By Steve Ashkin, The Ashkin Group

Green Seal has announced that its revision of GS-37 Standard for Industrial and Institutional Cleaners is now available for public review and comments through January 16, 2008.

The Proposed Revised Standard, along with a background document providing information about the proposed changes, is available on the Green Seal web site:
http://www.greenseal.org/certification/gs37_iicleanersstandard_dev.cfm.

After a quick review of the documents I generally think that the development team is headed in a positive direction. However I was disappointed that as a member of their elected Stakeholder Committee they generally failed to respond to my requests to provide information on the costs of proposed new testing methods. I had requested this information because I wanted to be in a position to make a more informed decision about various testing options.

The reason this is important is because GS37 is a VOLUNTARY standard and in most cases end-users such as schools can choose NOT to use Green products if they cost more than the traditional counterparts. This certainly is the case in New York with the Green Cleaning in Schools legislation, as it is in Illinois. Bottom line is that if this additional testing makes the cost of these products prohibitive, then in affect we have harmed rather than helped our efforts to create safer schools for our children.

I am also concerned about the issues relative to asthmagens. Please know that I am very aware of the asthma epidemic among young children. But simply providing a questionable list of ingredients to be prohibited is to me a poor solution to the problem. Furthermore, the issues around fragrances and whether or not they are “formaldehyde-donors” give me reason to pause since I am unsure of the implications of this requirement and the science behind it. Frankly it leaves me to wonder if the underlying effort is simply to “ban” fragrances.

But these in some respects are minor compared to two other issues that have emerged. I have become increasing concerned about Green Seal’s process and how it appears to have been manipulated by the Executive Committee. First I think it is important to point out that in all the standard setting efforts in which I have been involved I have never before seen the use of an “executive committee”. ASTM doesn’t do this. ISO doesn’t do this. Environmental Choice doesn’t do this. And up until now, Green Seal hadn’t done this.

And one of the places where the influence of the Executive Committee may play out is in how they have changed the voting. For example, did you realize that the 20 or so members of the elected Stakeholder Committee represent how votes will be weighed? I certainly didn’t and I am a member of the elected Stakeholder Committee.

And my understanding is that the hundreds of stakeholders from the chemical industry get 3 votes and if you are in the chemical industry your vote is just a small fraction of those 3 votes. At the same time the handful of equipment manufacturers get 1 vote. Thus if you are one of the 10 or so equipment manufacturers, your vote is worth a lot more, compared to the vote of one of the hundreds of chemical industry representative.

This to me is unfair and while I appreciate the intent to make “all voices heard” and to prevent the chemical industry from dictating the standard, but this process has swung the vote to the other extreme. I believe it is wrong and should be corrected especially in light of the fact that this was NOT explained to us in the beginning of the process.

Please know that this is NOT a contrarian position where I am just opposed to what Green Seal is doing because I think my work over the years to support Green Seal proves otherwise. Nor is this a political statement. Rather the revision of GS37 is a technical document specifically designed to help formulate greener cleaning chemicals. And as such we need to get the involvement of those who actually formulate products --- rather than trying to minimize their input by devaluing their vote regardless of the “intent”.

And finally, buried in Green Seal’s recent message is that the University of Tennessee (UT) who has served as the technical administrator of the project has been removed to help streamline communications. I must be upfront and tell you that I have known the folks at UT for over 10 years now and have an enormous amount of respect for their technical competence and their fairness. Removing them in the middle of this process gives me cause for concern. Especially since the stakes are so high.

So I would encourage you to participate in the process. Green Seal recommends that you use their on-line forum. All registered forum users will be able to view all the comments and the name of the commenter. Forum user registration is open until the deadline (January 16, 2008). To register as a user and access the forum:
• Click on http://green-seal.org/standards
• Register an account; for the username please use your first initial, then a space, and full last name (e.g., J Smith); select “GS-37 Standard Development”; review the disclaimer information; click Register.
• You should receive a welcome email from the Green Seal Development Forum within one business day.
Green Seal will also accept comments by email, fax and postal mail.

But the bottom line is for you to be engaged. Your vote has never been so important.

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