Earlier this year (1/8/09), FacilityBlog posted an article announcing the withdrawal of support from the Carpet and Rug Institute for Green Seal’s GS-37 (as a Green Certification for its Seal of Approval Carpet Cleaning Solutions). The following response comes directly from officials* from Green Seal.
Green Seal, a third party certifier of green products and services, first published its standard for institutional cleaning products—GS-37—on October 2, 2000. GS-37 has become the single most-referenced environmental standard in the cleaning industry. Increased concerns about the impact of chemicals on health, particularly our children’s health, and the environment led to the recent revision of this standard. The final result of the 21-month revision process, completed on August 29, 2008, is a standard that represents leadership in the industry and takes environmental stewardship and the protection of human health to a whole new level.
In the final analysis, 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 & CEO of Green Seal, “and anticipate that many progressive manufacturers will see the benefit of conforming with a leadership standard that promotes more sustainable cleaning products that will ensure a healthier, cleaner environment for all.”
The Guidelines Are Clear
The Green Seal 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. While Green Seal standards have achieved 100% 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. 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.
There were 400 registered stakeholders engaged in the standard development process, including chemical manufacturers, children’s health advocates, facilities workers, government agencies, and institutional purchasers. Having a scope of work available at the onset of the project that outlined the procedures following ISO 14024, all stakeholders were fully aware of the process being followed, the number of votes required and the type of standard they participated in developing.
The Participation Was Open
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 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.
The Criteria are Science-Based
ISO 14024 also requires that the criteria of a standard be based on sound scientific and engineering principles and be derived from data that support the claim of environmental preferability. The revised GS-37 is based on peer-reviewed scientific data. For specific chemicals of concern, if there was evidence of a safer alternative, this warranted replacement of such chemicals. Peer review is also included within the other criteria in the standard by citing chemical lists that are compiled based on expert review of literature supplied by IARC, NTP, ACGIH, AOEC among others.
As a general principle Green Seal standards reference other widely accepted standards in their criteria. In the case of carpet cleaners, there are a number of methods of testing efficacy. If there were a singular standardized method to which stakeholders referred, it would have been referenced. In the absence of an approved standard, the new GS-37 references CRI or WoolSafe methods or comparison tests as the best means for assessing if the product performs as required.
Supporting the Health of Children
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. 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. This approach is well accepted by Federal and State agencies as well as global and international regulatory bodies.
The Standard Has Broad Support
It has been Green Seal’s mission and work for twenty years to develop environmental leadership standards for products and services. These standards are only as strong as our credibility and adherence to a strict, open and transparent process such as defined by ISO. While the standard did not achieve 100% consensus, we have already received a number of GS-37 recertification applications, and we have now certified products to the new standard. The majority of stakeholders, including government agencies, environmental and public health groups, accept the published standard and continue to support it. And Green Seal will continue to do the challenging and often controversial work of protecting the health of adults, children and the environment in which we all live.
*Disclaimer: FacilityBlog has been asked to present both sides of the issue; it does not support or dismiss the views of either organization.