Manufacturing Today - January/February 2014 - 17

LYNN L. BERGESON

Analysis
EPA states that the Draft Guidelines
are not intended to discontinue or
diminish procurement of products
conforming to government standards
and ecolabels, but rather supplement
existing mandates and government
standards and ecolabels. Although
only intended expressly to help guide
federal purchasing, EPA acknowledges that the Draft Guidelines could
affect a broader consumer marketplace to the extent that the Draft
Guidelines increase the availability of
greener and safer products that are
purchased by both the government
and consumers. EPA provided examples, including cleaning products,
paper and building materials.
The new Draft Guidelines reflect
the commitment of the federal government to lead by example in greening the purchasing habits of the government. As more and more products are subject to limitations that
are intended to prompt the greening
of product categories, suppliers will
be challenged to meet these standards or choose not to service the
federal procurement market. As a
"big bear in the woods," the federal
government is a hugely influential
purchaser and is plainly committed
to incentivizing green purchasing
habits. Manufacturing Today readers
may wish to understand these Draft
Guidelines and appreciate their commercial impact to remain competitive and qualified to service the federal government. mt

E CONOMY

Under the Draft Guidelines, one or
more non-governmental (private
sector) organizations with expertise
in environmental standards and ecolabels would work with EPA and key
stakeholders to develop a process for
applying the guidelines to private
sector environmental standards and
ecolabels. The Draft Guidelines
include criteria to assist in identifying those private sector standards
and ecolabels federal purchasers
should consider when buying greener products. Specifically, the Draft
Guidelines are divided into four sections addressing various aspects of
product environmental performance
standards and ecolabels:
> Section I, "Guidelines for the
Process for Developing Standards"
addresses the procedures used to

Recognizing that the level to which
sustainability practices have been
incorporated varies by industry sector
and sometimes even from product category to product category, the Draft
Guidelines would be applied on a
product-category by product-category
basis. A list of product standards and
ecolabels that meet the Draft
Guidelines could be created and then
considered by federal purchasers,
along with other federal mandates and
requirements for federal purchasing.
EPA is seeking comments on the
Draft Guidelines in general and has
posed these specific areas for comment. Topics include: how might the
Guidelines benefit the broader marketplace?; are there gaps in the Draft
Guidelines that could be addressed
by a new Guideline(s)?; are the designations of "baseline" and "leadership" in the Draft Guidelines understandable?; do the Draft Guidelines
appropriately
reflect
varying
approaches in the marketplace
today?; and what challenges need to
be addressed/resolved in implementing the proposed Guidelines in order
to be a transparent, fair and consis-

tent process? These questions provide guidance to stakeholders on the
types of issues on which EPA can be
expected to focus.

A LFAB INC.

Draft Guidelines

develop, maintain and update a
product environmental performance standard.
> Section II, "Guidelines for the
Environmental Effectiveness of
the Standards" addresses the criteria in the standard or ecolabel that
support the claim of environmental preferability.
> Section III, "Guidelines for
Conformity Assessment" addresses the procedures and practices
by which products are assessed
for conformity to the criteria
specified by standards and ecolabeling programs.
> Section IV, "Guidelines for
Management of Ecolabeling
Programs" addresses the organizational and management practices
of an ecolabeling program.

B UY AMERICAN

more sustainable in its purchasing, and
how federal purchasers can best meet
the numerous federal requirements
for the procurement of sustainable
and environmentally preferable products and services.
While federal agencies currently
use some programs to assist them in
purchasing products that meet federal standards for energy, water and
safer chemicals (e.g., Energy Star,
Watersense and Design for the
Environment ecolabels), there are
many other products that are not
covered by such federal programs
and ecolabels.
EPA states that the "lack of guidance on using other product environmental performance standards and
ecolabels often results in an inconsistent approach by federal purchasers
and confusion and uncertainty for
vendors and manufacturers." EPA
states that the "challenge for federal
buyers is sorting through these hundreds of other products with nongovernmental standards and ecolabels that claim to be safer or environmentally friendly."

COLUMN BY

Lynn L. Bergeson is managing partner of Bergeson & Campbell P.C.
(B&C®), a Washington, D.C., law firm focusing on conventional, nanoscale,
and biobased industrial, agricultural and specialty chemical product regulation and approval matters, environmental health and safety law, chemical
product litigation, and associated business counseling and litigation issues.
She is president of The Acta Group, with offices in Washington, D.C.,
Manchester, UK, and Beijing, China, and president of B&C Consortia
Management L.L.C. (BCCM) with offices in Washington, D.C.

JANUARY/FEBRUARY 2014 manufacturing-today.com

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Table of Contents for the Digital Edition of Manufacturing Today - January/February 2014

Table of Contents
Manufacturing Today - January/February 2014 - Cover1
Manufacturing Today - January/February 2014 - Cover2
Manufacturing Today - January/February 2014 - 1
Manufacturing Today - January/February 2014 - 2
Manufacturing Today - January/February 2014 - Table of Contents
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