Report from the Montana SBC

SBCbadgeKatherine Roggeveen, an intern with the Montana Sustainable Business Council, did an outstanding job researching some questions I had proposed to the council back in June.

I now have even more confidence in the products I am using. Thanks Katherine!space

Product Certification – Background Information

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The process of searching for a “green” cleaning product becomes one of great difficulty with the overwhelming presence of eco-labels, product certification, and greenwashing overtaking the marketplace. When analyzing the certification process, there are three levels of certification ranging in levels of credibility: first party, second party, and third party.
space •    First party: First party certification is self-declaration by the company producing the product. The company sets its own standards and certifies that their products measure up to the standards set. Third-party assessments are rarely used to check credibility of claims and, if they are used, these parties are chosen by the organization itself. No external test data or verification processes are required.

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-Example: GreenSpec Directory

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space•    Second party: Second party certification describes an industry-based association that an individual organization belongs, that provides the standard, label, or set of criteria for certification that a product, process or service may aspire. The lab or organization conducting the testing or auditing, if chosen to do so, may be a third party or independent agent against an industry-managed standard, and is therefore dictated in part by a group of vested interests.

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-Examples: ENERGY STAR, WaterSense, Sustainable Forestry Initiative.

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space •    Third party: Third party certification is considered the leadership standards, providing opportunity for market transformation and greater assurance that marketing claims truly reflect the products’ “green” capabilities. This level of certification describes a product, process or service that meets specified, industry-independent criteria or standards according to the verification and review by an impartial industry-independent agent. Verification is performed through a certifying body conducting independent data reviews, auditing, and/or testing in accordance with industry-independent standards or criteria. To ensure credibility of third-party certification, the testing lab or certificating body must not be an extension or subsidiary of the company requesting the certification.

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-Examples: Cradle to Cradle (C2C), Green Seal, GREENGUARD                 Certification Program, and Forestry Stewardship Council (FSC).

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Source: Primary Green Product Standards and Certification Programs: A Comparison. 2009. Air Quality Sciences, Inc. 29 June 2009. http://www.aerias.org/uploads/2009.03.WP.GreenProdCertProgCompare.pdf

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When searching for any type of green product, third party certification is the most credible and unbiased source of certification.

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Green Seal Product Certification

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Being a third-party certifying organization, Green Seal is a reliable source for “green product” certification. Green Seal is an independent, non-profit organization that identifies and promotes products and services that cause less toxic pollution and waste, conserve resources and habitats, and minimize global warming and ozone depletion. Green Seal uses an open consensus-based process to develop its standards and relies on outside funding to support this process. How does a product become Green Seal certified?
•    Requires up front payment of all fees as a part of the application process.
•    Utilizes a life-cycle approach, which means it evaluates a product or service from the creation of the materials used in the product, to manufacturing and use of the product itself, to recycling and disposal of the product.
•    After products are evaluated and found to be in compliance with the applicable Green Seal standard (Green Seal Environmental Standards for Industrial and Institutional Cleaners: http://www.greenseal.org/certification/gs37_iicleaners.cfm), the manufacturing facility is visited to ensure the current product is representative of future production. Manufacturers must keep extensive records to demonstrate continued compliance with this requirement.
•    Once certified, products are subject to annual monitoring. Manufacturers are required to demonstrate that their products meet each standard’s specific criteria, including providing test results.

**Green Seal is also recognized by the U.S. Green Building Council’s LEED 2009 Rating System Certification. **

Overall, Green Seal is a reliable source for green purchasing because:
•    Third party certification
•    Independent
•    Testing required (performed by outside, non-stakeholder or organization affiliated assessor).
•    Follow up and rigorous bookkeeping and adherence to standards.
•    Standards change as needed to comply with environmental changes (requiring manufacturers to change their practices/products to still adhere and be able to use the Green Seal label).

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Source: Primary Green Product Standards and Certification Programs: A Comparison. 2009. Air Quality Sciences, Inc. 29 June 2009. http://www.aerias.org/uploads/2009.03.WP.GreenProdCertProgCompare.pdf

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Greenest Carpet Cleaners – Assessment of Procyon Cleaning Products

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As of August 29, 2008, Green Seal has issued a revised edition of GS-37, Green Seal’s Environmental Standard for Industrial and Institutional Cleaners. Products certified under the previous editions of GS-37 have until November 29, 2009, to comply with the revised standard. (For more information about re-certification requirements, see: http://www.greenseal.org/certification/forms_fees.cfm).

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Procyon Plus

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The carpet cleaner Procyon Plus is currently certified under the revised standards for GS-37.
Procyon Plus:
-Received the Carpet and Rug Institute Seal of Approval.
*Identifies effective carpet cleaning solutions and equipment that clean carpet right the             first time and protect a facility’s carpet investment.
Source: Commercial Customers: Seal of Approval Products. Carpet and Rug Institute. 30 June 2009. http://www.carpet-rug.org/commercial-customers/cleaning-and-maintenance/seal-of-approval-products/index.cfm
-Meets the current Green Seal environmental standards for industrial and institutional cleaners     based on its reduced human and environmental toxicity and reduced volatile organic     compound content (VOC).
-Complies with OSHA’s HAZARD Communication Standard.
*Ensures that the hazards of all chemicals produced or imported are evaluated, and that         information concerning their hazards is transmitted to employers and employees. The             transmittal of information is to be accomplished by means of comprehensive hazard             communication programs, which include container labeling and other forms of warning,             material safety data sheets and employee training.
Source: Hazard Communication. 1996. United States Department of Labor: Occupational Safety and Health Administration. 3 July 2009. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099.
-Received the approval of IAQ (Indoor Air Quality).
*The IAQ and OSHA (Occupational Safety and Health Administration) regulate                 formaldehyde, a specific VOC, as a carcinogen. In order to be approved as adhering to             IAQ standards, a product must be mitigated if the present formaldehyde level is higher             than 0.1 ppm and does not except the Permissible Exposure Level of .75 ppm.
Source: An Introduction to Indoor Air Quality. . U.S. Environmental Protection Agency. 30 June 2009. http://www.epa.gov/iaq/voc.html#Standards%20or%20Guidelines

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Procyon Plus is a smart and reliable product to use in your green carpet cleaning business.

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Procyon Extreme!

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The carpet cleaner Procyon Extreme! is currently not certified under the new GS-37 Green Seal standards. Although the MSDS shows the Green Seal Certification, it is only because the manufacturer has until November 29, 2009 to make the necessary changes to adhere to the new requirements.
Procyon Extreme!:
-Is currently still certified under the IAQ’s seal of approval.
-Complies with OSHA’s HAZARD Communication Standard.
-Complies with the previous GS-37 standard.

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The use of Procyon Extreme! is not a bad choice in your carpet cleaning business but it would be worth while to make sure that this product does make the necessary changes to become re-certified or to look for a current product that is updated in certification. For a list of certified products under the new GS-37 see: http://www.greenseal.org/findaproduct/i&icleaners.cfm)

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Reliability of MSDS Documents

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A material safety data sheet is intended to be a reference document that reflects the most accurate and current information about a specific hazardous chemical product that is available at the time the MSDS is developed. It is the chemical manufacturer’s (or the responsible party’s) obligation to ensure that the information contained on an MSDS is accurate and meets the requirements of OSHA’s Hazard Communication Standard (HCS). A MSDS must:
•    Represent an up-to-date reflection of current scientific information related to the hazardous chemical or product as of the date that the MSDS is prepared. (The MSDS would be in violation of the HCS if the dates required by the standard were not included on the document).
•    Be updated whenever the required information on the data sheet changes. The updated data sheet must then be sent with the next shipment of the chemical to the downstream user.
A MSDS is valid until the information is superseded and a new MSDS is issued to the purchaser with the next order/shipment. As the duty of learning about and staying up-to-date about current scientific data on hazardous chemicals falls on the manufactures, importers, and distributors of the chemicals, it would be illegal for MSDS to be out-dated and incorrect in the information they present. Therefore the MSDS documents provided by Procyon are reliable and accurate documents as they abide by OSHA’s HCS and represent only the most recent knowledge.

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Source: Clarification of the Requirement to Provide Accurate and Current Hazard Information on an MSDS. 22 June 2009. ILPI’s Interactive Library of OSHA MSDS Regulations and Interpretations. 28 June 2009. http://www.ilpi.com/msds/osha/I20080418.html

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Testing Indoor Air Quality

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If you believe that there is an air quality problem in an indoor environment, Indoor Air Quality Testing should not be the first move. This is because:

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•    There Are No Standards
•    There are no appropriate standards for indoor air quality (IAQ) in environments such as schools and residences.
•    There are some industrial standards for permissible exposure limits for certain chemicals used in manufacturing and other work place settings.
•    There are no standards for indoor levels of molds. This because there is great variability in people’s reaction to mold. Also, there is no scientific support for designating a particular mold measurement “safe” or “unhealthy.”
•    The most current ventilation guidelines for acceptable indoor air quality are just that – guidelines. They are not enforceable unless they are part of the building code.

•    The Lack Of Enforceable Standards Makes Interpretation A Tricky Business
•    It is difficult to interpret the results of air testing.
•    Testing as a first response does not usually lead to an answer or solution. Very often air testing is conducted as an impulse reaction to a reported IAQ problem.
•    Background Exposures – Most IAQ pollutants (mold, particles, and volatile chemicals) are present in buildings at “background” levels. These contaminants are present in most buildings without causing adverse health effects. Testing indoor air will therefore always find something, usually background that does not have significance for reported health complaints.

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Therefore, DO NOT TEST IF:
•    The results cannot be interpreted
•    Results will add no meaningful information
•    Someone simply wants the air quality tested

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Steps to do before testing air quality
•    Walk through the building using your eyes, nose, and common sense to identify potential problems.
•    Look at general cleanliness (or lack thereof) in each of the areas you inspect.
•    See if building services can substitute cleaning agents that have less of an odor (“low emitters”) than the stronger odor-producing ones that may be in use.
•    Take note of where carpeting is used. How is it cleaned, and how often? Does it ever get wet from flooding, roof leaks, etc, and if so, how quickly is it dried out?
•    Walk around outside of the building and look for potential pollution sources.
•    Look for locations of fresh air intakes and exhausts. Are they too close together, allowing exhaust air to be sucked back into the building via the intakes? Are the intakes located near dumpsters or where busses, trucks or cars idle?
•    Look at how the building is set on the land. Does the land slope downward towards the building, allowing rainwater to pool along the foundation? Is the building located on former swampland or landfill? Is there a high water table or underground stream under the building? Is landscaping too close to the building?
**Most of the time, a building assessment should be enough to identify basic problem areas. Once these areas have been identified, you then may decide to call in the professionals.**

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As an additional first step, there are things you can do yourself:
•    Develop proactive risk communication
•    Do routine scheduled maintenance, especially on HVAC (heating, ventilation and air conditioning) systems
•    Remove pollution sources
•    Substitute low emitting products whenever possible
•    Fix all leaks promptly!
•    Remove and discard all porous materials damaged by water. This includes ceiling tiles, carpets, furnishings, and even wallboard.

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Indoor Environmental Testing Can be Beneficial
Once a problem has been identified, the solution may be unclear. There are many solutions, and air sampling may be one of them. Other important steps to fixing the air quality problem will include:
•    a building walk through
•    taking a history of the building and any past and present maintenance problems
•    history of building usage and land usage on the property and surrounding neighborhoods
•    review of architectural and mechanical blueprints
•    interviewing maintenance staff
•    anything else that would add information about the physical structure of the building and the activities that go on in and around the building.
•    interview the building occupants. Ask for their help in identifying problem areas.
When all of the practical steps and investigations described above have been conducted, there may be a place for air testing. Air testing may be used to confirm or refute a highly suspected source that is uncovered during the walk-through inspection.

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Air testing is most useful when a specific contaminant or contamination source has already been identified as a likely culprit, and quantitative data are needed to:
•    Document the degree or extent of the hazard, or
•    Document different locations in a building where elevated levels or severe conditions exist.

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Air testing may also be useful in a qualitative manner when trying to differentiate between several suspect chemicals or sources.

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Indoor air testing may be useful when:
•    It is part of an overall evaluation
•    When the data is interpretable
•    When the data has a descriptive component that helps to illustrate its place in the overall evaluation
•    NEVER alone

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After completing the steps above, you may find it necessary to hire one or more professionals. It is important to remember that varied problems may require more than one type of specialist.

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When You Have To Call In A Consultant
•    Discuss the problem with your local health director, and enlist their help with risk communication to all of the people involved. He/she may also be able to help you select the right kind of consultant for the job at hand.
•    Review the American Industrial Hygiene Association (AIHA) consumer brochure:
Guidelines for Selecting An Indoor Air Quality Consultant. Go to
http://www.aiha.org/Content/AccessInfo/consumer/GuidelinesForSelectingAnIndo    orAirQualityConsultant.htm
•    Have a clear understanding of the problem, so that you can direct the consultant properly.
•    Make sure the consultant explains the scope of the project up front – what they can and cannot do. Communicate this to all of the people involved so they will have a realistic expectation about the process.

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Source: Indoor Air Quality Testing Should Not Be The First Move. 1 August 2006. Connecticut Department of Public Health-Environmental & Occupational Health Assessment Program. 4 July 2009. http://www.ct.gov/dph/lib/dph/environmental_health/eoha/pdf/ieq_testing.pdf

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Some resources for air quality testing & air cleaning devices

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•    U.S. EPA – Guide to Air Cleaners in the Home
http://www.epa.gov/iaq/pubs/airclean.html#How%20is%20the%20Performance%20Measured
•    U.S. EPA – The Inside Story: A Guide to Indoor Air Quality
http://www.epa.gov/iaq/pubs/insidest.html#Suspect
•    Health Goods – Indoor Air Quality Testing (an example of some air quality testing kits)
http://www.healthgoods.com/shopping/Home_Test_Kits/Indoor_Air_Quality_Testing.asp
•    American Industrial Hygene Association (AIHA) – Guidelines for Selecting an Indoor Air Quality Consultant (a great resource explaining how to: investigate problems, determine scope of the problem, locate sources of chemicals and allergens, looking for HVAC problems, when to call a professional, types of IAQ testing professionals, how to find the best consultant, and steps for solving IAQ problems)
http://www.cal-iaq.org/guide_aiha_9901.htm

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