- THE MAGAZINE
Out of the 101 votes cast, 53 voted in the negative thereby rejecting the latest iteration of the proposed revisions to GS-37. Moreover the ballots submitted by registered stakeholders revealed that there was “sustained opposition” on a number of key aspects of the draft revisions to the environmental standard for cleaners. As such, Green Seal must now work with stakeholders to resolve these issues before it can finalize the standard. Given this scenario, it is estimated that GS-37 may not be finalized until August 2008.
ISSA voted in the negative on GS-37, and in its comments raised concerns including but not limited to the handling of asthmagens, dispensing control systems, VOC limits and concentrates.
ISSA encourages member companies to remain engaged in the process of revising GS-37. Continued participation will be critical if industry is to prevail on those issues around which sustained opposition exists.
A review of the summary of comments received by Green Seal along with the GS-37 ballots revealed that the following issues were the most contentious:
- 1. Asthmagens. A significant number of comments objected to Green Seal’s continued reliance on the AOEC list of asthmagens as the basis for prohibiting certain ingredients from being included in cleaning product formulations. These comments invariably noted that reliance on the AOEC list was inappropriate because it was never intended for such a purpose. Rather the AOEC list is part of an epidemiology tool for developing a database for occupational exposures. The AOEC does not identify known agents that cause asthma; instead it provides a reference for clinics to gather information to be compiled into an occupational database.
- 2. Respiratory Irritants. Green Seal received a number of comments objecting to the definition of respiratory irritants as overly broad, recommending instead that it adopt the definition used in the Globally Harmonized System for Hazard Communication (GHS). In addition, commenters took issue with the limitations placed upon allowable concentrations of d-limonene and terpene hydrocarbons, noting the lack of scientific basis for regarding these substances as respiratory irritants.
- 3. Dispensing System Concentrates. Non-governmental organizations and others continue to raise concerns over Green Seal’s proposed approach to dispensing system concentrates, which would allow such products to be tested “as used” as opposed to in its concentrated form in regard to a number of health and environmental criteria.
- 4. Prohibited Ingredients. Significant objections were raised concerning Green Seal’s proposed approach to prohibiting heavy metals (as a neurotoxin), 2-butoxyethanol (as a systemic toxin), and phthalates (as an endocrine disruptor).
- 5. VOC Content. Proposed VOC content limitations were also the subject of significant comments in the voting process. One camp pointed out the inconsistencies in the calculation of VOC content between the summing approach that exempts low vapor pressure VOCs, and California Method 310, which does not allow for such exemptions. In addition, industry representatives continued to urge Green Seal to set limits consistent with the California Air Resources Board.
- 6. Chronic Inhalation Toxicity. This subject was the source of quite a bit of discussion by commenters, a number of which called upon Green Seal to continue to pursue an exposure modeling approach that was floated about a month before the voting closed on GS-37. Industry opposed that approach because it surfaced late in the process and is far too complex to adequately address in the short time frame necessitated by the GS-37 revision process.
Steps Going Forward
In order to finalize its revisions to GS-37, Green Seal will work with the various stakeholders in an effort to seek resolution on these and other areas of concern. In addition to working with individual stakeholders, Green Seal plans to reach out to the stakeholder committee, the standard development team and engage the broad stakeholder community for the purpose of carving a path forward.