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Summary of Comments Received from the Federal Register Notice of Voluntary Standards for EPP - Other

Chemical Compliance Systems, Inc.
Consumer's Choice Council
Logistics Management Institute

[EPA Questions answered: 1, 2, 3, 4, 5, 6, 7, 8 ]

1.	Name	Chemical Compliance Systems, Inc.
	Address	Lake Hopatcong, New Jersey
	Contact Info	George Thompson (973) 663-2148
	Nature of Organization	Consulting firm.
2.	Standards Development Activities for Which Sectors?	Internal standards for wide range of clients: academic, government, and industry.
3.	Procedures	Has extensive written SOPs. Not a certified ANSI affiliate.
4.	Environmental Attributes in Scope of Standards?	Has been discussing prospective computerized tool for EPP with DLA, GSA, and EPA.
5.	Perform Product Certification?	No. Performs hazard assessments.
6.	Perform Product Attribute Development?	No. Performs hazard assessments.
7.	Nature of Government Participation, If Any:	None to date.
8.	EPP Market Needs:	Has extensively discussed market needs with numerous organizations. High interest in paints, cleaners, oils and lubricants, adhesives, and inks. Since EPP is a regulatory-driven concept, the "need' within market sectors will be as broad and as deep as the regulatory agencies demand.
	Other issues:	CCS is prepared to work either with EPA and other appropriate federal agencies, or with a nongovernmental standards development organization, to refine its computerized resources and software to support environmentally preferable purchasing.

[EPA Questions answered: 1]

1.	Name	Consumer's Choice Council
	Address	Washington, D.C.
	Contact Info	Cameron Griffith (202) 785-1950
	Nature of Organization	Coalition of environmental, labor, and human rights organizations that works to facilitate the identification of environmentally and socially responsible products through third-party certification.
	Recommendations:	EPA should encourage federal agencies to take advantage of the existing expertise of organizations (e.g., GreenSeal, the Forest Stewardship Council, and Canada's Environmental Choice Program) that use "leadership standards." Environmental preferability should be determined through leadership standards, not consensus standards.
	Other issues:	Use of consensus standards is inconsistent with E.O. 13101 and would delay federal agencies' implementation of their EPP responsibilities. NTTAA, OMB A-119, and ISO 14024 do not require use of consensus standards.

[EPA Questions answered: 1, 2, 6]

1.	Name	Logistics Management Institute
	Address	McLean, Virginia
	Contact Info	Raheem Cash 703/917-7377
	Nature of Organization	Nonprofit research and consulting organization.
2.	Standards Development Activities for Which Sectors?	Not a voluntary standards development organization.
3.	Procedures	Not addressed.
4.	Environmental Attributes in Scope of Standards?	Not addressed. See 6 below.
5.	Perform Product Certification?	Not addressed. See 6 below.
6.	Perform Product Attribute Development?	Worked with various clients to "green" their product specifications and to incorporate environmental considerations into their daily practices.
7.	Nature of Government Participation, If Any:	Not addressed.
8.	EPP Market Needs:	Not addressed.
	Recommendations:	Reviewing and using existing standards is an excellent starting point because it allows the government to determine which markets are most suited for consensus based standards. EPA should convene key stakeholders to explore this very complex issue further. EPA could develop standards for the process of evaluating products. EPA should consider using a Type III labeling scheme. Organizations should be assigned to stay abreast of changes in technology and practices and report regularly to standards developers.
	Other issues:	The time it takes to develop standards. The complexity of environmental attributes to consider over the product lifecycle. Lack of agreement on the criteria and the process for weighing those criteria. The potential to hinder flexibility and innovation because standards are difficult to change and are viewed as endpoints. Waiting for standards could seriously delay the government's progress in green purchasing.

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