.
After securing initial funding through an EPA grant, administered by the Army
Acquisition Pollution Prevention Support Office, TARDEC entered into an agreement
with the contractor to supply the UNICARB system. The Army, however, also request-
ed a unique low-VOC coating to use with the equipment to further reduce VOC emis-
sions. Union Carbide did not have a paint product meeting the request but entered
into a licensing agreement with paint manufacturers to develop the new coating.

  Using the new paint and application process eliminates the need to acquire $4.5
million dollar scrubbers. The results of two demonstration projects suggest additional
savings. One of the projects reduced paint use by 67 percent, VOC emissions by 78
percent, and painting time by 33 percent and included savings  of $114 per gallon of
paint used. A second project, which involved painting U.S. Army tanks and personnel
carriers, achieved a 2 5 percent reduction in paint quantities and comparable VOC and
cost reductions. In addition, the second project demonstrated significant time savings,
thanks to a two-hose design that enabled two people to paint at the same time.
Although the new paint is 20 percent more expensive than traditional high-VOC
                          Appendix C—Other Environmentally Preferable Paint Pilot Projects    +   25

                     paints, and the UNICARB equipment requires an initial investment of $70,000, the
                     avoided scrubber costs, reduced paint consumption, and other savings more than off-
                     set the costs.

                       TARDEC has been working with paint and equipment manufacturers to further
                     refine the system to better meet its needs. While previous comparable systems were
                     large and cumbersome, the UNICARB system is now portable, which makes it easy to
                     maneuver within a work area and to transport to other destinations.

                       TARDEC is planning some additional testing before making any final decisions
                     regarding full deployment of the system. A three- or six-month in-place comparison
                     between the existing system and the UNICARB system will allow TARDEC to collect
                     and compare data on maintenance, savings, and other characteristics. As of October
                     1999, it was still seeking financing for this part of the project. Following the initial
                     grant, financing of the new painting process was provided by in-kind contributions
                     from private companies,  minimizing the dollar amount expended from government
                     funds, and by the United Defense Limited Partnership, a Department of Defense con-

                       For additional information, contact Anna Wojciechowski of TARDEC at the U.S.
                     Army Tank, Automotive, and Armaments Command, Warren, Michigan, at 810 574-
                     5954 or .
26   +   Appendix C—Other Environmentally Preferable Paint Pilot Projects

We want to hear from you! Please tell us about your environmentally
preferable purchasing activities and efforts. We are collecting and shar-
ing information, tools, and hints about what works and what doesn't as
environmentally preferable purchasing evolves and expands. Please con-
tact the EPP program by e-mail, regular mail, or fax:
           Environmentally Preferable Purchasing Program

               U.S. Environmental Protection Agency

                     401 M Street, SW (7409)

                      Washington, DC 20460

                     e-mail: epp.pilot@epa.gov

                        Fax: 202 260-0178

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   Environmental Protection Agency
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