2006 Response to Comments

The public comments received by May 19, 2006 on the Green Cleaning Proposed Guidelines and Specifications on the Procurement and Use of Environmentally Sensitive Cleaning and Maintenance Products for all Elementary and Secondary Schools in New York State have been reviewed. We would like to thank each and every one of you who took the time to provide public comments.

Based on our review of all comments, we developed groupings of similar comments, which we called categories. We then created a heading or title for each category, provided our response to that category, and attached all associated or related comments. Below you will find a Table of Contents that lists all 54 categories. Please find the category you wish to view and click on it. You will be linked to that specific category, which will be followed by the response, then by all the related comments.

The Guidelines do not adequately protect children’s health — Protect Children's Health
OGS should accept products listed or certified by other organizations and not rely solely on the Green Seal standards — Cleaning Product Certification
The Guidelines should require the use of non-toxic (bio-based) cleaning products — Non-Toxic Cleaning Products
The Guidelines need to address the use of cleaning products with fragrances — Fragrances
Products must not contain compounds that persist or bio-accumulate in human or animal tissue or in the environment –- Bioaccumulating
The VOC (volatile organic compound) levels should be changed in the Guidelines — VOC's
Cleaning products contained in Single use Aerosol Cans or those with ozone depleting propellants should not be used — Aerosol Cans
Cleaning products should not contain compounds that contribute to Atmospheric Greenhouse Gases, Ground Level Smog or Ozone Depletion — Gases Ozone
The Guidelines do not adequately address ingredients that may be potential carcinogens, teratogens, mutagens or endocrine disrupters — Carcinogens
Cleaning products should not contain Nonyl Phenol Ethoxylates (NPE) or Alkyphenol Ethoxylate (APE) — NPE's and APE's
For all cleaning products, the water supply should be purified and free of chlorine and residual chlorine — Chlorinated Organics
Cleaning products should not contain chlorine, chlorinated or brominated solvents — Solvents
The Guidelines should not allow the use of cleaning products that contain heavy metals that are toxic to humans, animal life or the environment — Heavy Metals
The Guidelines should limit phosphate cleaning product compounds — Phosphates
Safety provisions are necessary for the use of cleaning products and should meet federal wellness policy — Product Safety
The Guidelines should limit the use of cleaning products that contain air fresheners and or fragrances — Air Fresheners
The Guidelines should contain specific criteria covering floor care products which are safe to use or proven to be effective — Floor Care
The Guidelines should require supplier disclosure of cleaning product ingredients — Supplier Disclosure
Caution is needed with any partnering with “Consultants” with implementation of the Guidelines — Consultants
A rigorous Quality Assurance/Quality Control program should apply to all cleaning products — Quality Assurance
The Guidelines should require raw material product suppliers to certify their materials — Raw Material Certification
Cleaning products testing should conform to American Society for Testing Materials standards (ASTM) — ASTM Standards
OGS guidelines should specify the use of products that are non-toxic or have the lowest level of toxicity — Low Toxicity
The list of approved cleaning products should identify environmentally safe cleaning product cost competitiveness with traditional cleaners — Cost Effectiveness
The Guidelines should require companies to provide cost information for their products on the approved product list — Cost Information
Guidelines should group cleaning products according to a Tier Level listing (Tier I - General Cleaning Products; Tier II - Floor Care Products; and, Tier III - Sanitizer and Disinfectant Products) — Product Tiers
The use of cleaning products should be non-corrosive to skin or inanimate surfaces — Non-Corrosive Products
The use of petroleum distillate based cleaning products should be limited — Petroleum Products
Cleaning products should be non-combustible below 150 degrees F — Non-Combustible Products
Automatic dispensing systems should be utilized for cleaning products — Automatic Dispensing
The Guidelines should examine the use of Electrolyzed Oxidative Water for safer cleaning — Oxidative Water
The Guidelines should require the use of cleaning products and processes that reduce asthma triggers — Asthma
The Guidelines should address the use of cold water versus hot water cleaning — Hot Cold Water Cleaning
The Guidelines should examine the need for cleaning product efficacy testing and its relationship to the Green Seal certification process — Product Efficacy Testing
The Guidelines should include other testing standards as a way to certify vacuum cleaners — New Cleaning Technology
The Guidelines should allow preferred source purchasing — Preferred Source Purchasing
The Guidelines should restrict the use of disinfectant/sanitization cleaning products — Restrict Disinfectants
The Guidelines should address the use of hands soaps — Hand Soap
Several of the Best Management Cleaning Practices need to be modified — Best Management Practices
The Guidelines should address the use of paper products — Paper Products
The Guidelines should allow for the addition of new products to the sample list of approved cleaning products — New Products for Sample List
The September 1, 2006 implementation date of the Law should be extended — School Implementation Date
The Guidelines should reduce the burden on the Laws required school reporting requirements — School Reporting Requirements
The State should develop advanced custodial cleaning practices — Advanced Cleaning Practices
Changes are needed to the Guideline Appendices — Guideline Appendix Changes
Investigate the use of new green cleaning technology and equipment — New Cleaning Equipment
The Guidelines should define “cleaning” — Define Cleaning
The Guidelines should contain other cleaning technology considered to be equally beneficial and effective as their chemical counterparts — Beneficial Cleaning Technology
The Guidelines should address the need for lab testing and the use of out-of-state testing laboratory certified cleaning products — Out of State Product Testing
The Guidelines should require the use of recyclable cleaning packaging and not require products to be used in concentrated form — Recyclable Packaging
The Guidelines should address other products used in schools — Use of Other Products
Guidelines formatting, changes and related public comments — Guideline Changes
The Guidelines should be amended to include additional information on Cleaning Product Category and Definitions Section for General purpose cleaners, floor finishes and floor strippers, and carpet and vacuum cleaners — Cleaning Product Categories
The Guidelines should eliminate the cleaning product self-certification process — Self-Certification of Products