As seen on ISSA.com. 

The first round of public voting on proposed revisions to the Green Seal Environmental Standard for Institutional and Industrial Cleaning Products (GS-37) has concluded, and Green Seal has identified a number of contentious issues that will need to be resolved.

One of the major issues that has arisen relates to the proposed revision that would require concentrated products intended to be used in dispensing systems to meet the human health criteria in the concentrated form. Under the current GS-37, such products are allowed to meet the criteria in the diluted form.

Another related issue is Green Seal’s proposed revision to the term “concentrate.” As proposed, a concentrate would be defined as a product that must be diluted by at least 32 parts by volume of water—a 1:32 dilution ratio—prior to its intended use. Currently, GS-37 calls for a dilution ration of 1:8. This change in definition is particularly problematic for formulators of products packaged in portion control packs.

Another contentious issue relates to the proposed additions to the list of prohibited ingredients, such as phthalates and nitro-musks. Green Seal also has proposed limitations on the amount of d-limonene that may be present in cleaning products.

ISSA: AOEC Asthmagens List is ‘Inappropriate’

Green Seal’s proposed ban on asthmagens is based on a list published by the Association of Occupational and Environmental Clinics (AOEC). In comments filed with Green Seal, ISSA contended that the AOEC list is a poor indicator of asthmagens in the context of cleaning product formulations and therefore is inappropriate for the use Green Seal proposes.

Questions Posed

On a related note, Green Seal is actively seeking information regarding cleaning product formulations and product testing as indicated below. ISSA asks its formulator members to review the questions below and send your answers to ISSA Director of Legislative Affairs Bill Balek at bill@issa.com.

1. Scope:

Do you have any bathroom cleaners that are not FIFRA registered?

2. Concentration:

What concentration level do you use for each product category: bathroom, glass, general, and carpet (please indicate if these are closed-loop dispensing systems)?
 
What concentration level do you use for toilet-bowl cleaners?
 
What concentration level do you use for carpet-spot removers and  cleaners?
3. Performance:

What standardized methods do you use for carpet cleaners and carpet-spot removers, to determine cleaning efficacy and resoiling resistance?
 
Do you have a standardized soil that is more real-life than the one specified in ASTM D4488-95, A5 for general-purpose cleaners?
 
Do you use a standardized method for floor cleaners?
4. Dyes:

Do you use food-grade (FDA-certified) dyes?
 
Do you use natural colors?
 
Are there limitations of either of the two above color options?
Going Forward

Based on the comments received, the Green Seal Standard Development Team is expected to make additional revisions to the proposed revised GS-37 standard and release it for consideration and voting by the stakeholder community at large by April 4, 2008. Comments and votes on that draft proposed revised standard will be due May 30, 2008. Green Seal expects to release the final revised standard by June 6, 2008.