Green Seal, a third-party
certifier of green products and services, says increased
concerns about the impact of chemicals on health, particularly
children’s health, and the environment are what led to the
recent revision of GS-37, its standard for institutional
cleaning products.
Green Seal’s defense comes in
the wake of the Carpet and Rug Institute (CRI) announcing it
will no longer recognize GreenSeal’s GS-37 standard as a “green”
certification for its Seal of Approval Carpet-Cleaning
Solutions.
In the final analysis, Green
Seal says the success of the revision of GS-37 will be measured
by the extent to which it changes the landscape of cleaning
products.
“We trust that government
agencies that are charged with protecting the health of their
citizens will choose to support a standard that protects the
health of children and other vulnerable populations,” says Dr.
Arthur Weissman, president and CEO of Green Seal. He anticipates
“that many progressive manufacturers will see the benefit of
conforming to a leadership standard that promotes more
sustainable cleaning products that will ensure a healthier,
cleaner environment for all.”
Green Seal first published the
standard for institutional cleaning products on Oct. 2, 2000,
and says GS-37 has become the single most-referenced
environmental standard in the cleaning industry. But CRI
President Werner Braun said, “GS-37 is flawed, and CRI cannot
support it.”
According to CRI, Green Seal
failed to follow its own written guidelines for consensus
standard setting, specifically in the areas of stakeholder input
and risk assessment.
Prior to its decision, CRI had
accepted GS-37 as a component for its Seal of Approval Green
designation, which identifies spot cleaners, pre-sprays, and
in-tank cleaning solutions that are environmentally responsible
as well as effective.
CRI cited several reasons for
withdrawing its support of GS-37:
• GS-37 measures product
efficacy against a ‘nationally recognized’ product rather than
against an approved standard. GreenSeal did not allow the
participation of all stakeholders in the development process for
GS-37;
• GS-37 arbitrarily bans
chemicals according to a list, without regard for proper risk
assessment, a practice that runs contrary to accepted scientific
practices;
• At various points, it seemed
that peer reviewed scientific data was discounted in favor of
preconceived bias on the part of the standard developers;
• GS-37 was released without a
second ratifying ballot, even after a first ballot failed to
achieve a majority.
Green Seal says its guidelines
are clear. It says the process strictly followed the ISO 14024
standard. These guiding principles for environmental labels are
different from ANSI guidelines in that they require that
reasonable efforts be made to achieve consensus but do not
require that all stakeholders vote the same way.
Noting that Green Seal is
accredited by the American National Standards Institute (ANSI)
as a standard-setting body, Braun said he would expect the
company to follow the ANSI process of standard development.
He added that CRI would
reconsider its decision if Green Seal were to “reopen the GS-37
standard and develop it in an environment that respects the
consensus standard-setting process.”
While Green Seal standards
have achieved 100 percent consensus in the past, the votes for
GS-37 were split. Given the significance of GS-37 and the
controversy that surrounds all chemical restrictions, this was
to be expected, says Green Seal. “It is difficult to reach total
consensus with leadership standards that may exclude many
products in a market and potentially many manufacturers as well.
It is therefore no coincidence that a number of trade
associations object to the standard, as they are constituted to
uphold the interests of all their members and members’
products.”
In October, a group of trade
associations and producers announced their opposition to the
revised standard, saying the process Green Seal implemented to
develop GS-37 fell far short of being “fair, unbiased and
credible.”
The group includes the
following: New York State Chemical Alliance, Alkylphenol
Ethoxylates Research Council, American Chemistry Council, Carpet
and Rug Institute, Consumer Specialty Products Association,
Reckitt Benckiser, Inc., SI Group, Inc., The Fragrance Materials
Association, The Soap and Detergent Association, and Zep, Inc.
“As organizations directly
involved in the development of this standard, we are deeply
disappointed by Green Seal’s process and cannot recognize GS-37
as a valid, consensus-based standard,” the group said in a
statement.
They went on to say,
“throughout the standard development process, our organizations
consistently commented that numerous criteria in GS-37 lack
sufficient scientific basis. These concerns were not adequately
addressed, leading to sustained opposition when stakeholders
voted on the November 2007 proposed standard.”
ISSA voted in opposition to
the revised GS-37 standard based on a number of substantive
issues. Nonetheless, Bill Balek, ISSA’s director of Legislative
Affairs, said the cleaning industry association has adopted a
neutral position in regard to the revised GS-37 standard.
“Ultimately, it is the role of
the marketplace to determine whether the revised environmental
standard succeeds in its goals,” he said.
Balek said ISSA voted against
the revised draft of GS-37, and in its comments raised concerns,
including but not limited to, the handling of asthmagens,
dispensing control systems, VOC limits and concentrates.
Balek’s review of the summary
of comments received by Green Seal along with the GS-37 ballots
revealed that the following issues were the most contentious:
Asthmagens — A significant
number of comments objected to Green Seal’s continued reliance
on the Association of Occupational and Environmental Clinics
(AOEC) list of asthmagens as the basis for prohibiting certain
ingredients from being included in cleaning product
formulations.
These comments invariably
noted that reliance on the AOEC list was inappropriate because
it was never intended for such a purpose. Rather the AOEC list
is part of an epidemiology tool for developing a database for
occupational exposures.
The AOEC does not identify
known agents that cause asthma; instead it provides a reference
for clinics to gather information to be compiled into an
occupational database.
Respiratory Irritants — Green
Seal received a number of comments objecting to the definition
of respiratory irritants as overly broad, recommending instead
that it adopt the definition used in the Globally Harmonized
System for Hazard Communication (GHS). In addition, commenter’s
took issue with the limitations placed upon allowable
concentrations of d-limonene and terpene hydrocarbons, noting
the lack of scientific basis for regarding these substances as
respiratory irritants.
Dispensing System Concentrates
— Non-governmental organizations and others continue to raise
concerns over Green Seal’s proposed approach to dispensing
system concentrates, which would allow such products to be
tested “as used” as opposed to in concentrated form in regard to
a number of health and environmental criteria.
Prohibited Ingredients —
Significant objections were raised concerning Green Seal’s
proposed approach to prohibiting heavy metals (as a neurotoxin),
2-butoxyethanol (as a systemic toxin), and phthalates (as an
endocrine disruptor).
VOC Content — Proposed VOC
content limitations were also the subject of significant
comments in the voting process. One camp pointed out the
inconsistencies in the calculation of VOC content between the
summing approach that exempts low vapor pressure VOCs, and
California Method 310, which does not allow for such exemptions.
In addition, industry representatives continued to urge Green
Seal to set limits consistent with the California Air Resources
Board.
Chronic Inhalation Toxicity —
This subject was the source of quite a bit of discussion by
commenter’s, a number of which called upon Green Seal to
continue to pursue an exposure modeling approach that was
floated about a month before the voting closed on GS-37.
Industry opposed that approach because it surfaced late in the
process and is far too complex to adequately address in the
short time frame necessitated by the GS-37 revision process.
Green Seals says, the process
to develop GS-37 was open and transparent, as required by ISO.
Any interested party was allowed to participate in the public
review periods and given several opportunities to register as a
stakeholder, for involvement throughout the process. Project
progress and discussion were continually accessible through
several electronic means (e.g., Web site, on-line forum, and
e-mail).
Stakeholder discussions were
also conducted through teleconferences with open participation.
Green Seal said it took
measures well beyond the requirements to ensure that stakeholder
input was carefully considered. This even involved the use of a
professional, independent facilitator to address unresolved
issues. The result was a balance of all the viewpoints of the
stakeholders involved in the project, noting that there were
divergent perspectives on many issues where parties were not
able to find areas of agreement or compromise.
In environmental leadership
standards, the accepted practice is not to use less of a
potentially harmful component, but rather to use less harmful
alternatives to begin with. Green Seal says one reason for
revising GS-37 was to address the health concerns of children,
since green cleaning products are being used increasingly in
schools. But current risk assessment studies are limited and are
primarily focused on adults.
The many uncertainties
inherent to health risk assessment are compounded when applied
to children. The differences between children and adults,
critical developmental windows, and uncertainty in the risk
assessment process all support taking a precautionary approach
to protecting children from chemical exposures from cleaning
products. Green Seal says this approach is well accepted by
Federal and State agencies as well as global and international
regulatory bodies.