New York State Responds to Comments on Proposed Green Guidelines
According to reports from ISSA, the New York State Office of General Services (OGS) announced its intent to rely on Green Seal and Environmental Choice certification, and not the U.S. EPA Design for the Environment Formulator Initiative, in defining environmentally preferable cleaning products in the context of the state’s Proposed Guidelines and Specifications on the Procurement and Use of Environmentally Sensitive Cleaning and Maintenance Products for Elementary and Secondary Schools in New York State.
OGS’s announced intent was included in the Agency’s official response to the public comments it received on the subject of the proposed guidelines, which are posted here.
In 2005, new legislation amended New York Education Law and State Finance Law related to the purchase and use of green cleaning products in public and non-public elementary and secondary schools. Among other things, the legislation requires OGS to establish and maintain guidelines and specifications for the procurement of such products.
ISSA was disappointed to learn of the State’s decision to not recognize the U.S. EPA Design for the Environment Formulator Initiative in qualifying cleaning products as environmentally preferable. In regard to New York State and public procurement policy generally, ISSA has been an ardent advocate of a multi-faceted approach to defining green cleaning products. Specifically, as it relates to chemical cleaners, ISSA supports an approach that recognizes cleaning products as green by virtue of:
Green Seal certification;
Environmental Choice certification;
Recognition by U.S. EPA Design for the Environment; or
Other valid documentation that the product meets the requisite specifications.
Such an approach ultimately will ensure that the State has available a robust supply of efficacious green cleaning products at a competitive price.
Despite the numerous comments submitted in support of Design for the Environment program, OGS opted to exclude DfE recognized products because in its opinion the DfE program “…has not established a standard or set of criteria that products must meet to be recognized.”
In a memo directed to Kurt Larson, OGS, ISSA registered its objections to the Agency’s decision and encouraged OGS to reconsider its position on products recognized by the EPA DfE Formulator Initiative.
The New York State Office of General Services is expected to publish the final version of its green cleaning product procurement guidelines later this week.
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