Larry Cobb
Member
Here is a quote from ISSA I just received:
"ISSA Chimes in on Proposed Revisions to Green Seal’s Cleaning Product Standard
ISSA Positively Impacts Voting Process
January 31, 2008
ISSA called upon Green Seal to devise a path forward that would drive out the substantial costs associated with revisions it has proposed to its environmental standard for institutional and industrial cleaners (GS-37), in comments submitted January 30 by Bill Balek, Director of Legislative Affairs, ISSA.
In addition to the costs associated with the price of certification, ISSA noted in its comments that the proposed revisions to GS-37 would likely require the generation of additional data at the price of thousands of dollars per product. “Ultimately, if left unchecked, these and other costs associated with certification will act as a financial barrier to small and medium sized formulators of cleaning products,” according to Balek.
In its comments, ISSA also urged Green Seal to address the process of transitioning to a new GS-37 standard, an issue that heretofore has gone unaddressed. Given the huge financial and operational implications the transition process has for industry, ISSA’s Balek urged Green Seal to consider a process that would “grandfather” currently certified products to soften the blow.
ISSA’s comments were submitted as part of the public comment phase in the process of revising GS-37. Green Seal anticipates that it will release a final revised version of GS-37 by June 2008 after the proposed revisions undergo one more comment period that will be limited only to registered stakeholders.
Other issues addressed in ISSA’s comments include proposed VOC limitations, packaging requirements, asthmagens, dispensing system concentrates and other related subjects."
At their website, ISSA says that Green Seal is proposing:
1. To limit VOC's to 1% for Carpet Cleaning products.
(ISSA is proposing 4%)
2. To Eliminate Fragrances & low-vapor pressure solvents completely.
(ISSA is proposing 2%)
3. To require biodegradability testing for every ingredient.
(This eliminates many raw materials & ISSA proposes EPA methods to predict biodegradability)
4. To set limits for d-Limonene and terpenes.
(ISSA is proposing no limits)
5. Wants package weight reduced by 20%.
(This would increase shipping leaks. ISSA proposes 10%)
6. Wants new testing with an estimated additional cost of $4350 to $6350 PER PRODUCT.
(This would increase costs significantly for carpet cleaners.)
ISSA is also recommending that Green Seal recognize CleanGredients with EPA criteria as suitable for GS-37.
As cleaners, you need to stop Green Seal before it is required by LAW in most commercial buildings.
Larry Cobb
"ISSA Chimes in on Proposed Revisions to Green Seal’s Cleaning Product Standard
ISSA Positively Impacts Voting Process
January 31, 2008
ISSA called upon Green Seal to devise a path forward that would drive out the substantial costs associated with revisions it has proposed to its environmental standard for institutional and industrial cleaners (GS-37), in comments submitted January 30 by Bill Balek, Director of Legislative Affairs, ISSA.
In addition to the costs associated with the price of certification, ISSA noted in its comments that the proposed revisions to GS-37 would likely require the generation of additional data at the price of thousands of dollars per product. “Ultimately, if left unchecked, these and other costs associated with certification will act as a financial barrier to small and medium sized formulators of cleaning products,” according to Balek.
In its comments, ISSA also urged Green Seal to address the process of transitioning to a new GS-37 standard, an issue that heretofore has gone unaddressed. Given the huge financial and operational implications the transition process has for industry, ISSA’s Balek urged Green Seal to consider a process that would “grandfather” currently certified products to soften the blow.
ISSA’s comments were submitted as part of the public comment phase in the process of revising GS-37. Green Seal anticipates that it will release a final revised version of GS-37 by June 2008 after the proposed revisions undergo one more comment period that will be limited only to registered stakeholders.
Other issues addressed in ISSA’s comments include proposed VOC limitations, packaging requirements, asthmagens, dispensing system concentrates and other related subjects."
At their website, ISSA says that Green Seal is proposing:
1. To limit VOC's to 1% for Carpet Cleaning products.
(ISSA is proposing 4%)
2. To Eliminate Fragrances & low-vapor pressure solvents completely.
(ISSA is proposing 2%)
3. To require biodegradability testing for every ingredient.
(This eliminates many raw materials & ISSA proposes EPA methods to predict biodegradability)
4. To set limits for d-Limonene and terpenes.
(ISSA is proposing no limits)
5. Wants package weight reduced by 20%.
(This would increase shipping leaks. ISSA proposes 10%)
6. Wants new testing with an estimated additional cost of $4350 to $6350 PER PRODUCT.
(This would increase costs significantly for carpet cleaners.)
ISSA is also recommending that Green Seal recognize CleanGredients with EPA criteria as suitable for GS-37.
As cleaners, you need to stop Green Seal before it is required by LAW in most commercial buildings.
Larry Cobb