By Linda H. Chipperfield With many municipalities now requiring sustainable cleaning and maintenance programs and many private facilities looking to do the same, the hardest part of “going green” is not usually getting buy-in from constituents and colleagues, but ensuring that the program put in place is truly “green.” Guidelines used by the Federal Trade Commission (FTC) to prevent deceptive advertising, which were recently revised specifically to address green marketing claims, can help do just that. Long before green cleaning became an imperative for facility managers (fms), “greenwashing” was a caution. As demand for green cleaning products and services rose, so too did sustainability claims made by providers that often were at best “questionable.” Recognizing that the marketing of green products and services was becoming unmoored from any reliable standard, The FTC revised in recent years what are known as “The Green Guides,” the Federal government’s guideline for marketers of sustainable products and services. The FTC’s Guides for the Use of Environmental Marketing Claims, as they are more formally known, were first drafted in 1992 to govern advertising claims related to the environmental benefits of a product or service. These guidelines underwent significant revision and expansion in 2012 to reflect a changed green marketplace. While the Green Guides are purely guidance and not laws or regulations, they exist to explain how the FTC interprets the law as it pertains to environmental claims in order to ensure truth in advertising and to guard against deceptiveness. For fms looking to source green cleaning and maintenance products or services, the requirements put in place by the FTC in the Green Guides can be used as a measuring stick to determine if that product or service really qualifies as environmentally preferable. These provide some much needed assurance into decision making and thus inject greater confidence into the acquisition process. Basically, any claim a product manufacturer or service provider makes in its marketing or communications that conveys an environmental benefit or environmental health benefit is covered by the Green Guides. This applies to a claim that a product is green or sustainable, or to a claim that any part of a cleaning service is green or sustainable. The guidance strongly discourages any general environmental benefit claims. For example, saying a product or service is green or sustainable and then not qualifying this claim with respect to specific features is interpreted as being misleading. Any seal or certification that suggests a product or service is environmentally preferable must be qualified. A certification for a green or sustainable product or service should state the basis for the award in specific terms. The basis or qualification statement must be able to be substantiated with actual evidence. It is deceptive to make an environmental claim that appears to be made by a third party (independent and without conflict of interest) when it is not. “Self certifications” or seals awarded by a product manufacturer or service provider to itself must be disclosed as such. Also, certifications by a second party, such as an industry trade association or membership organization, must disclose this relationship. Any material connection between the certifier and the certified party must be disclosed. For example, if the certifier has a board that is in any way controlled by the manufacturing or service industry, this must be disclosed. The Green Guides are not intended to discourage environmental claims or marketing, but are constructed to ensure that marketing claims are truthful, can be substantiated, and are not misleading or deceptive. For fms who are looking to secure products or services in compliance with sustainability mandates (whether internal or external), using the Green Guides as a way to assess supplier claims can make their task easier. Prior to this guidance, it was even more difficult to know that what was being acquired was truly green or that it met the expectations created by its marketing or packaging.
The FTC Green Guides bring a greater degree of certainty to the process of acquisition over time. Meanwhile, fms have a useful tool for determining truly green products and services. And this means more than just fulfilling requirements for green cleaning and maintenance programs; it means peace of mind that products used within a facility will help protect the health and safety of occupants and cleaning staff alike. Chipperfield is the vice president of marketing and communications at Green Seal. As an independent, science based standards developer and certification body, Green Seal identifies products and services that are environmentally responsible.