Friday
August 20, 1999
Part VII
Environmental
Protection Agency
Final Guidance on Environmentally
Preferable Purchasing for Executive
Agencies; Notice
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Federal Register / Vol. 64, No. 161 / Friday, August 20, 1999 / Notices
ENVIRONMENTAL PROTECTION
AGENCY
[OPPTS-00149A; FRL-6095-4]
FUN2070-AC78
Final Guidance on Environmentally
Preferable Purchasing for Executive
Agencies
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice.
SUMMARY: This document announces the
availability of a general guidance
designed to assist Executive agencies in
identification and acquisition of
environmentally preferable products
and services. The final guidance is in
response to section 503 of Executive
Order 13101. entitled "Greening the
Government Through Waste Prevention,
Recycling and Federal Acquisition" (63
FR 49641, September 16, 1998), which
requires EPA to issue guidance to
address environmentally preferable
purchasing by the Federal government.
The guidance is designed to assist
Executive agencies with the
implementation of the environmentally
preferable purchasing provisions of
Executive Order 13101 and Section
23.704 of the Federal Acquisition
Regulations. The implementation of this
guidance will result in increased
purchases by the Federal government of
products and services which minimize
harmful effects on human health and
the environment.
FOR FURTHER INFORMATION CONTACT: For
information contact: Eun-Sook Goidel,
Office of Pollution Prevention and
Toxics, Pollution Prevention Division,
7409, Environmental Protection Agency,
401 M St., SW., Washington, DC 20460,
telephone: (202) 260-3296, fax: (202)
260-0178, e-mail:
goidel.eunsook@epa.gov.
SUPPLEMENTARY INFORMATION:
I. Does this Apply to Me?
* You may be potentially affected by
this notice if you are an Executive
agency employee responsible for the
acquisition and use of products and
services. Those who produce and sell
products and services for use by the
Federal government may also find the
information in this notice to be of
interest. If you have any questions
regarding the applicability of this notice
to a particular organization, consult the
person listed in the "FOR FURTHER
INFORMATION CONTACT" section.
n. How Can I Get Additional
Information or Copies of this Document
or Other Documents?
For the convenience of the reader, the
final guidance is published below in its
entirety in Unit VII.
1. Electronically. You may also obtain
electronic copies of this document and
various support documents from the
EPA Internet Home Page at http://
www.epa.gov/. On the Home Page select
"Laws and Regulations" and then look
up the entry for this document under
the "Federal Register—Environmental
Documents." You can also go directly to
the "Federal Register" listings at http:/
/www.epa.gov/fedrgstr/. Alternatively,
you can go to the Environmentally
Preferable Purchasing program's
website: http://www.epa.gov/opptintr/
epp.
2. In person. The Agency has
established an official record for this
action under docket control number
OPPTS-00149A. The official record
consists of the documents specifically
referenced in this action, any public
comments received during an applicable
comment period, and other information
related to this action, including any
information claimed as confidential
business information (CBI). This official
record includes the documents that are
physically located in the docket, as well
as the documents that are referenced in
those documents. The public version of
the official record does not include any
information claimed as CBI. The public
version of the official record, which
includes printed, paper versions of any
electronic comments submitted during
an applicable comment period, is
available for inspection in the TSCA
Nonconfidential Information Center,
North East Mall Rm. B-607, Waterside
Mall, 401 M St., SW., Washington, DC.
The Center is open from noon to 4 p.m.,
Monday through Friday, excluding legal
holidays. The telephone number for the
Center is (202) 260-7099.
EQ. Introduction
On September 14, 1998, President
Clinton signed Executive Order 13101,
entitled "Greening the Government
through Waste Prevention, Recycling
and Federal Acquisition." Section 503
of this Executive Order requires EPA to
establish guidance to "address
environmentally preferable
purchasing."
The guidance that is being made
available today is designed to help
Executive agencies meet their
obligations under Executive Order
13101 to identify and purchase
environmentally preferable products
and services. "Environmentally
preferable" is defined in section 201 of
the Executive Order to mean products or
services that have a "lesser or reduced
effect on human health and the
environment when compared with
competing products or services that
serve the same purpose." The guidance
is intended to draw on the extensive
procurement experience of the
Executive agencies and on the
environmental expertise of EPA and
others both within and outside of the
government. It provides a broad
decision-making framework for
environmentally preferable purchasing
and is a first step to help Executive
agencies systematically integrate
environmental preferability into the
Federal government's buying decisions.
IV. Background
This Final Guidance on
Environmentally Preferable Purchasing
is based on EPA's September 1995
Proposed Guidance on the Acquisition
of Environmentally Preferable Products
and Service and the comments received
on that proposal. EPA announced the
availability of and sought comment on
the Proposed Guidance on the
Acquisition of Environmentally
Preferable Products and Service on
September 29, 1995 (60 FR 50721)
(FRL-4760-5). The process EPA used to
develop the proposed guidance is
described in that Federal Register
notice. In addition, lessons and insights
from early pilot projects have guided the
development of the Final Guidance.
Since 1995, a variety of things have
occurred that will directly affect the
Federal government's environmentally
preferable purchasing practices.
Foremost are the 1997 revisions to the
Federal Acquisition Regulations that
incorporate policies for the acquisition
of environmentally preferable and
energy-efficient products and services.
These changes require the consideration
of environmental factors in all aspects of
Federal acquisition, including
acquisition planning (part 7),
conducting market surveys (part 10),
describing an agency's needs (part 11),
evaluating and selecting a vendor (parts
14 and 15), and contract administration
(part 42), as well as other provisions.
Another milestone is the 1996
enactment of the National Technology
Transfer laid Advancement Act of 1995
(NTTAA) which requires the Federal
government to use consensus-based
industry standards when available
rather than creating a government-
unique stijndard.
The acquisition streamlining reform
initiatives have also brought many
changes to the way the Federal
government purchases products and
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45811
services. One example is increased
decentralization of the purchasing
decision, best exemplified by the
meteoric increase in credit card use by
Federal agency personnel. The number
of card holders increased from 10,000 in
1989 to 250,000 in 1996 with the dollar
volume increasing from $460,000 to
close to $3 billion during the same time
period. This trend highlights the
importance of reaching out to those
beyond the acquisition community with
the environmentally preferable
purchasing message.
Another trend is the increased interest
at all levels of government—local, state
and foreign—in using the government's
purchasing power as a policy tool to
drive environmental improvement. This
trend will likely accelerate the
anticipated spill-over effect of
environmentally preferable purchasing
practices. Beyond the governments'
interest, other large institutional
purchasers—non-profits and individual
companies-are also beginning to
include environmental factors in their
buying decisions.
V. Lessions Learned
In the years since the Proposed
, Guidance was first issued, a number of
pilot projects were initiated to
demonstrate how EPA's Proposed
Guidance could be applied to specific
product categories. Though limited in
number, these projects have provided
important insights into the development
of the Final Guidance as well as the
direction of EPA's Environmentally
Preferable Purchasing program.
First; it is important to have the
participation of both the environmental
and the acquisition/procurement
personnel. The acquisition of
environmentally preferable products
and services in the Federal government
context involves both defining what is
environmentally preferable for a given
product or service and ensuring that the
procurement process encourages the
purchases of these products. Innovative
approaches that leverage the expertise of
the environmental and procurement
experts is essential to accomplishing
these tasks and institutionalizing
environmentally preferable purchasing
practices.
Second, on a very positive note, early
pilots have shown that vendors
understand that providing a broad range
of environmental information is an
important part of doing business with
the government and that it can serve as
a competitive advantage. Generally
speaking, however, information about
environmental performance of products
and services, particularly along the
various life cycle stages, and easy-to-use
tools to assess environmental
performance remain scarce, limiting the
wide-spread adoption of
environmentally preferable purchasing.
This is likely to change as Executive
agencies begin to implement the '.
changes to the Federal Acquisition
Regulations and as agencies begin to use
information and technical ejcpertise of
non-governmental entities.
Lastly, early pilots indicate that there
is not a single, "one size fits all,"
approach to incorporate environmental
preferability into Federal acquisition.
Using common sense, we need to tailor
our approach and level of analysis to fit
the complexity of the product and
service categories being purchased.
Much progress has been made since
Executive Order 12873 was issued in
October 1993. A number of pilot
projects have been implemented by key
purchasing agencies that have provided
valuable insights and lessons on ways to
integrate environmental considerations
into the Federal procurement process.
These pilots have helped to identify
gaps in information and tools. Future
pilots will be instrumental in guiding
both EPA's and other Executive
agencies' efforts in environmentally
preferable purchasing. As EPA and the
other agencies move forward, the debate
about the appropriate approaches and
goals will likely continue. This is
desirable given the dynamic nature of
the issue. Based on feedback from all
stakeholders, EPA will continue to test
a variety of approaches and develop and
refine tools to allow agencies to more
readily apply the concepts of
environmental preferability iin
government purchasing decisions.
VI. Major Changes to the Guidance
This section describes some of the key
changes made to the 1995 Proposed
Guidance. EPA has also prepared a more
detailed Response to Comment
document, which has been included in
the public record for this guidance.
A. Guidance Framework
The Guidance framework remains
largely unchanged and includes an
introduction (Section I), intended
audience (Section II), approach (Section
III), a set of guiding principles (Section
IV), suggested steps for Executive
agency implementation (Section V), and
appendices (Section VII). A new section,
Section VI, lists available resources and
tools related to environmentally
preferable purchasing.
B. Guiding Principles
A number of changes have been made
to the guiding principles, including the
addition of a new principle and the
merging of a number of principles. As
a result, the Final Guidance now has
five, rather than seven, guiding
principles. Taken together, the
principles are intended to provide a
broad guide to help Executive agency
purchasers address environmental
preferability in acquisition of products
and services. Specifically, the following
changes have been made:
1. A new principle on product safety,
price, environmental considerations,
performance and availability has been
added as Principle #1 and reads:
Environmental considerations should
become part of normal purchasing practice
consistent with such traditional factors as
product safety, price, performance, and
availability.
This was in response to a number of
comments requesting more emphasis be
placed on the point that the addition of
environment is not in lieu of traditional
purchasing factors. Although the
original proposal noted this, the
addition of this new principle should
send a clearer message on the
importance of putting environmental
considerations in the context of other
purchasing factors.
2. The guiding principles on life cycle
and multiple attributes have been
collapsed into one principle (Principle
#3) and reads:
A product's or service's environmental
preferability is a function of multiple
attributes from a life cycle perspective.
This change is based on comments
and also EPA's strong belief that the two
concepts are integral in determining
environmental preferabiliry. The
discussion that follows the guiding
principle has also been modified to
reflect that although the determination
of environmental preferability should be
based on multiple attributes, the
purchasing decision may at times be
based on a single attribute.
3. The guiding principles on impacts
and local conditions*have been
modified and collapsed into one
principle (Principle #4) and reads:
Determining environmental preferability
may involve comparing environmental
impacts. In comparing environmental
impacts, Federal agencies should consider:
the reversibility and geographic scale of the
environmental impacts, the degree of
difference among competing products or
services, and the overriding importance of
protecting human health.
This change was made to remove the
perceived conflict between the two
original principles and to provide
purchasers with more guidance on how
to assess relative impacts. The original
principles were intended to convey that,
in general, global and irreversible
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environmental impacts should be given
greater weight in determining
preferability than local and rapidly
reversible environmental impacts.
However, we also recognize that there
may be situations in which there are
unique mitigating circumstances locally,
and in those cases, the purchaser can
make the judgement that the local
conditions and impacts should be given
priority.
4. The principles on competition and
product attribute have been revised and
a new principle (Principle #5) on
environmental information has been
added. It reads:
Comprehensive, accurate and meaningful
information about the environmental
performance of products or services is
necessary in order to determine
environmental preferability.
This revision was based on lessons
from the pilots and reflects the
importance of having relevant
environmental information for
determining environmental
preferability. The discussion related to
competition which originally appeared
under guiding Principle #6 is now
captured under guiding Principle #1.
C. Federal Agency Implementation
A number of changes have been made
to facilitate Executive agency
implementation of environmentally
preferable purchasing, including:
1. EPA recommends that Executive
agencies look to EPA's list of the top 20
prioritized product categories to focus
their pilot projects. The description of
this list is included in Section VI of the
Final Guidance and the complete list is
available on EPA's Environmentally
Preferable Purchasing Program's
website: www.epa.gov/opptintr. The
prioritized list was developed pursuant
to Section 503 (a) of Executive Order
13101 which states that EPA's guidance
"should be.. .targeted towards products
and services that have the most effect."
2. In implementing pilot projects, EPA
recommends, pursuant to section
503(b)(2) of Executive Order 13101, that
agencies use all of the options available
to determine environmentally preferable
attributes of products and services in
pilot projects, including the use of
technical expertise of non-governmental
entities such as labeling, certification, or
standards developing organizations.
Additional guidance on the use of these
organizations is elaborated in the Office
of Federal Environmental Executive and
EPA's April 1998 policy letter. The full
text of this policy letter has been added
as Appendix E.
3. EPA recommends that agencies
document their pilot efforts. In order to
facilitate this, the Final Guidance
includes a sample case study template
(Appendix E).
D. Appendices
A number of changes have been made
to this section, including:
1. The addition of three new items:
i. Sample Policy Directive (Appendix
C).
ii. Full Text of April 1998 Policy
Letter on Non-governmental Entities
(Appendix: D).
iii. Sample Case Study Template
(Appendix: E).
2. The deletion of the original
Appendix D, "A Summary of the
Federal Trade Commission's Guides to
the Use of Environmental Marketing
Claims." The Guides were updated in
May 1998 and the information on how
to access the most recent Guides is now
included in Section VI—Resources.
VII. Final Guidance on
Environmentally Preferable Purchasing
for Executive Agencies
For the convenience of the reader, the
final guidance is published below in its •
entirety.
BILLING CODE: esso-so-F
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45813
Final Guidance on Environmentally Preferable Purchasing
Table of Contents
I. Introduction
II. Intended Audience of This Guidance
HI. Overall Approach for Implementing Executive Order 13101
IV. Guiding Principles
V. Executive Agency Implementation
VI. List of Resources
A. EPP Web Site
B. Federal Case Studies of Environmentally Preferable Purchasing
C. Life Cycle-Based Resources
D. Agency Environmental Catalogs
E. Federal Trade Commission's Guides on the Use of Environmental Marketing Claims
F. Office of Federal Environmental Executive Web site
. G. Other Resources and Tools
VII. Appendices
Appendix A Glossary of Terms
Appendix B Environmental Attributes
(1) Menu of Environmental Attributes
(2) Definitions for Environmental Attributes
Appendix C Sample EPP Policy Directive
Appendix D Text of Policy Letter on Use of Non-Governmental Entities Issued By the
Office of Federal Environmental Executive and U.S. Environmental
Protection Agency, April 1998
Appendix E Pilot Project Case Study Template
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Guidance on Environmentally Preferable Purchasing
I. Introduction
On September 14,1998, President Clinton signed Executive Order (EO)13101, entitled
"Greening the Government through Waste Prevention, Recycling and Federal Acquisition."
Executive Order 13101 (EO 13101) supersedes EO 12873, Federal Acquisition, Recycling and
Waste Prevention, issued on October 20,1993, but retains a similar requirement for the U.S.
Environmental Protection Agency (EPA) to develop guidance to "address environmentally
preferable purchasing." (Section 503, EO 13101) The Final Guidance that follows is based on
EPA's September 1995 Proposed Guidance on the Acquisition of Environmentally Preferable
Products and Services (60 FR 50721, September 29,1995) and comments received on that
Proposed Guidance as well as lessons learned from pilot projects conducted to date.
The Final Guidance below is designed to help Executive agencies meet their obligations
under EO 13101 to identify and purchase environmentally preferable products and services.
Section 503 (c) of EO 13101 directs Executive agencies to "use the principles and concepts in the
EPA Guidance on Acquisition of Environmentally Preferable Products and Services, in addition
to the lessons from the pilot and demonstration projects to the maximum extent practicable, in
identifying and purchasing environmentally preferable products and services" and "modify their
procurement programs as appropriate." Furthermore, Section 23.704 of the Federal Acquisition
Regulation requires agencies to "affirmatively implement" the objective of "obtaining products
and services considered to be environmentally preferable (based on EPA-issued guidance)."
"Environmentally preferable" is defined in Section 201 of EO 13101 to mean products or
services that "have a lesser or reduced effect on human health and the environment when
compared with competing products or services that serve the same purpose. This comparison
may consider raw materials acquisition, production, manufacturing, packaging, distribution,
reuse, operation, maintenance or disposal of the product or service."
•
Implementation of the Final Guidance will draw on the procurement experience of the
Executive agencies and on the environmental expertise of EPA and other organizations both
within and outside of the Federal government. This guidance provides a broad framework of
issues to consider in environmentally preferable purchasing and will help Executive agencies
systematically integrate environmental preferability principles into then- buying decisions.
The guidance is not however, a step-by-step, "how to" guide and it is not intended to
answer many of the specific questions that might arise in the acquisition of a particular product
category or service. The list of resources in Section VI provides more specific guidance and
information about various product and service categories, environmental attributes that have been
identified for them, and the approaches used to consider those attributes in acquisition decisions.
For the latest information on other resources and tools under development, Executive agency
personnel and others are directed to EPA's Environmentally Preferable Purcliasing Program
Web site at:
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The Final Guidance strives to meet the National. Performance Review and procurement
reform goals of simplifying and streamlining Federal purchasing while recognizing that the
definition of "environmentally preferable" will likely require the consideration of different
environmental factors as appropriate for different situations. ;In sum, the guidance:
• Applies to all acquisition types, from supplies and services to buildings and
systems.
• Provides a set of guiding principles.
• Requests Executive agencies to select and implement pilot acquisitions or
demonstration projects.
• Provides a framework for Executive agencies to implement the environmentally
preferable purchasing provisions of EO13101.
II. Intended Audience for the Guidance
The target audience of this guidance includes all Executive agency employees involved in
the acquisition of supplies, services, systems, and/or facilities. The general guidance and the
information generated by the pilot projects also will be useful to Executive agency employees
who request, maintain, or use the supplies, services, systems and facilities. In addition, both the
general guidance and the pilot project information should provide pragmatic direction for private
sector businesses who wish to manufacture, market, or provide environmentally preferable
products and services for use by the Federal government.
III. Overall Approach for Implementing Executive Order 13101
Section 503 of EO 13101 has two key components: (1) development of this guidance; and
(2) implementation of the guidance through pilot and demonstration projects. This guidance
sets a broad policy framework for implementing environmentally preferable purchasing within
the context of Federal government. For the second component, Section 503 (b) of the EO states
"[A]gencies are encouraged to immediately test and evaluate the principles and concepts
contained in the EPA's Guidance—through pilot projects...". These pilots may be undertaken
using the in-house expertise of EPA and other Executive agencies, as well as the technical .
expertise of nongovernmental entities, including, but not limited to, voluntary consensus
standards bodies (see§ 12(d) of the National Technology Transfer and Advancement Act (Pub. L.
104-113, §12(d), 15 U.S.C. 272 note), environmental standard setting organizations, third party
certification programs, environmental labeling or environmental "report card" programs, and
other environmental consulting organizations. Section V of this Final Guidance provides more
detail about how these pilot projects might work. These pilots are expected to yield more
specific and practical information about applying this Final Guidance to purchases of particular
products and services.
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In addition to promoting environmentally preferable purchasing, EO 13101 encourages
Executive agencies to purchase bio-based products. (Section 504 (b)). Under the EO, "biobased
product" means "a commercial or industrial product (other than food or feed) that utilizes
biological products or renewable domestic agricultural (plant, animal and marine) or forestry
materials."
Bio-based products may also be environmentally preferable. Made from renewable
resources by definition, these products have many positive environmental aspects and should be
considered by agencies looking to make environmentally preferable purchases. However,
Federal purchasers should not assume all bio-based products are automatically environmentally
preferable. As with other products, Executive agencies should consider a range of environmental
impacts associated with bio-based products when making purchasing decisions. In some cases,
factors such as pesticide use or high water consumption might make a bio-based product less
environmentally preferable. The list of bio-based products which the U.S. Department of
Agriculture will issue under Section 504 of EO 13101 will be a good starting point for Executive
agencies looking to identify environmentally preferable purchasing. During the development of
pilots under Section 503 (b) of the EO, EPA will look for opportunities involving bio-based
products.
IV. Guiding Principles
EPA has developed five guiding principles to provide broad guidance for applying
environmentally preferable purchasing in the Federal government setting. Applicability of these
principles in specific acquisitions will vary depending on a variety of factors, such as: the type
and complexity of the product or service being purchased; whether or not the product or service
is commercially-available; the type of procurement method used (e.g., negotiated contract, sealed
bid, etc.); the tune frame for the requirement; and the dollar amount of the requirement.
In all acquisitions, Executive agency personnel use their professional judgement and
common sense, whether assessing a product or service's performance, cost, or availability.
Similarly, in applying these environmentally preferable principles Executive agency personnel
should use reasonable discretion about the level of analysis needed to determine environmental
preferability. For example, an extensive life cycle assessment might not be conducted to
purchase rubber bands. On the other hand, for large-volume or systems acquisitions, or for
complex products, such assessments may be appropriate, and might already be required. Or, in
some cases, much of the information upon which to build such an analysis might have already
been collected.
Guiding Principle 1: Environment + Price + Performance = Environmentally
Preferable Purchasing
Environmental considerations should become part of normal purchasing practice,
consistent -with such traditional factors as product safety, price, performance, and
availability.
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45817
The manufacture, use, and disposal of certain products might have adverse impacts on
human health and the environment. These impacts impose costs that the purchasing
entity, and ultimately, society as a whole, end up paying for in one way or another. For
the Federal government, the hazardous or toxic nature of a product or service can result in
significant cleanup or liability costs, as well as in less directly quantifiable, but
cumulative and persistent environmental damage. Even non-hazardous waste is
associated with ever-increasing disposal costs that can be avoided or reduced.
Responsible management, beginning with the initial purchase of products and services
that minimize environmental burdens, can diminish the Federal government's raw
material, operating, maintenance, and disposal costs. In addition, a product or service's
environmental preferability can often have positive impacts on its overall performance.
For these reasons, the Federal government's purchasing decisions are no longer confined
to considerations of price and functional performance but should include considerations
of environmental performance as well. Today agencies can obtain improved
environmental attributes not at the expense of, but instead may operate in concert with,
other traditional factors like price and functional performance. Those product or service
providers who can optimize all these factors will capture and maintain the largest market-
share of government customers.
Just like price, performance, and health and safety, environmental factors should be a
subject of competition among vendors seeking government contracts. In turn, this
increased competition among vendors should stimulate continuous environmental
improvement and increase the availability of environmentally preferable products and
services. The purpose of this guidance is to encourage Executive agencies to award
contracts to companies that take environmental concerns into account. This process,
consequently, will lead to the development of environmentally preferable products and
services that perform better and cost less because they reduce waste and negative
environmental impacts. As stated, this principle reflects the spirit of a number of
reinvention initiatives at EPA and across the Federal government aimed at testing cleaner,
cheaper, and smarter approaches to environmental protection.
Agencies have considerable discretion in incorporating environmental preferability into
procurement decisions, especially within the context of "best value" contracting. For
example, environmental considerations that result in payment of a price premium for
goods or services may be reasonably related to an agency's definition of its "minimum
needs" and, therefore, may be permissible. This is not much different than paying a
higher price for better performance or quality. Federal personnel may consider paying a.
reasonable premium for environmentally preferable products on a number of grounds.
For example, a reasonable price premium may be justified because the environmental
attributes of a product or service provide offsetting reductions in operating and disposal
costs.
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Guiding Principle 2: Pollution Prevention
I
Consideration of environmental preferability should begin early in the acquisition
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 environment.
It is never too early in the acquisition process to begin considering environmental
preferability. Pollution prevention, the reduction or elimination of waste at the source,
can not only reduce pollution, but it can save money for agencies as well. Defense and
civilian Federal agencies have ongoing programs for pollution prevention under EO
12856 and other authorities that can result in cost savings throughout the product or
service life cycle. Furthermore, pollution prevention measures can lead to a higher
degree of environmental protection by reducing subsequent costs for disposal or cleanup
of hazardous wastes and materials. A key reason for environmentally preferable
purchasing is to protect the environment by reducing waste and pollution at the source
with the resulting benefit of reduced overall cost to the government and the public
(taxpayers and society as a whole).
Under this guiding principle, pollution prevention should be the primary motivation and
strategy for the Federal government's implementation of environmentally preferable
purchasing. There are many ways to apply pollution prevention to the acquisition
process:
a) Customized purchases or projects in which program managers, architects, engineers,
systems designers, or others have input into the design phase afford agencies an early
opportunity to apply environmentally preferable concepts. In addition, early involvement
offers agencies a unique point of leverage from which to address environmental impacts.
Although these types of purchases are not the bulk of Federal acquisition requirements,
the early stage of qustomized product or project design is the time when decisions about
different approaches, materials, and manufacturing processes are made. Estimates show
that 70 percent or more of the costs associated with product development, manufacture,
and use are determined during the initial design stages.1 By incorporating environmental
factors during product or service design, Federal agencies can minimize environmental
problems and their associated costs. For example, early environmental consideration
helps agencies avoid potential liabilities due to fines as well as the costs of record
keeping and reporting.
b) During the early stages of acquisition, Executive agency personnel ican also apply a
systems analysis approach for certain products or services (such as computers, buildings,
and transportation systems) hi which a number of components have interdependent
functions. A systems analysis approach takes into consideration the full set of product
JU.S. Congress, Office of Technology Assessment, Green products by Design: Choices for a Cleaner
Environment, OTA-E-541 (Washington, D.C.:U.S. Government Printing Office, October, 1992)
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45819
elements, focusing on how they
interact from a life cycle perspective
and helping to identify the most
• efficient options for meeting the
government's needs.
c) Executive agency personnel might
also appropriately ask whether a
product or a service is even necessary
or can be replaced by a less damaging
process. For instance, in degreasing
operations, questions arise as to
whether an efficient cleaner using
halogenated solvents is better or
worse for the environment than an
aqueous-based cleaner. A more
appropriate question may be whether
the cleaning/degreasmg step can be
eliminated without affecting the
overall performance of the product or
system. This might be accomplished,
for example, by consolidating
cleaning and degreasing in a later
stage of the manufacturing process or
changing the process itself. As this
example illustrates, environmental
preferability does not just involve
substituting a "green" product for
another. It also involves questioning
whether a function needs to be
performed and how it can best be
performed to minimize negative
environmental impacts.
The Department of Defense integrates pollution
prevention into all of its major weapons system
acquisition programs. For example, the New Attack
Submarine (NSSN) Program has worked to include
environmental considerations in all phases of the
submarine's life cycle, from initial design to eventual
disposal some 30 or more years later.
By considering all viable environmental alternatives
during the design phase, the NSSN Program identified a
number of options that will result in benefits. Just a few
examples are listed below:
• A redesigned nuclear reactor core will eliminate the
need for refueling and disposal of spent nuclear fuel,
while achieving a multi-million dollar cost
avoidance. !
• 31 percent reduction in the number of paints and
coatings used in manufacturing the NSSN while
ensuring that all of the selected paints satisfy
applicable .performance and environmental
requirements.
• 61 percent reduction in the number of adhesive
products to be used on the NSSN compared to the
number required for previous submarine classes.
• 80 percent reduction in the number of solvents and
cleaners.
• Research and development effortto identify and test
a biodegradable hydraulic fluid for submarines to
replace the current toxic mineral oil-based fluid.
By recognizing early on that the key to reducing
environmental impact throughout the ship's life cycle is
pollution prevention and hazardous material control and
management, the NSSN Program was able to design a
submarine that meets strict safety and performance
requirements, achieves significant cost savings, and
minimizes risk to the environment.
Guiding Principle 3: Life Cycle Perspective/Multiple Attributes
A product or service's environmental preferability is a Junction of multiple attributes
from a life cycle perspective.
Federal agencies should consider the following concepts in applying this principle :
a) Life cycle perspective—A product or service has environmental impacts long before
and after the Federal government purchases and uses it. The manufacture, use,
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distribution, and disposal of products create a variety of burdens on the environment.
Federal agencies should strive to purchase products or services with as few negative
environmental impacts in as many life cycle stages as possible. In other words, Federal
agencies should determine the "environmental preferability" of a product or serviee by
comparing the severity of environmental damage it causes throughout its life cycle with
that caused by competing products—from the point of raw materials acquisition, product
manufacturing, packaging, and transportation to its use and ultimate disposal. By doing
so, the Federal government can minimize the overall environmental impacts of products
and services. In addition, by actively seeking and considering life cycle information to
inform buying decisions, Executive agency personnel can send a clear signal that
government business will go to those who consider the effect of their product's life cycle
on the environment.
Life Cycle Stages of a Typical Product
Although most people would agree that considering life cycle impacts in purchasing
decisions is desirable, there are disagreements on how to make purchasing decisions that
best reflect a life cycle perspective. Even the term "life cycle" is interpreted differently
by'different people. To some, it connotes an exhaustive, extremely time-consuming, and
very expensive analysis. To others, a life cycle perspective is possible iin an abbreviated
process, in which a long list of potential environmental attributes and/or impacts is
narrowed to a few, allowing for comparison across a particular product category. In
addition, the ability of Federal purchasers to make buying decisions from a life cycle
perspective depends on a variety of factors including: the type of product or service being
purchased; the availability of life cycle information and/or willingness by the provider to
give the information; and the availability of easy-to-use tools that can translate this
information to support purchasing decisions by the Federal government. EPA recognizes
that agencies may find it easier to apply a life cycle perspective when the result will be
internal agency environmental benefits and/or cost savings rather than external benefits.
Nevertheless, EPA encourages agencies to consider reducing impacts ailong all stages of
the product or service life cycle.
This guidance promotes the use of a range of practices, from life cycle considerations to a
more rigorous, scientifically defensible life cycle assessment methodology. EPA
encourages Executive agencies to use currently available tools as well as help refine and
address the needs of Federal purchasers. Examples of available tools and references are
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listed in Section VI. For the most current list of available tools, Executive agency
personnel are referred to EPA's EPP Program Web site: .
EPA also encourages experts both within and outside of the Federal community to
develop additional life cycle tools to support environmental preferability decisions." "'
b) Multiple environmental attributes — Environmental preferability should reflect the
consideration of multiple environmental attributes such as increased energy efficiency,
reduced toxicity, or reduced impacts on fragile ecosystems. In addition, these attributes
should be considered from a life cycle perspective. Focusing on one environmental
attribute of a product or a service, without considering others, might inadvertently
exclude important impacts on the determination of environmental preferability. For
example, improving one attribute (e.g., increased energy efficiency or reduced toxicity)
may result in other unintended environmental life cycle impacts. It is also possible that
focusing on a single aspect of the product or service will cause Executive agency
personnel to overlook improvements that the vendor has or can make in other aspects of
the product or service. In short, it is difficult to be confident that an alternative product is
environmentally preferable without some consideration of multiple attributes from a life
cycle perspective. Analytical tools such as life cycle assessment can help Federal
agencies ensure the product or service they purchase does not create new problems for
some other aspect of the environment by identifying other potential negative impacts that
should be alleviated.
Although the determination of environmental preferability should be based on multiple
environmental attributes, Federal agencies may at limes make purchasing decisions based
on a single attribute when that attribute distinguishes the product or service in a category.
In its environmentally preferable purchasing effort, EPA aims to build upon those
attributes that are well-defined, measurable and familiar to Federal purchasers (e.g.,
recycled content and energy efficiency). EPA also seeks to support the development of
similar definitions and measures for other attributes that are less understood and to
advance consideration of multiple environmental attributes in purchasing decisions.
The menu of environmental attributes described hi Appendix B offers a preliminary look
at what should be considered in environmentally preferable purchasing decisions. Many
of the attributes are relevant to a number of different product life cycle stages, while
others are more pertinent to one particular stage. The menu should serve as a means to
inform Executive agency personnel about the different types of attributes that can make a
product or service environmentally preferable. Each and every element in the menu is not
meant to be applicable to all products and services nor is the menu all-inclusive
Guiding Principle 4: Comparison of Environmental Impacts
Determining environmental preferability might involve comparing environmental
impacts. In comparing environmental impacts. Federal agencies should consider: the
reversibility and geographic scale of the environmental impacts, the degree of difference
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among competing products or services, and the overriding importance of protecting
human health.
In determining environmental preferability, Executive agency personnel might need to
compare the various environmental impacts among competing products or services. For
example, would the reduced energy requirements of one product be more important than
the water pollution reductions associated with the use of a competing product? The ideal
option would be a product that optimized energy efficiency and minimized water
pollution. When this is not possible, however, Executive agency personnel will have to
choose between the two attributes. It is important to consider both the nature of the
environmental impact and the degree of difference among competing products.
There is no widely accepted hierarchy that ranks the attributes or environmental impacts
that are most important. The following three factors are intended to help Executive
agency personnel analyze the environmental impacts of competing products and services
and make decisions about environmental preferability when faced with trade-offs among
environmental attributes. These factors are not listed in order of importance.
a) Recovery time and geographic scale—Federal agencies should consider
recovery time and geographic scale in comparing environmental impacts. To
what extent is an environmental impact reversible? An impact is less acceptable
if the recovery time is longer.2 The geographic scale of the problem and the
importance of the affected ecosystems are also significant. Global environmental
impacts are more significant, therefore, than ecological stressore that have a local
or regional ecosystem impact.3
: • i
The table shown below provides a basic framework for considering the
reversibility and geographical scale of environmental impacts and includes some
examples of how certain impacts might fit into the matrix.
While some environmental standards or other sources of comparative information
on products are national or international in scope, Federal agencies should also be
prepared to consider unique local impacts and site-specific uses. Information
based on an assessment of national or global needs, by its nature, rarely allows for
the consideration of local impacts associated with how products are used,
2T!iis is based on the findings of the Science Advisory Board, published in its 1990 report entitled "Reducing
Risk: Setting Priorities and Strategies for Environmental Protection," a statement of policy on priority pollutants
affecting environmental and public health. In this report, environmental stressors were judged to be significant based
on two primary criteria—the geographic scale and degree of reversibility of the impact.
The Science Advisory Board is a public advisory group providing extramural scientific information and advice
to the Administrator and other officials of the Environmental Protection Agency. The Board is structured to provide
balanced, expert assessment of scientific matters related to problems facing the Agency.
3Refer to above footnote.
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recycled, and/or discarded. Executive agency personnel are encouraged to
consider local factors, where they are relevant, and not rely exclusively on
national or global information. For example, although it may be generally
accepted that an aqueous-based degreaser is preferred over a halogenated solvent
degreaser, the environmentally preferable purchasing decision may depend on
whether there is sufficient local wastewater treatment capacity to deal with the
aqueous waste.
There may be rare occasions where the goal of minimizing a local impact, such as
smog, is in conflict with the goal of minimizing a global impact, such as ozone
depletion and global climate change. In these instances, EPA encourages
purchasers to engage as much as possible in applying Principle #2 and aiming to
prevent pollution, thereby avoiding such trade-offs. Where there are unique local
circumstances, the purchaser can make the judgment that the local conditions and
impacts should be given priority.
ECOLOGICAL PRIORITY IMPACTS MATRIX
Geographic
Scale
Reversibility
Local/Regional
National
Global
Years
* Erosion
* Conventional Pollutants
•Hazardous Air Pollutants
* Chemical Releases
Decades
* Bioaccumulative
Pollutants
Centuries/ Indefinite
* Loss of biodiversity
* Ozone Depleting Chemicals
* Global Wanning Gases
»....»*.a ivrr wojjipiwa vi uvw w&iuuii cuviiumiiciiuii MrcsMjra ana impacts migni
the different categories of reversibility and geographic scale considerations and is not meant to be
comprehensive.
b) Differences among competing products—In some situations, a purchaser may
determine preferability by looking at the differences of environmental
performance among competing products, rather than by comparing environmental
problems. Guiding Principle 3 addresses the importance of identifying relevant
attributes for a product. There might be significant differences among competing
products for some of these attributes, while for others, the differences could be
minimal. In purchase comparisons, Executive agencies might prefer the product
or service that provides a significant improvement over competing products,
without making a determination that one environmental problem is more
significant than another. For example, a product that significantly reduces
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toxicity might be preferable to one that makes a minimal reduction in waste
reduction.
c) Human health -A product or a service should be at least equivalent to
comparable
products/services in
protecting human health to
be considered
environmentally
preferable. EPA's
Science Advisory Board
listed the environmental
factors listed to the right as
significant contributors to
human health risks.
List of High Priority Human Health Stressors
(not in any order of importance):
Ambient air pollutants
Hazardous air pollutants
Indoor air pollution
Occupational exposure to chemicals
Bioaccumulative pollutants
EPA recognizes that Executive agencies considering these three factors ( recovery time
and geographic scale; differences among products; and human health) must rely on
providers of products and services to supply practical environmental information on
products. EPA encourages organizations that provide environmental standards or other
types of comparative product information to consider these factors in evaluating and
reporting environmental information for purchasers.
Guiding Principle 5: Environmental Performance Information
Comprehensive, accurate, and meaningful information about the environmental
performance of products or services is necessary in order to determine environmental
preferability.
|
a) Importance of Environmental Information — Executive agency personnel will need
comprehensive, accurate and meaningful life cycle-based information about the
environmental characteristics of products and services in order to evaluate whether one
product or service is more or less damaging than another. Even with this thorough
information, however, making these evaluations can be difficult. Yet, without such
information, determinations of environmental preferability are even more challenging.
Executive agency personnel are encouraged to seek, and product and service providers
are encouraged to provide, life cycle-based information about the environmental
performance of products and services. This information should be sought and provided in
all appropriate stages of the acquisition process including, but not limited to market
surveys, request for proposals, etc. (See Federal Acquisition Regulation, (FAR) 48
C.F.R. Subpart 23.7, which includes a mandate for the acquisition of environmentally
preferable and energy-efficient products and services.
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Executive agency purchasers may encourage product and service providers to describe
their product or service's performance according to the menu of environmental attributes
included in Appendix B (1).
Product and service providers' disclosure of environmental information about their
products and services will also foster competition and encourage a market-driven
approach to environmental improvement. The accessibility of the information to the
public (both Executive agency personnel and the general public) will help ensure its
accuracy and credibility.
b) What/How Information is Conveyed - A number of resources about the environmental
performance of products or services are currently available. Two general categories of
information sources can be distinguished: (1) manufacturers who provide environmental
information (e.g., environmental claims, product profiles, etc.) about their products either
on the label or through product literature, including advertisements; and (2)
environmental information compiled, evaluated, and reported by non-governmental
entities. Included in this second category are third-party certification programs that
evaluate the environmental aspects of products, and award symbols (e.g., "seals-of-
approval") or compile "report cards" of environmental information. Non-governmental
entities may also verify specific claims made by manufacturers (e.g., paper contains 30
percent recycled content).
Information conveyed through claims and seals can help Executive agency personnel
identify environmentally preferable products, depending on the types of products being
purchased and the legal acquisition requirements involved. A more detailed discussion of
how Executive agencies can use technical expertise and research of non-governmental
entities in their environmentally preferable purchasing practices is included in Section V
and Appendix D. In evaluating the environmental attribute claims made by anyone,
whether they are manufacturers, vendors, or other non-governmental entities, Executive
agency personnel should refer to the Federal Trade Commission's (FTC's) "Guides for
the Use of Environmental Marketing Terms." (Green Guides.)
V. Executive Agency Implementation
This section recommends steps that each agency can take to implement the
environmentally preferable purchasing provisions of EO 13101.
A. Policy directive and affirmative procurement plans
Recognizing that effective implementation of environmentally preferable purchasing will
require clear direction and support from the top levels of each agency, this Final Guidance
recommends that each Executive agency issue a Policy Directive promoting the practice. A
sample is included in Appendix C. The policy directive should include the elements listed
below:
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An overall statement of policy:
• Agency personnel should seek to reduce the environmental damages associated
with their purchases by increasing their acquisition of environmentally preferable
products and services to the extent feasible, consistent with price, performance,
availability, and safety considerations.
• Environmental factors should be taken into account as early as possible in the
acquisition planning and decision-making process. (See EO 1.3101, Section 401.)
• Responsibility for environmentally preferable purchasing should be shared among
the program, acquisition, and procurement personnel.
A commitment to the following:
• Increasing the acquisition of environmentally preferable products and services.
(See EO 13101, Sections 102,503 (.c), and 602.)
Under section 6002 of the Resource Conservation and Recovery Act of 1976 and
FAR Subpart 23.4, procuring agencies are required to establish affirmative
procurement programs for purchasing EPA-designated recycled products. EPA
recommends that agencies expand the scope of their affirmative procurement
programs to include environmentally preferable products and services. EO
13101, Section 302, (a)(lXa) calls for a Strategic Plan to include the "direction
and initiatives for acquisition of recycled and recyclable products and
environmentally preferable products and services." Furthermore, Section 302 (b)
(1) requires Agency Environmental Executives to "translate [this] Government-
wide Strategic Plan into specific agency and service plans."
• Identifying and implementing pilot projects (See Section V (B) below).
• Establishing internal agency incentive and award programs to recognize those
people, teams, and interagency work groups who are most successful at promoting
the purchase of environmentally preferable purchasing (see Executive Order
13101, Section 802). Collaboration among agencies to provide education and
training is highly encouraged.
In order to minimize the burden on Executive agencies, EPA recommends that each
agency incorporate in its Policy Directive to promote environmentally preferable purchasing into
its Affirmative Procurement and Strategic Plans. This incorporation can transpire as agencies
revise their plans. Agencies should ensure that their Policy Directive is made available to the
field-level procurement and environmental personnel.
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B. Pilot Projects
Section 503 (b) of EO 13101 states "jAjgencies are encouraged to immediately test and
evaluate the principles and concepts contained in the EPA's Guidance on the Acquisition of
Environmentally Preferable Products and Services through pilot projects to provide practical
information to the EPA for further updating of the guidance." Furthermore, Section 704 states
"Each executive agency shall establish a model demonstration program... to demonstrate and
test new and innovative approaches such as incorporating environmentally
preferable...products...." into model facility programs. To help Executive agencies implement
these provisions of the EO, this Final Guidance includes some suggested steps for initiating and
implementing pilot acquisitions.
The suggestions that follow are based on lessons from early pilots undertaken by the
General Services Administration and the Department of Defense in partnership with EPA. Case
studies from these and other pilot projects are available from the Pollution Prevention
Information Clearinghouse (202 260-1023) or they can be accessed through EPA's EPP Program
Web site .
Additional pilot acquisitions will be important testing grounds for applying the guiding
principles and testing their applicability. The pilots will also provide valuable information for
the development of tools and resources to facilitate widespread adoption of environmentally
preferable purchasing practices.
EPA will track pilots that are planned or already underway on the EPP Web site,
providing a clearinghouse for information on government-wide activities related to
environmentally preferable purchasing. (SeeEO 13101, Section 503 (b)(4).) EPA will
disseminate information about different pilots among the agencies through the EPP Web site,
updates, and fact sheets to ensure that lessons learned are shared and used to inform other pilot
projects.
The discussion below further describes how these pilots and demonstration projects might
proceed. EPA encourages Executive agencies to undertake pilots and use all existing sources of
information and technical expertise to carry them out. EPA is committed to supporting these
pilots and providing overall coordination and technical assistance, as resources allow.
1. Selection of pilots. Selection of pilot acquisitions is at the discretion of the individual
Executive agencies. There are at least two options for how agencies can approach this selection
process. First, an agency may want to identify an environmental problem that it wants or needs
to address. Once the problem has been identified, the agency can develop a list of products and
services that contribute to that specific environmental problem. Alternatively, an agency may
start out with a product or service category for which it wants to find alternatives. In either
case, criteria that agencies might wish to consider in selecting pilot acquisitions include:
• Potential for a reduction hi risk to human health and the environment.
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• Status on EPA's prioritized list. Pursuant to EO 13101, Section 503 (a), and in
order to assist Executive agencies focus their efforts on minimizing serious
environmental impacts, EPA has developed a prioritized list of the top 20 product
categories. The complete list, along with a discussion of the methodology used in
its development can be found in EPA's EPP Web site at
.
• Existence of less harmful product or service alternatives. Alternatives could vary
anywhere along the product or services' life cycle, for example, different ways of
manufacturing or disposing. Alternatives might also include different ways of
getting the same result, even if it means acquiring a completely different type of
product or service.
• Feasibility/degree of flexibility in the acquisition.
• Products or services that are widely used within the Federal government and are
representative or typical of the procurement system. This maximizes the pilot's
potential value to others by providing lessons about the effectiveness of the
guidance and increasing the likelihood that the pilot could be replicated. (See EO
13101, Section 503 (b)(l).)
2. Implementation of pilot projects. In implementing the pilot projects;, Executive
agencies can look to the process and results of projects others have completed or develop a
different approach for environmentally preferable purchasing. In undertaking the pilots, agencies
are encouraged to:
• Ensure the participation of environmental and procurement experts.
• Use all of the options available to them to determine the environmentally
preferable attributes of products and services in their pilot projects, including the
technical expertise of non-governmental entities. This is pursuant to EO 13101,
Section 503 (b) (2). More specific guidance on the use of non-governmental
entities is included in Appendix D.
Once a product or service has been chosen, pilots typically involve:
a) Determining environmentally preferable products and services. This can be
accomplished by Executive agencies:
• Identifying product attributes that can serve as indicators of environmental
preferability. Agencies can look to Appendix B for a menu of attributes.
Selection of attributes should be tied to the most significant environmental
problems or impacts.
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45829
b)
• Collecting information from product and service providers. This may
require the development of contract language to ensure that vendors
provide environmental information.
With the recent changes to the FAR and the trend toward best value
contracting, agencies can now more easily consider environmental factors
when making purchasing decisions. However, environmental information
is often not provided by vendors. Thus, it may be necessary for Executive
agency personnel to clearly request or require relevant environmental
information from vendors in market surveys and proposals whenever
appropriate.
• Evaluating the environmental information.
Incorporating results of the environmental information research into the
acquisition process to purchase environmentally preferable products and services.
While the acquisition strategy and method are determined by the purchasing
agency, EPA asks that agencies select a strategy that:
• Maximizes the number of environmentally preferable product or service
choices available to the purchasing agency.
• Promotes competition across products and services in terms of
environmental performance.
• Stimulates product and service process innovation and continuous
improvement.
• Allows for the consideration of local environmental conditions.
• Promotes a definition of environmentally preferable products and services
that can improve over time.
Documenting the pilot effort, including a description of how the project was
initiated and implemented and the lessons learned. A sample case study template
is attached in Appendix E and is also available on EPA's EPP Web site. The
results of pilot projects will be shared among Executive agencies through EPA's
EPP Web site.
More specific information about pilot implementation will be made available through a
variety of tools that EPA currently is developing including: an interactive training module; a
"best practices guide" with examples of specific contract language that have been used by
purchasing agencies; and a database of existing environmental standards that have been
developed by governmental and non-governmental entities.
c)
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Section 12(d) of The National Technology Transfer and Advancement Act of 1995
(NTTAA) (Pub. L. 104-113, §12(d), 15 U.S.C. 272 note) and OMB Circular A-l 19 (63 FR 8546,
February 19,1998) direct Federal agencies to use both domestic and international voluntary
consensus standards in lieu of government-unique standards in their procurement and reglilatory
activities, except where it would be inconsistent with applicable law or otherwise impractical.
The Act's purpose is to reduce the cost of procurement and regulation by requiring a Federal
agency to draw upon any suitable technical standard already used in commerce or industry rather
than inventing a new standard. Some of those standards might relate to evaluating
environmental performance and measuring the environmental attributes of products or services.
In establishing Environmental Preferable Purchasing pilot projects or planning other
environmentally-sensitive activities, agencies should first determine whether there is an
applicable voluntary consensus standard that would meet its needs.
The NTTAA also requires a Federal agency, when it is consistent with the agency's
mission, authorities, priorities, and budget resources, to participate in the standards-setting
activities of voluntary consensus standards bodies. Such participation helps ensure the
development of standards that meet the agency's needs, including those related to
Environmental Preferable Purchasing concerns. This collaboration can also promote national
goals and objectives. OMB Circular A-l 19 specifically mentions the need to promote the use of
environmentally sound and energy-efficient materials, products, systems, services, or practices as
well as the improvement of public health and safety. (See OMB A-l 19, Section 7a.)
In the long run, institutionalizing the purchase of environmentally preferable products and
services requires that Executive agencies continue their efforts after the pilot's are completed.
Given that environmental information about products and services is still scarce, agencies should
rely on all sources of information and technical expertise in making determinations about
environmental preferability. To foster agencies continue acquisition of "green" products, EPA
will coordinate the development and standardization of environmental information about
potential product and service categories for future pilots. This effort will consist of identifying
environmental performance characteristics and measurement methods and will involve technical
experts both inside and outside the Federal government. Executive agencies should examine all
information generated through these types of efforts. The agencies, and not the nongovernmental
entities, must make all final determinations regarding environmental preferability.
The experience gained from Executive agency pilots will be key in determining the
scope and nature of EPA's long-term activities to advance Federal environmentally preferable
purchasing. The lessons learned and partnerships formed from these pilots will help establish a
broader infrastructure to support this initiative. EPA might use existing mechEinisms or help
develop new resources such as guidance, networks, and databases in support of the Federal
purchasing community—to build this infrastructure. The infrastructure will help bridge the gap
between the environmental and procurement expertise within the Executive agencies.
All Executive agency personnel will have a role in creating a demand for environmentally
preferable products and services. Thus, the infrastructure will also have to support the
development of tools that are easy and convenient for general and diverse use..
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In light of the evolving acquisition landscape £ind the dynamic nature of the marketplace,
the infrastructure will have to be flexible. In the increased globalization of the economy and
trends toward commercialization of the Federal marketplace, will also require agencies to
coordinate this initiative with new international trade and standardization developments.-
Ultimately, the measure of this initiative's success will be in the increased availability and
purchase of products and services that pose fewer adverse impacts on human health and the
environment.
VI. List of Resources
This section includes a partial list of current resources that Executive agency personnel
may find useful in implementing environmentally preferable purchasing. For a more complete
and updated list, please refer to EPA's EPP Web site, described below.
A. EPA's EPP Program Web site:
This comprehensive Web site serves as the main repository of information and resources
related to environmentally preferable purchasing, including:
• Publications such as case studies, program updates and fact sheets.
• Interactive features designed to elicit information exchange such as topical
discussion forums, a listing of upcoming events, a bulletin board for posting
questions and comments and sharing users' experiences, as well as tools that have
been helpful in implementing EPP.
• A list of top twenty prioritized product and service categories selected because
they represent large volume federal procurements with environmental impacts,
along with a description of the methodology used. The list is provided to assist
Executive agencies in selecting pilots that will have the most effect.
The site will also include training modules, a collection of promising green contracting
practices, and a database of existing environmental standards, specifications and contract
language.
B. Federal Case Studies of Environmentally Preferable Purchasing
EPA has developed a number of documents that describe the results of EPP pilot projects,
including:
• "Cleaners Pilot Project Case Study " documents a collaboration between
the General Services Administration and the Environmental Protection
Agency.
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• "Paving the Road to Success " describes Department of Defense's efforts
to "green" a parking lot repair and maintenance contract
" ! !
• "Leading by Example " documents how EPA incorporated environmental
features into two new buildings, the Ronald Reagan Building and the
Research Triangle Park office complex.
• "Defending the Environment at the Department of Defense " describes the
addition of environmental factors in the maintenance of the Pentagon and
other DOD facilities.
In addition, Executive agencies have either initiated or are contemplating a number of
other pilot projects involving products such as degreasing agents, painls, adhesives and
copier paper4, and services such as conferencing. Examples of where environmental
preferability was factored into purchasing decisions can be found under "How to Do
EPP" as well as "EPP Resources" on EPA's EPP Web site.
Life Cycle-Based Resources
• Building for Environmental, and Economic Sustainability
A life cycle-based, decision-support software tool to assist users in balancing
environmental and economic concerns among products. The tool generates
relative scores for alternative products based on environmental and economic
performance weights that individual users can set. Although originally designed
for building materials and product comparisons, the tool will be expanded to
include other materials. The disks can be obtained by contacting the Pollution
Prevention Information Clearinghouse at 202 260-1023.
• Federal Facility Pollution Prevention Project Analysis: A Primer for Applying
Life Cycle and Total Cost Assessment Concepts
4 Under the Pulp and Paper Cluster Rule published in 1998, EPA's Air and Water Offices have created the
Voluntary Advanced Technology Incentives Program in order to move the industry toward the minimum environmental
impact "mill of the future." EPA also has proposed to add a procurement incentive in line with this goal in the near
fiiture. The purchase of recycled content, chlorine-free paper would be a way to advance several Administration
initiatives, including the Technology Incentives Program, President Clinton's directive to purchase paper containing
30 percent post-consumer fiber and the President's directive to agencies to purchase environmentally preferable products
and services. For those interested in EPA's views on recycling and chlorine content in copier paper, please see EPA's
^fluent Guidelines andStandardsfor Pulp, Paper, and Paperboard Category, Phasel, promulgated on April 15,1998.
(See 40 CFR Parts 63,261 & 430)
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D. Agency Environmental Catalogs
The General Services Administration (GSA) and the Defense Logistics Agency (DLA) in
the Department of Defense, the two major suppliers for the rest of the Federal • -
government, publish product catalogs that highlight some environmental attributes.
These catalogs are listed below:
• Environmental Products Guide
Published by the GSA, this guide contains a list of over 3,000 products
and services with environmental attributes, such as low volatile organic
compound content, recycled content, energy-efficiency, etc. All products
featured in the guide are available through the supply system of GSA's
Federal Supply Service. The guide is available on MUFFIN (Multi-Use
File for Interagency News).
• Environmental Products Catalog
Published by the DLA, this catalog includes products that meet the
requirements of EPA's Comprehensive Procurement Guidelines as well as
products that help reduce hazardous waste or eliminate the use of ozone-
depleting chemicals. Currently, the catalog does not have a systematic
way of screening products for their environmental characteristics, so
inclusion in the catalog does not necessarily connote an environmentally
preferable product. A DLA pilot is underway to develop environmental
standards for a category of products in the catalog. For more information,
contact the Defense General Supply Center at 1 800 352-2852.
E. Federal Trade Commission's Guides to the Use of Environmental Marketing Claims
(Green Guides), 16 C.F.R. Part 260
The Green Guides, recently revised in May 1998, are intended to reduce consumer
confusion and prevent false or misleading use of environmental terms in product
advertising and labeling. The Green Guides indicate how the Federal Trade Commission
will apply Section 5 of the Federal Trade Commission Act, which prohibits unfair or
deceptive acts or practices, in environmental marketing claims. The Green Guides apply
to all forms of product and service marketing to the public, including advertisements,
labels, package inserts, promotional materials, and electronic media. The Green Guides
can be accessed via FTC's Web site: (Select "Consumer Protection",
then select "Environment", and then select "Guides"). For hard copies, contact FTC at
202 FTC-HELP (382-4357). For questions, contact Janice Podoll Frankle at 202 326-
3022.
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F. Office of Federal Environmental Executive's Web Site —
l'
The Office of the Federal Environmental Executive (OFEE) maintains a comprehensive
Web site Updated frequently, it includes background information on OFEE's mission,
history, and staff; resources for implementing EO 13101; best practices and success
stories for environmental procurement, recycling, and waste prevention; federal agency
compliance guidance; and posts information on current and upcoming conferences,
activities, publications, and other relevant news. The site also showcases the Closing the
Circle Awards recognizing outstanding performance towards "greening" the government.
OFEE also manages an interactive forum (list serve) for the exchange; of information on
environmental purchasing, recycling, and waste prevention.
Other Resources and Tools
• "Greening" of the Federal Logistics Information System (FLIS)
The Defense Logistics Agency is working through a multi-agency group to
incorporate positive environmental attributes (such as recycled content, energy
efficiency and water efficiency) into FLIS, is a database of more than 7 million
supply items purchased by the Federal government. With the supply items tagged
with environmental attributes, FLIS will provide Federal consumers with specific
environmental information about the products they buy.
• There are a variety of other resources and tools that are currently available or
under development to assist Executive agency personnel implement
environmentally preferable purchasing practices. For the latest list of resources
and tools, please check the EPP Web site .
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45835
VII. Appendices
Appendix A Glossary of Terms
Appendix B Environmental Attributes
(1) Menu of Environmental Attributes
(2) Definitions for Terms on the Menu of Environmental Attributes
Appendix C Sample EPP Policy Directive
Appendix D Text of Office of Federal Environmental Executive and U.S. Environmental
Protection Agency's April 1998 Policy Letter on Use of Non-Governmental
Entities
Appendix E Pilot Project Case Study Template
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Appendix A—Glossary of Terms
Acquisition - means the acquiring of products and services (including construction) by contract
with appropriated funds by and for the use of the Federal government through purchase or lease,
whether the supplies or services are already hi existence or must be created, developed,
demonstrated, and evaluated. Acquisition begins at the point when agency needs are established
and includes the description of requirements to meet those needs, solicitation and selection of
sources, award of contracts, contract financing, contract performance, contract administration,
and those technical and management functions directly related to the process of fulfilling agency
needs by contract (EO 13101, Section 201)
Bio-based products - are defined as commercial or industrial products (other than food or feed)
that utilize biological products or renewable, domestic, agricultural (e.g., plant, animal and
marine), or forestry materials. (EO 13101, Section 201)
Environmentally preferable - products or services that have a lesser or reduced effect on human
health and the environment when compared with competing products or services that serve the
same purpose. The product or service comparison may consider raw materials acquisition,
production, manufacturing, packaging, distribution, reuse, operation, maintenance, or disposal.
(EO 13101, Section 201)
Life cycle assessment - means the comprehensive examination of a product's environmental and
economic aspects and potential impacts throughout its lifetime, including raw material
extraction, transportation, manufacturing, use, and disposal. (EO 13101, Section 201)
The International Standards Organization, through ISO 14040, has defined life cycle assessment
slightly differently as follows: Compilation and evaluation of the inputs, outputs, and the
potential environmental impacts of a product system throughout its life cycle.
Life cycle cost - means the amortized annual cost of a product, including capital costs,
installation costs, operating costs, maintenance costs and disposal costs discounted over the
lifetime of the product, according to OMB Circular A-94 and Executive Order 13101, Section
201. However, this definition does not include external costs (i.e., those not borne directly by the
entity that owns and operates a product/service, such as environmental costs to society at large).
For the purposes of this guidance, EPA encourages agencies to consider all internal and external
costs associated with a product, process, or activity throughout its entire life cycle—from raw
materials acquisition to manufacture, recycling and final disposal.
Non-governmental entities - within the context of this guidance, non-governmental entities
include, but are not limited to, voluntary consensus standards bodies (see§ 12(d) of the National
Technology Transfer and Advancement Act (Pub. L. 104-113, §12(d), 15 U.S.C. 272 note),
environmental standard setting organizations, third party certification programs, environmental
labeling or environmental "report card" programs and other environmental consulting
organizations.
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45837
Pollution prevention - "source reduction," as defined under the Pollution Prevention Act of 1990
(42 U.S.C. § 13102), and other practices that reduce or eliminate the creation of pollutants
through: increased efficiency in the use of raw materials, energy, water, or other resources; or
protection of natural resources by conservation..
The Pollution Prevention Act defines source reduction to mean any practice that:
• Reduces the amount of any hazardous substance, pollutant, or contaminant
entering any waste stream or otherwise released into the environment
(including fugitive emissions) prior to recycling, treatment, or disposal
• Reduces the hazards to public health and the environment associated with
the release of such substances, pollutants, or contaminants.
The term includes: equipment or technology modifications, process or procedure
modifications, reformulation or redesign of products, substitution of raw materials, and
improvements in housekeeping, maintenance, training, or inventory control.
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Appendix B—Lists of Environmental Attributes
Below is a list of environmental attributes that can help Executive agencies assess the
environmental performance of products and services. This list, viewed from, a life cycle
perspective can enable Executive agency purchasers to select the product or service that
minimizes adverse environmental impact Although, it is a preliminary list of the major sources
of potential human health and environmental risk, this source should not be considered
definitive. Definitions for each of the attributes follow the list. Agency personnel can use this
list in two ways:
(1) To provide a framework for identifying the most important environmental attributes
of products and services, and using that information in product or seivice comparisons.
(2) As a check list of environmental issues to consider when designing and acquiring
systems or buildings.
Not all of the environmental attributes will apply to each product or service; indeed, in some
cases, information on just a few key environmental attributes will enable Executive agency
personnel to determine environmental preferability.
The list of environmental attributes suggests that Federal agency personnel can use two
different approaches to soliciting information from providers of products and services. The first
includes consideration of releases of pollutants that occur during the life-cycle of the product. In
the research on product life-cycle assessments that have been conducted over the past several
years, these releases are known as "inventory" items. Alternatively, the risks (or risk surrogates)
associated with various life-cycle stages of a product can be identified. This approach seeks to
identify actual environmental impacts rather than solely environmental releases. When
calculating risks, general population (both environmental and human) exposures and
occupational exposures need to be considered. Executive agencies may consider using both risk
and release data in their decisions to purchase environmentally preferable products and services.
If product and service providers use this list as a basis for making environmental
marketing claims, the claims should conform to the FTC's Guides for the Use of Environmental
Marketing Claims (Green Guides), 16 C.F.R. Part 260). A copy of the Green Guides can be
obtained through FTC's Web site . Any party making a claim (or an independent
third party that is certifying a claim) concerning a product's environment attribute must, at the
time the claim is made, possess and rely upon a reasonable basis for substantiating the claim (16
C.F.R.§ 260.5). A reasonable basis consists of competent and reliable evidence. In the context
of environmental marketing claims, such substantiation will often require competent and reliable
scientific evidence, defined as tests, analyses, research, studies, or other evidence based on the
expertise of professionals in the relevant area, conducted and evaluated in an objective manner
by persons qualified to do so, using procedures generally accepted in the profession to yield
accurate and reliable results.
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45839
The Green Guides state that either an unqualified or inadequately qualified claim that a
product is "environmentally preferable" implies to consumers that a product is generally
environmentally superior to others. "Environmentally preferable" claims should be accompanied
by language limiting the superiority claim to the particular attributes that can be substantiated.
For example, Green Guides state that environmental seals-of-approval should be accompanied by
information on product labels explaining the basis for the award.
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Appendix B(l) — Menu of Environmental Attributes
Executive agency personnel are reminded that the attributes listed and defined below are
not comprehensive. In addition, Executive agency personnel should note that notall of
these attributes will be applicable to every product or service. Furthermore, different
attributes may be applicable to each product or service life cycle stage being considered.
A. Natural Resources Use
• Ecosystem impacts, such as endangered species, wetlands loss, fragile
ecosystems, erosion, animal welfare, etc.
• Energy consumption, which can serve as an indicator of acid rain, climate
change potential, air pollution, and associated human health risks.
i i
• Water consumption which can serve as an indicator of water quality impacts,
risks to aquatic ecosystems, and degradation of drinking water resources.
• Non-renewable resource consumption, which can serve as an indicator of acid
• rain, climate change potential, air pollution, and associated human health risks
and risks to endangered species and fragile ecosystems.
• Renewable resource consumption, which can serve as an indicator of loss of
biodiversity and increased erosion. Although in many cases; the use of renewable
resources is considered environmentally preferable to use of nonrenewable
resources, products made from renewable resources may also have negative
environmental impacts (e.g., ethanol is derived from a renewable resource, yet its
manufacture can lead to releases of VOCs).
B. Human Health and Ecological Stressors
• Bioaccumulative pollutants.
• Ozone depleting chemical global warming gases.
• Chemical releases (Toxics Release Inventory (TRI) list chemicals or others.)
• Ambient air releases (other than TRI, including volatile organic compounds and
particular matter).
i
• Indoor environmental releases (consumer and occupational).
• Conventional pollutants released to water.
• Hazardous waste.
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Non-hazardous solid waste (e.g., municipal solid waste, large volume waste,
surface impoundments). '
Other stressors.
C. Hazard Factors Associated With Materials
• Human Health Hazards:
— acute toxicity
— carcinogenicity
— developmental/reproductive toxicity
— immunotoxicity
— irritancy .;
— neurotoxicity
— sensitization
— corrosivity
— flammability
— reactivity
— other chronic toxicity
• Ecological Hazards:
— aquatic toxicity
— avian toxicity
— terrestrial species toxicity
D. Positive Attributes
The attributes listed below are viewed as positive because they either serve as proxies for
minimizing natural resource use or avoiding waste and the associated environmental impacts
identified in A, B, and C. These attributes also are linked to authorities and requirements in
statutes or executive orders that encourage the Federal government to promote their use.
"Recyclability" and "recycled content" are attributes encouraged under RCRA. There are
executive orders that encourage Federal agencies acquire bio-based products, and to promote
energy efficiency and water conservation. "Durability", "reusability", "take-back", and
"reconditioned or remanufactured" are positive attributes that encourage source reduction.
"Product disassembly potential" increases the potential for source reduction and recycling of
product components. Agencies should note that the presence of these attributes alone does not
automatically make a product or service environmentally preferable. When making purchasing
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decisions, executive agencies should consider a range of environmental impacts associated with
products from a life cycle perspective when making purchasing decisions.
Recycled content
Recyclabiliry
Product disassembly potential
Durability
Reusability
Reconditioned or remanufactured
Take-back
Bio-based
Energy efficiency
Water efficiency
Other attributes with positive environmental effects
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Appendix B(2)—Definitions for Terms on the List of Environmental Attributes
A. Natural Resource Use
(1) Ecosystem impacts- adverse impacts on the ecosystem, for example, endangered species,
wetlands loss, fragile ecosystems, erosion.
(2) Energy consumption- the total amount of energy consumed for product or service
manufacture, use, and disposal. Different sources of energy are associated with different
environmental impacts.
(3) Water consumption- refers to the water resources that are consumed or used, which can
serve as an indicator of water quality impacts, risks to aquatic ecosystems, and degradation of
drinking water resources.
(4) Non-renewable resource consumption- those resources consumed that are not renewable
in 200 years (e.g., fossil fuels, minerals). This can serve as an indicator of acid rain, climate
change potential, air pollution, and associated human health risks and risks to endangered species
and fragile ecosystems.
(5) Renewable resource consumption: refers to a continuum of resources, from those that are
renewable in under 200 years, such as timber-based products, which can serve as an indicator of
biodiversity loss and increased erosion, to those which axe renewable in less than 2 years, such as
grain-based feed stocks.
B. Human Health and Ecological Stressors
(1) Bioaccumulative pollutants- those chemicals that bioconcentrate in the environment as
described in the Significant New Use Rule for new chemicals. (40 CFR 721.3.)
(2) Ozone depleting chemicals- defined in the Protection of Stratospheric Ozone Final Rule.
(58 FR 65018, December 10,1993.)
(3) Global warming gases- listed in Climate Change 1992, The Scientific Report on the
IPCC Scientific Assessment. (Table A 2.1.)
(4) Chemical releases- ambient releases of chemicals of concern such as those reported in the
TRI of the Emergency Planning and Community Right-to-Knpw Act. The current list is reported
in 40 CFR 372.65.
(5) Ambient air pollutants- pollutants for which ambient air quality standards have been
developed. (40 CFR 50.4- 50.12.) These pollutants include nitrogen dioxide, sulfur dioxide,
ozone precursors, paniculate matter, carbon monoxide, Jind lead.
(6) Indoor environmental releases- releases to an indoor environment of potentially
hazardous chemicals such as those reported in the TRI in both occupational and consumer
settings.
(7) Conventional pollutants- defined in 40 CFR 401.16. These pollutants include
biochemical oxygen demand, total suspended solids, fecal coliform, pH, and oil and grease.
(8) Hazardous waste- Quantity of Resource Conservation and Recovery Act (RCRA)
hazardous waste as defined in 40 CFR 261.3.
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(9) Non-hazardous waste- solid waste as defined in 40 CFR 261.3. Includes municipal solid
waste, large volume waste (e.g., oil and gas, mining, etc.) and solids disposed of in surface
impoundments.
(10) Other stressors- any other stressors associated with the product or service but net-
captured elsewhere.
C. Factors Associated With Materials
Human Health Hazards
(1) Acute toxicity- the potential of a chemical substance to cause adverse health effects
from short-term exposure.
(2) Carcinogenicity- defined by EPA through a weight-of-evidence approach. (51 FR
33992, September 24,1986 and 61 FR 17960, April 23,1996.) When quantification is possible,
slope factors or other measures such as LED10 can also be used to express carcinogenic potency.
(3) Development/reproductive toxicity- adverse effects on the developing organism
that result from chemical exposure prior to conception (i.e., either parent), during prenatal
development, or, postnatally, to the time of sexual maturation. (56 FR 63798, December 5,
1991.) Reproductive toxicity is any adverse effect on an organism's ability to reproduce. (61 FR
56274, October 31,1996.)
(4) Immunotoxicity- any adverse effect on an organism's immune system that results
from exposure to a chemical substance.
(5) Irritancy- defined according to the Occupational Safety and Health Administration
(OSHA) Hazard Communication Standard (29 CFR part 1910.1200) or other standard scales
such as EPA or Organization for Economic Cooperation and Development (OECD) Guidelines
(EPA 712-C-98-196, August, 1998.)
(6) Neurotoxicity- any adverse change in the development, structure, or function of the
central and peripheral nervous system following exposure to a chemical agent (59 FR 42272,
August 17,1994.)
(7) Sensitization- an immunologically mediated cutaneous reaction to a substance. EPA
test methods for evaluating sensitization potential are found in 40 CFR part 798.4100.
(8) Other chronic toxicity- the potential of a chemical substance to cause an adverse
effect on any organ or system following absorption and distribution to a site distant from the
toxicant's entry point
( 9) Corrosiviry- dermal corrosion is defined by EPA as the production of irreversible
tissue damage in the skin following application of a test substance. Test methods for evaluating
dermal corrosipri can be found in the harmonized Office of Prevention, Pesticide and Toxic
Substances (OPPTS) guidelines for acute dermal irritation. (OPPTS 870.2500.) These guidelines
harmonize the TSCA, FIFRA and OECD requirements in this area. The OSHA HazCom
Standard listed above for irritancy also explicitly or implicitly covers coirosivity, sensitization,
neurotoxicity, and all other toxic endpoints.
(10) Flammability- defined by the OSHA HazCom Standard (29 CFR 1910.1200) and
ignitability is defined in 40 CFR part 261.21.
(11) Reactivity-defined in 40 CFR 261.23.
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Ecological Hazards
(1) Aquatic toxicity- the potential of a substance to have an adverse effect on aquatic
species. Measurement methods for aquatic toxicity can be found in 40 CFR part 797, subpart B.
(2) Avian toxicity- the potential of a substance to have an adverse effect on avian
species.
(3) Terrestrial species toxicity- the potential of a substance to have an adverse effect on
terrestrial species, other than man.
D. Positive Attributes
The following attributes are generally viewed as positive because they either serve as
proxies for minimizing natural resource use or avoiding waste and the associated environmental
impacts identified in A, B and C. Agencies should note that the presence of these attributes
alone do not automatically make a product or service environmentally preferable. Executive
agencies should consider a range of environmental impacts associated with products from a life
cycle perspective when making purchasing decisions.
(1) Recycled content: Materials that have been recovered from the solid waste stream,
either during the manufacturing process (pre-consumer), or after consumer use (post-consumer)
(see Federal Trade Commission Environmental Marketing Guides mentioned above for more
detail). Executive agencies are required to purchase EPA-designated items with recycled content
(40 C.F.R. Part 247). Purchasers may want to consider whether the material contains pre-
consumer or post-consumer recycled content. Recycled content, under the Federal Trade
Commission guides, includes recycled raw material, that would have otherwise been incinerated
or land filled, as well as used, reconditioned and remanufactured components. For products that
are only partially made of recycled material, a recycled claim should indicate the percentage, by
weight, of recycled content in the finished product. Unless it is otherwise clear from the context
of the sale, for products that contain used, reconditioned or remanufactured components, a
recycled claim should make clear that such components are used, reconditioned or
remanufactured. Manufacturer's scrap material that would have, in any case, been incorporated
into the product does not qualify as recycled under the Federal Trade Commission's guides.
Refer to 16 C.F.R. § 260.7(e).
(2) Readability: Refers to products or materials that can be collected, separated or
otherwise recovered from the solid waste stream for reuse, or in the manufacture or assembly of
another package or product, through an established recycling program. For products that are
made of both recyclable and non-recyclable components:, the recyclable claim should be
adequately qualified to avoid consumer deception about which portions or components are
recyclable. In addition, unless recycling collection programs for the product are available to a
substantial majority of communities or consumers when: the product is sold, claims of
recyclability need to be qualified to indicate the limited of availability of recycling collection
sites. A product that is made from recyclable material, but, due to its shape, size or some other
attribute, is not accepted in recycling programs for such material, should not be marketed as
recyclable. Refer to the FTC Environmental Marketing Guides, 16 C.F.R. § 260.7(d).
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(3) Product disassembly potential: Refers to the ease with which a product can be
disassembled for maintenance, parts replacement, or recycling.
(4) Durability: Refers to the expected lifetime of the product.
(5) Reusability: Refers to how many times a product may be reused. Since reusable
products generally require more up-front costs than disposable products, they are often subjected
to a cost/benefit analysis in order to determine the life cycle cost.
(6) Reconditioned/Remanufactured: Refers to the process of restoring used, durable
products to meet original performance standards. Remanufacturing has many other names,
including: rebuilding (automotive sector); retreading (tire remanufacturing); reconditioning; and
refurbishing. Remanufacturing results in less waste and raw material and energy use.
(7) Take-back: Refers to the manufacturer or designee accepting a return of end-of-life
product; who pays for the transportation of the product may be situation-specific.
(8) Bio-based: Refers to a commercial or industrial product (other tfian food or feed) that
utilizes biological products or renewable, domestic, agricultural (plant, animal and marine), or
forestry materials.
(9) Energy efficiency: Refers to products that meet or exceed the Department of Energy
(DOE)/Federal Energy Management Program's product energy efficiency recommendations
which identify the top 25 percent of energy efficiency for all similar products or that meet the
energy efficiency criteria of the Environmental Protection Agency (EPA)/DOE Energy Star
program. •
(10) Water efficiency: Refers to any plumbing fixtures that meet or exceed the
Department of Energy's Federal Energy Management Program recommended performance
standards for flow rates.
(11) Other attributes: Refers to any other positive attributes that are associated with the
product but are not listed here.
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Appendix C—-Sample Environmentally Preferable Purchasing Policy Directive
Environmentally Preferable Purchasing Policy
The purchase and use of products and services can have a profound impact on the
environment. [NAME OF DEPARTMENT OR AGENCY] recognizes the positive impact that
it can make on the environment through the purchasing decisions that its employees make. It
is the intent of [NAME OF DEPARTMENT OR AGENCY] to integrate environmental
considerations into every aspect of acquisition. Although the environment may not be the core
of our professional mission, the integration of these factors will result in economic, health, and
environmental gains that will further our goals.
Overall Statement of Policy
• Agency personnel should seek to reduce the environmental damages associated
with their purchases by increasing their acquisition of environmentallypreferable
products and services to the extent feasible, consistent with price, performance,
availability, and safety considerations.
• Environmental factors should be taken into account as early as possible in the
acquisition planning and decision-making process.
• Responsibility for environmentally preferable purchasing should be shared
among the program, acquisition, and procurement personnel.
• Environmentally preferable purchasing represents one important component of
this agency's commitment to pollution prevention.
[NAME OF DEPARTMENT OR AGENCY] is committed to the following:
• Increasing the acquisition of environmentally preferable products and services.
• Identifying and implementing pilot projects to test the best ways to incorporate
environmental preferability into acquisition.
• Establishing incentive and award programis to recognize those people, teams, and
interagency work groups who are most successful at promoting the purchase of
environmentally preferable products.
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Appendix D—Text of Office of Federal Environmental Executive and tf.S. Environmental
Protection Agency's April 1998 Policy Letter on Use of Non-Governmental Entities
Pilot Project Approach on Use of Non-Governmental Entities
to Implement Section 503 of Executive Order 12873 on
Federal Acquisition, Recycling, and Waste Prevention
Background:
Section 503(a) of Executive Order 12873 directs EPA to "issue guidance that
recommends principles that Executive agencies should use in making determinations for the
preference and purchase of environmentally preferable products." Section 503 (b) states that
Executive agencies shall use EPA's guidance to "identify and purchase environmentally
preferable products" and to "modify their procurement programs by reviewing and revising
specifications, solicitation procedures, and policies as appropriate."
On September 28,1995, EPA issued a proposed Guidance on the Acquisition of
Environmentally Preferable Products and Services which includes a series of principles that are
intended to guide Federal purchasers as they consider environmental preferability in their
acquisition decisions. This proposed Guidance was the culmination of numerous discussions
EPA had with staff from key purchasing agencies and departments as well as representatives
from industry and environmental and other interested organizations.
In EPA's proposed Guidance (Supplementary Information - Section HI (E)), EPA
acknowledged the existence of non-governmental entities — including, but not limited to,
environmental standard setting organizations, third party certification programs, environmental
labeling or environmentaT"report card" programs and other environmental consulting
organizations ~ to which Executive agencies, in appropriate circumstances, may refer for
technical assistance1 in meeting the Executive Order goals.
1 For example, Executive agencies might seek technical assistance from non-governmental entities to help
Executive agencies:
(a) analyze life cycle and multiple environmental attributes;
(b) analyze basic environmental performance characteristics for specific categories; of products/services;
(c) identify environmentally preferable product/service criteria for a given product category based on
agencies' core environmental values; and
(d) identify products/services in a given category which meet agencies' predetermined set of environmental
performance criteria.
Executive agencies are reminded that they must critically examine all information from non-governmental
entities. The Executive agencies involved, and not the non-governmental entities, must make all final
determinations regarding environmental preferability.
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In this paper, EPA suggests a pilot project approach to test the utility of various means of
using non-governmental entities to achieve environmentally preferable purchasing goals. This
pilot project approach will be publicized through a Notice of Availability in the Federal Register.
Ultimately the findings from the pilot project approach will provide practical information to EPA
in the development of its final Guidance.
Spectrum of Approaches
First, it must be emphasized that Executive agencies may choose to implement EPA's
proposed Guidance without technical assistance from non-governmental entities. A number of
on-going environmentally preferable purchasing (EPP) pilot projects are relying successfully on
the in-house environmental and procurement expertise of EPA and the partnering Executive
agency (e.g., General Services Administration and the Department of Defense). Therefore, this
paper should in no way be interpreted as an EPA endorsement of a specific
non-governmental entity, organization or program, nor should agencies feel obligated in
any way to utilize the technical assistance of such entities.
However, to the extent that the Agencies are interested in tapping the expertise that
resides outside the Government, EPA concludes that Agencies, in carrying out existing mandates
for environmentally preferable purchasing may use non-governmental entities in accordance with
appropriate operating guidelines. Executive agencies should note that they must avoid favoring,
without reasonable justification, one non-governmental entity over another. Executive agencies
should also inform their personnel about the Federal Trade Commission's Guides for the Use of
Environmental Marketing Claims which govern environmental claims made by anyone,
including manufacturers or environmental labeling or "report card" programs.
Thus far, EPA has identified a number of different potential approaches for how
Executive agencies could use the technical expertise of non-governmental entities in furthering
then- environmentally preferable purchasing goals. All of the potential approaches described
below require that the Executive agencies involved critically examine all information from
non-governmental entities. The Executive agencies involved, and not the non-governmental
entities, must make all final determinations regarding environmental preferability.
This list of approaches is not comprehensive. Agencies are encouraged to bring to EPA's
attention other potential approaches for using non-governmental entities. In utilizing an
approach, agencies have considerable discretion in incorporating environmental preferability into
procurement decisions. For example, environmental considerations that result in limiting
competition or in the payment of a price premium for goods or services may be reasonably
related to an agency's definition of its "minimum needs" and therefore permissible.
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Approach I: Use of Existing Information Developed by Non-governmental Entities
i i
Executive agencies' personnel could use existing information developed by
non-governmental entities regarding environmental preferability of products and services, along
with other available information (such as product performance and price) in defining the
requirements for procurements and making more informed procurement and acquisition
decisions. For example, Agencies might consider undertaking pilot project;; to test the utility, of
non-governmental entities in the following instances:
a) Executive agencies could examine and evaluate already existing environmental criteria
or standards developed by non-governmental entities for products or product categories
(as well as for services or service categories), along with other available information, to
identify a range of environmental attributes which can inform the agencies' own
determinations of environmental preferability. Those determinations of environmental
preferability could then translate into agency requirements, or at the very least, important
criteria in the evaluation and selection of competing vendors or manufacturers.
b) In buying commercial items off-the-shelf, Executive agencies could inform their
personnel to take into consideration environmental information (e.g., environmental
claims, product profiles, "report cards", or environmental seals along with accompanying
explanation, etc.,) either displayed on the products or provided through product literature
or other materials (e.g., newsletters) in making purchasing decisions. This environmental
information could be provided by vendors or manufacturers or by non-governmental
entities. Executive agency personnel should be cautioned to avoid making their
purchasing decisions on broad claims of environmental superiority.2
c) At the request of vendors or manufacturers, an Executive agency could include in its
catalogs or schedules symbols from non-governmental entities denoting certain
environmental characteristics, provided that (1) these symbols are accompanied by
additional information that specify the reasons why a product has been "tagged" with a
point:
2The following excerpt from FTC's Guides for the Use of Environmental Marketing Claims illustrates this
A product is advertised as "environmentally preferable." This claim is likely to convey to consumers that this
product is environmentally superior to other products. If the manufacturer cannot substantiate this broad
claim, the claim would be deceptive. The claim would not be deceptive if it were (accompanied by clear and
prominent qualify ing language limiting the environmental superiority representation to the particular product
attribute or attributes for which it could be substantiated, provided that no other deceptive implications were
created by the context. (From FTC's Guides, (a) General Environmental Benefit Claims, Example 6)
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45851
symbol; (2) the catalogs or schedules clearly emphasize that Executive agency personnel
are not required to purchase products or services that are tagged; and (3) procurement
officials should not rely on the symbols to make purchasing decisions, but instead, are
required to take into account the environmental information underlying the symbol for
relevance to the procurement.3 Agencies including such symbols in their schedules or
catalogs should ensure that their employees receive appropriate guidance in utilizing this
approach. Vendors or manufacturers who choose not to obtain a seal or other symbols
denoting certain environmental characteristics from non-governmental entities may
nevertheless also request that environmental infoimation about their products be included
in the agency's catalogs or schedules.
This option will be piloted on a limited basis so mat it can be closely monitored to
determine its effectiveness.
d) On its own initiative, an Executive agency could tag products or services in its catalogs
or schedules with its own symbol which denotes environmental characteristics that the
Executive agency, through its own determination, deems preferable. This symbol could
be based on existing information (e.g., environmental claims, product profiles, "report
cards", or environmental seals along with accompanying explanation, etc.) available from
non-governmental entities or from vendors or manufacturers themselves. This symbol
should be accompanied by specific information explaining the basis for "tagging" a
product as well as the source of the information. Catalogs or schedules should emphasize
that Executive agency personnel would not be required to purchase products or services
which are tagged, but are requested to take into account the environmental information
underlying the symbol for relevance to the procurement.
Approach 2: Use of Non-governmental Entities as Certijiers of Specific Claims
Executive agencies could require vendors or manufacturers to have specific, measurable
and verifiable claims certified by qualified non-governmental entities. A product's percentage
content of volatile organic compounds (VOCs), for example, would be considered measurable
3The following excerpt from FTC's Guides for the Use of Environmental Marketing Claims provides an
example of this point:
A product label contains an environmental seal, either in the form of a globe icon, or a globe icon -with
only the text "Earth Smart" around it. Either label is likely to convey to consumers that the product is
environmentally superior to other products. If the manufacturer cannot substantiate this broad claim, the
claim would be deceptive. The claims would not be deceptive if they were accompanied by clear and
prominent qualifying language limiting the environmental superiority representation to the particular
product attribute or attributes for which they could be substantiated, provided that no other deceptive
implications were created by the context. (From FTC's Guides, (a) General Environmental Benefit Claims,
Example 5)
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and verifiable. The rationale behind this approach is that credible certification by
non-governmental entities (or actual evidence from vendors or manufacturers themselves) could
increase the credibility of claims that may be displayed on products. Such certification, or a
vendor's or a manufacturer's ability otherwise to prove particular claims of environmental
preferabiliry, could be a prerequisite for competitive consideration.
This approach assumes that (1) no particular non-governmental entity is favored (without
reasonable justification) over any other non-governmental entity; and (2) vendors or
manufacturers who choose not to be certified by non-governmental entities are provided the
opportunity to present credible evidence that -their products or services conform to established
standards.
Approach 3: Use of Non-government Entities as "Consultants" under Advisory and
Assistance Contracts
Pursuant to the competitive contracting process as set forth in the Federal Acquisition
Regulation (FAR), non-governmental entities could provide consulting services to Executive
agencies. Non-governmental entities may provide advice and recommendeitions about
environmentally preferable purchasing, for example, through the identification of key
environmental characteristics of product categories. Under this approach, Executive agencies
would define environmental preferability'with the assistance of a non-governmental entity on a
procurement-by-procurement basis. As per FAR Subpart 9.5, Executive agencies must fully
consider the potential for conflict of interest concerns where a non-governmental entity may be
unable to render impartial advice or assistance because of private business or financial interests.
Also, Executive agencies should make every effort to maximize competition in awarding these
advisory and assistance contracts to avoid any exclusive or preferential relationship with any
particular non-governmental entity. Finally, the environmental preferability standards developed
under this approach could be used as a basis for defining the agency's "minimum needs" in
particular procurements and for developing criteria for evaluating competing vendors.
EPA's Suggested Next Steps
One of the key tenets of EPA's proposed Guidance is to have Executive agencies
undertake a series of pilot projects that can demonstrate the applicability and workability of the
guiding principles as contained in EPA's proposed Guidance. The success of our efforts
depends on learning from these pilot projects and sharing the results widely among the different
Executive agencies. It is in this spirit that EPA strongly encourages Executive agencies to enter
into pilot projects that test the potential approaches for using non-governmental entities as
described above.
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Moving forward with this non-governmental entities pilot approach is desirable for a
number of reasons: 1) EPA can capture the lessons from the pilots and share them among the
Executive agencies so that there is no duplication of effort; 2) we can determine where the use of
expertise outside of the government is appropriate and useful and where it is not; and 3>the net
effect of creating a market for such EPP services may encourage increased competition among
existing and new organizations or programs that can supjport Federal procurement of
environmentally preferable products and services. Ultimately, the results from this and other
pilot project approaches will help Executive agencies identify the most effective and practical
ways to achieve the goals of environmentally preferable purchasing.
EPA recognizes that any pilot project involving a non-governmental entity will initially
raise practical questions such as which non-governmental entities are legitimate and are credible
and which are not; is there a need to certify a certifier? 'While EPA is not currently able to offer
an "approved" list of non-governmental programs best suited to assist the agencies, it is prepared
to provide assistance to Executive agencies on an individual procurement-by-procurement basis.
As an initial step, Agencies are directed to the list of questions for evaluating non-governmental
entities contained in Section III, [E] Third Party Certification Programs of EPA's proposed
Guidance on the Acquisition of Environmentally Preferable Products and Services. The list of
questions is included as Appendix 1 of this letter.
Specifically, within the context of this non-governumental entity pilot project approach,
EPA's Environmentally Preferable Purchasing Program in the Office of Pollution Prevention and
Toxics, is prepared to:
1) assist Executive agencies in structuring a pilot project involving non-governmental
entities, including providing support to assess the utility of non-governmental entities on
an individual procurement-by-procurement basis;
2) seek out and identify non-governmental entities who have expertise in the area of
environmentally preferable purchasing through a variety of means, such as, but not
limited to, Federal Register notices or announcements in the Commerce Business Daily
(CBD). To make such a task manageable, EPA will identify, with help and guidance
from the agencies, a few product or service categories upon which to focus at first. If
successful, further federal register notices or CBD announcements could be issued
focusing on additional product or service categories;
3) assemble a list of product categories for which eco-labeling criteria and standards have
been established, bom domestically and internationally ;for agencies to consider in
developing their own criteria for environmental preferability. If appropriate, EPA will
assist in such evaluations; and
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Federal Register / Vol. 64, No. 161 / Friday, August 20, 1999 / Notices
4) assist Executive agencies in structuring an environmentally preferable purchasing pilot
project that does not involve non-governmental entities.
In turn, Executive agencies should consult with EPA when undertaking pilots which may
raise environmental issues beyond their expertise (e.g., where a pilot involves consideration of
the way a product is made).
' i
Furthermore, Executive agencies who choose to undertake pilots under option l(c) should
consult with EPA in developing a written process or procedure for the role seals or symbols and
the associated information would play in their pilots. For example, agencies should provide clear
guidance which specifies the importance of considering the underlying criteria, not the seal or the
symbol.
As EPA and Executive agencies embark on these activities, EPA will continue to explore
a number pf different ways that it can address issues which are raised within the pilot project
context more definitively. Executive agencies will be kept informed of developments on these
issues. Agencies should inform EPA of their efforts in environmentally preferable purchasing,
whether such efforts involve non-governmental entities or not in order to share lessons learned
among other agencies and to aid in the evaluation of the pilot projects. In this way, EPA can
make EPP concepts more practical for use within the Federal acquisition context. To facilitate
this. Agencies are requested to send the attached FAX BACK form. Pilot projects involving
non-governmental entities will be evaluated over a period of the next three years. EPA will use
the findings from that evaluation to inform the development of its final Guidance.
For further information and to inform EPA of pilot project efforts, please contact:
Eun-Sook Goidel, Program Manager, Environmentally Preferable Purchasing Program,
Pollution Prevention Division, Office of Pollution Prevention and Toxics (202)260-3296;
(202)260-0178 FAX; e-mail: goidel.eunsook@epamail.epa.gov
For legal issues associated with use of non-governmental entities in environmentally
preferable purchasing, please contact:
Tali Zemel, Esq., Office of General Counsel (202)564-4708; e-mail:
Zemel.Avital@epamail.epa.gov
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45855
Attachment 1. List of Questions for Evaluating Non-Governmental Entities4
Executive agencies should consider the following list of questions in evaluating non-
governmental entities before using their expertise to further internal environmental preferable
purchasing goals. Does the program have:
an open, public process that involves key stakeholders (businesses,
environmental, consumer groups, and states, etc.) in developing its criteria or
standards?
award criteria, assumptions, methods, and data used to evaluate the product or
product categories that are transparent (i.e., they are publicly available, easily
accessed, and understandable to the lay person)?
a system of data verification and data quality?
a peer review process (with representation of all stakeholders) for developing the
standards or criteria? ;
criteria that are developed based on a "systems" or life cycle approach (i.e.,
"cradle to grave")?
an outreach program to educate the consumer, which includes clear
communications to consumers that provide key information concerning
environmental impacts associated with the product?
an established goal of updating standards or criteria as technology and scientific
knowledge advance?
authority to inspect the certified product's facility to ensure compliance with the
standards or criteria?
testing protocols for the certified products that ensure testing is conducted by a
credible institution?
access to obtaining the seal by small-and medium-sized companies (e.g., the cost
of the seal is not so high as to prevent access by smaller companies)?
compliance with the Federal Trade Commission's (FTC) Guides for the Use of
Environmental Marketing Claims'!
Services.
Excerpted from EPA's proposed Guidance on the Acquisition of Environmentally Preferable Products and
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Federal Register / Vol. 64, No. 161 / Friday, August 20, 1999 / Notices
FAX BACK FORM
PLEASE INFORM EPA ABOUT YOUR PILOT PROJECT INVOLVING THE USE OF
NON-GOVERNMENTAL ENTITIES IN
ENVIRONMENTALLY PREFERABLE PURCHASING!
Name: • •
Department/Agency:
Address:
Address:
Phone:
FAX
E-mail:
Type of Acquisition/Procurement:
(e.g., small purchase, credit card purchase, competitive bid, etc.)
Product/Service Category:
Name of Non-Governmental Entity:
Type of Non-Governmental Entity (check all that apply):
environmental standard setting organizations
third-party environmental certification programs
environmental labeling organizations
environmental report card organization
environmental consultants
other (please specify:
J
Type of Information/Assistance Sought from Non-Governmental Entity:
general environmental information about a product/service category;
analyze life cycle and multiple environmental attributes
analyze basic environmental performance characteristics for specific categories of products/services
identify environmentally preferable product/service criteria for a given product category based on
agencies' core environmental values
identify products/services in a given category that meet agencies' predetermined set of environmental
performance criteria; and
other (please speciry:__ )
Please FAX BACK to: Eun-Sook Goidel at U.S. EPA 202 260-0178.
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Appendix E — EPP Case Study Template
Project Basics
What does your agency/department/office do? Where is it based?
What, if anything, is unique about your efforts to purchase environmentally
preferable products and services?
What were the motivating factors behind the project?
What kinds of products and services are you purchasing with environmental
attributes in mind? Do you focus on a particular group of products or services? If
so, why?
Implementation
How have you incorporated environmental attributes into the purchasing process?
Did you alter the established procurement: process in any way to accommodate
environmentally preferable products?
What obstacles did you encounter (if any) in incorporating environmental
attributes into the purchasing process? How were these obstacles dealt with?
Did you incorporate environmental attributes into procurement specifications,
standards, or policies; requests for proposals; bid announcements; manufacturer
certifications; etc.? (If so, please provide examples.)
Product and Service Evaluation
How do you evaluate the products or services you purchase that have
environmental attributes? Do you rely solely on information provided by vendors,
or have you developed your own criteria or your own evaluation system?
Do you consider more than one attribute when evaluating a certain product (e.g.,
considering both recycled-content and bleaching when purchasing paper
products)? If so, how do you go about taking multiple attributes into
consideration?
Are products or services that meet your environmental attributes priced
competitively with other comparable products or services? Do you have a price
preference for products or services meeting your environmental criteria?
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Federal Register / Vol. 64, No. 161 / Friday, August 20, 1999 > Notices
Vendor Reactions
How do you inform vendors about your preference for products with
environmental attributes?
Were vendors already providing environmental information before you requested
it?
How did vendors react to your request for environmental attributes of their
products?
Customer (End-User) Reactions
•i I
Who has been most affected by the changes brought about by your efforts to
purchase environmentally preferable products (i.e., procurement staff, other
employees, contractors, citizens, end-users)? How have they been affected?
Have you attempted to inform or educate your customers about products'
environmental attributes? How?
How have customers responded to the environmental information you provided?
Are you keeping track of their responses?
Have customers been pleased with the performance of environmentally preferable
products (especially when compared to products that are not considered
environmentally preferable)?
Project Results
How are you tracking/measuring the success of your Environmental Preferable
Purchasing efforts? Have you been able to quantify your success in terms of
positive effects on the environment?
Have any cost savings resulted from the purchase of environmentally preferable
products? How were these calculated?
Do you think your experience with purchasing environmentally preferable
products could be valuable to others who purchase different products?
What are your future plans regarding the purchase of environmentally preferable
products? Do you expect to incorporate additional attributes! or examine other
product categories? What are some of the opportunities and challenges you
foresee in expanding your Environmental Preferable Purchasing efforts?
List of Subjects
Environmental protection.
Dated: August 13, 1999.
Carol M. Browner,
Administrator.
[FR Doc. 99-21664 Filed 8-19-99: 8:45 am]
BILLING CODE 6560-SO-C
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