Green Regulations: Thou Shalt Not...

It isn’t easy being green. No one knows this better than the custodial managers who must wade through a sea of green products, cleaning procedures and practices to uncover the ones that make the most sense in their cleaning operations. Now green legislation, executive orders and guidelines have also entered the picture making it necessary for cleaning managers to define these laws in order to fully comply.

Ten years ago, it was difficult to implement green cleaning programs, states Mark Bishop, deputy director of the Healthy Schools Campaign, Chicago. But as the availability of effective products grew, so too did legislation and orders mandating sustainable cleaning practices.

On the federal level, President Clinton signed an executive order in 1998 directing federal facilities to adopt green products and practices when financially feasible. The states of New York and Illinois passed similar laws, in 2006 and 2007 respectively, requiring schools to take on green cleaning. The states of Maine and Missouri followed suit in 2008, enacting green cleaning guidelines.

Steve Ashkin, president of The Ashkin Group LLC and founder of the Green Cleaning Network, Bloomington, Ind., predicts at least 10 states will introduce comparable legislation in 2009. And municipalities are getting into the act as well with Racine, Wisconsin, becoming the first U.S. community to implement green practices in April 2008.

“We have literally just opened the doors on this legislation,” says Ashkin.

ISSA Legislative Affairs Director Bill Balek echoes this sentiment. “We as an association expect the trend of green cleaning to continue to be the focus of policies and legislation throughout 2009.”

The emergence of these laws — designed to ensure the practice of green cleaning to protect both the health of custodians and building occupants, as well as the environment — leaves custodial managers with a challenge. How do they incorporate these laws into their existing operations? And what are the consequences if they don’t?

Bishop says making sense of it all won’t be easy. “It will be interesting to see how states define green cleaning,” he says. “The answer to the question ‘What does green mean?’ isn’t necessarily getting easier. And the trends for state legislation, while helping states go green, may in fact make it more complicated in the long run.”

Law And Punishment

As custodial managers search for the answers to the questions above and struggle to implement green cleaning in their operations, Balek offers the assurance that these laws are not meant to be punitive in nature. In other words, there is time to add sustainable practices in a way that makes sense for the custodial operation.

He emphasizes that the laws strive to affect change on two levels. They first attempt to improve environmental profiles and operations at federal, state and local levels by requiring organizations to purchase and use environmentally preferable products and equipment. The hope then is that the private sector will begin to follow the government’s lead and emulate these programs in their own cleaning operations.

Ashkin, who helped author both the New York and Illinois legislation, maintains these laws endeavor to simplify green cleaning implementation in schools and other government entities. Most laws contain exemption clauses whereby if facilities can show they will incur a financial hardship by making the switch, they can opt out of doing it. The state of Illinois put such a clause in place, says Balek, who adds not a single school has filed a request to opt out with the state’s Lieutenant Governor’s Office.

Circumventing the laws may be a non-issue, however. To date no facility has been fined or tried for failing to adhere to green policies. But ISSA President Bob Stahurski adds he’s not surprised because the legislations’ purpose is not to punish, but to encourage green cleaning strategies that:

(1) Improve the environment,

(2) Lower costs to maintain facilities, and

(3) Provide healthier buildings for custodians and occupants.

“There really isn’t a fine or a check because green cleaning makes sense,” adds Renee Blanchard, campaign coordinator of the Child Proofing Our Communities Program at the Center for Health, Environment & Justice (CHEJ), an environmental advocacy group founded in response to the Love Canal environmental disaster.

To The Letter Of The Law

Following the letter of the law requires that cleaning managers review federal, state and local laws and regulations to fully understand what may be needed. The “Green Cleaning Product Procurement Policies, Initiatives and Requirements in the U.S.,” written by Balek (www.issa.com/greenprocure), is one source that can help custodial managers ascertain what laws already exist and what they mean.

Once they’ve done their homework, custodial managers must then devise a way to fulfill these requirements. CHEJ’s Green Flag Schools Program for Environmental Leadership is designed to help schools take on environmentally friendly policies and practices, including green cleaning. The program offers a tool to assess a facility’s environmental impact. This is an excellent place to start when adopting green cleaning, says Blanchard. CHEJ also teams with other organizations, such as INFORM, which offers a chemicals checklist and guide for facility managers. In addition, the center provides walk-throughs to assess the green cleaning operation.

Audits typically uncover hundreds of opportunities for improvement, especially when one considers that many custodial operations utilize 50 or more cleaning products. But at the end of the day, Ashkin points out cleaning managers and their bosses need to know how much these changes will cost. He recommends considering each opportunity and putting it in one of three “buckets.” On the one extreme will be a bucket for changes that are tremendously expensive, on the other extreme will one for cost neutral or money saving strategies, and then there will be a bucket for everything that falls in between.

“We have to find a way to efficiently get a handle on what’s going on and build a plan,” Ashkin explains. “Putting every opportunity into one of three buckets helps custodial managers build a plan, because the things that are easy to implement, cost effective or cost neutral are the areas they can start on first.”

Ashkin then advises pairing with suppliers, who can be an outstanding resource when adopting sustainable practices. He recommends seeking help from those suppliers best poised to provide the assistance an operation needs.

“Everyone can drop off a box of Green Seal-certified chemicals to your loading dock,” he says. “But who can help you do the audit? Who can help you build the plan? Who can help you train your people? Who can communicate what’s going on to building occupants or the community? That’s the kind of stuff that will be incredibly valuable from a supplier.”

When weighing suppliers, Blanchard also recommends seeking more than a Green Seal or EcoLogo label signifying green certification and selecting a manufacturer who makes a minimal number of more toxic products. Many companies manufacture a green product line, she explains, but offer toxic chemical product lines as well.

“I think it’s important to support companies that mainly offer green products,” she says. “When you purchase a toxic chemical, the community is being harmed as well as your own home or office. It’s critical to look at the big picture.”

Cleaning For Health

ISSA’s Stahurski reminds that green cleaning encompasses the science of cleaning for health, not just incorporating sustainable products into a cleaning operation.

“Products are only part of the problem,” he emphasizes. “The other part is the processes and procedures.” Custodial supervisors, he says, must review the tasks being performed, how they’re currently being executed and their impact on the indoor environment of that building.

Unfortunately, cleaning operations generally use too many products far too often, Blanchard adds. Consider disinfectants. There really isn’t a good, nontoxic disinfectant but frequently these products are incorrectly or overused, she says.

“Custodians often use disinfectants as general cleaners,” she explains. “But you are supposed to clean the surface or spill with a general cleaner first then apply the disinfectant just to the most hazardous areas.”

Environmentally friendly cleaning entails reducing the consumption of cleaning products overall, whether an operation uses green or more traditional products. Reducing their chemical footprint may require that cleaning operations incorporate things such as microfiber, which doesn’t always require the use of chemicals; dilution systems that control the amount of water used and chemicals dispensed; or mats before and after entrances to minimize the dirt tracked inside.

Because green products may have different use patterns, education and training also becomes an important piece of the legislation-abiding puzzle. For instance, these chemicals may require more elbow grease, additional dwell time, different dilution ratios or the use of a new dilution system. Green cleaning legislation varies as to whether it’s mandatory or recommended to train employees in these newer cleaning practices. But regardless of whether state law requires it, Balek advises having manufacturers or distributors provide the training anyway.

“No matter what product you use, whether it is a green cleaning or traditional product, it’s crucial they be used as recommended by the manufacturer,” Balek points out.

As green cleaning moves forward, Stahurski stresses custodial operations also must re-define what it means to be clean.

“We’ve cleaned for appearance for a long time, but what does it mean to clean for the health of occupants?” he asks, noting the answer to this question will help reduce consumption and make buildings healthier overall.

Fortunately, green cleaning legislation helps pave the way to an answer. As Ashkin says, “The real goal of green cleaning is to create healthy, high performing buildings that minimize our impact on the environment.” And that’s exactly what these laws strive to do.

Leigh Hunt is a freelance writer based in the Milwaukee area.