The American Cleaning Institute (ACI) is active in states that have a legislative, regulatory or executive mandate on cleaning product procurement in a given jurisdiction.
ACI has been substantially engaged in environmentally preferable procurement issues. ACI is recognized for its contributions in many areas including standards development, and work with the U.S. Environmental Protection Agency (EPA) on developing its environmentally preferable purchasing guidance. ACI encourages market-based approaches and solutions that address environmental and state procurement issues.
March 14, 2017 – ACI comments to U.S. Department of Agriculture, Office of Procurement and Property Management, on Designation of Product Categories for Federal Procurement
ACI shared comments with USDA on the Department’s plans to include chemical intermediates within the USDA BioPreferred program. Specifically, this would add 12 sections that will designate the product categories within which biobased products would be afforded procurement preference by Federal agencies and their contractors.
"The designation of substances into the proposed twelve ‘product categories’ appears to be arbitrary as the categories range from very narrowly defined groups to extremely broad categories," wrote ACI’s Kathleen Stanton. "The scope of some of these categories falls outside the USDA definition of a ‘product category’ - a grouping of specific products that perform a similar function. ACI recommends categorizing intermediates based on functional use descriptions. In addition, as noted by USDA in the public notice, the analytical method (ASTM standard D6866) by which all the products in the BioPreferred Program is measured is imprecise. ACI recommends that a validation study be performed in order to better understand the ranges of inaccuracies across a number of intermediates and products."
May 5, 2015: In making changes to the EPA’s Safer Product Labeling Program – formerly Design for the Environment – the agency has disregarded a number of guidelines related to the process of developing standards, measuring their environmental effectiveness, and managing the standards programs, according to ACI. View our complete comments here.
- View archived state activities (ACI Members Only)
- Any legislative intent language must be proactive and recognize the essential benefits of cleaning products. Environmentally preferable cleaning products are market ready and available for widespread application in any and all state facilities and buildings.
- States should recognize the benefits of antimicrobial hand products for their intended uses.
- States should promote innovation by recognizing flexibility in environmentally preferable product procurement criteria. Environmentally preferable procurement cannot reasonably be defined by a single set of criteria or certification by a single non-governmental organization because of the dynamic nature of the preferable procurement issue.
- Within the procurement process, products should be considered based on an assessment of performance and environmental attributes that reflect the values and needs of the purchaser.
- Drawing on the EPA Guidance on Environmentally Preferable Purchasing, factors such as product safety, efficacy, ease-of-use, availability and cost must be given equal weight when examining the environmental characteristics of any particular product.
- Work to advance cleaning product manufacturer interests using life cycle analyses, self-certification language or industry-recognized third-party standards and processes to manage legislative and regulatory activities consistent with the official definition of EPP in federal Executive Order 1301, 1998.
- No delegation of procurement decisions to any single third-party non-governmental organization; there should be no lists of "safer" or "green" products. Such lists are likely in conflict with Federal Trade Commission (FTC) authority to validate and review the claims made for consumer products.
The American Cleaning Institute (ACI) supports the hazard and exposure based risk assessment as the key principle of safety assessments of cleaning and detergent products and ingredients. This approach has been the foundation of ACI’s scientific work for decades. ACI does not support ingredient or product assessments and ranking schemes that would in one way or another compromise this underlying principle.
As such, ACI will support the development of EPP schemes and standards at the local, national, or Federal levels that are in line with the above mentioned principle, EPA criteria and definitions of EPP that comply with this principle, and FTC guidelines for environmental marketing claims. Specifically:
Sound science and hazard/exposure based safety assessment (underlying ACI and member companies’ principle)
Environmental and Health Benefits based on all stages of product life cycle (Official definition of EPP in Executive Order 13101, 1998)
Holistic approach with consideration of environmental factors along with other product benefits such as performance (EPA Guidance on Environmentally Preferable Purchasing)
Accurate and meaningful information (EPA Guidance on Environmentally Preferable Purchasing)
Official guidelines for environmental claims (FTC Guides for the Use of Environmental Marketing Claims)
Reportable indicators across all relevant areas (AISE Sustainability Charter)
Open to continued innovation and flexibility
Agreed EPP principles should be consistent between the I&I and retail product sectors
Pass/fail criteria based on limited endpoints (e.g. ready biodegradation, acute toxicity cut-off levels)
Hazard-based only criteria
Targets addressing limited/narrow endpoints (e.g. amount of non-biodegradables per use)
Discrimination of certain ingredients, products and product categories based other than on sound scientific principles
Claims of environmental attributes unless based on sound science, compliant with FTC and EPA guidelines