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.


Table of Contents
  1. The Guidelines do not adequately protect children’s health — Protect Children's Health
  2. OGS should accept products listed or certified by other organizations and not rely solely on the Green Seal standards — Cleaning Product Certification
  3. The Guidelines should require the use of non-toxic (bio-based) cleaning products — Non-Toxic Cleaning Products
  4. The Guidelines need to address the use of cleaning products with fragrances — Fragrances
  5. Products must not contain compounds that persist or bio-accumulate in human or animal tissue or in the environment –- Bioaccumulating
  6. The VOC (volatile organic compound) levels should be changed in the Guidelines — VOC's
  7. Cleaning products contained in Single use Aerosol Cans or those with ozone depleting propellants should not be used — Aerosol Cans
  8. Cleaning products should not contain compounds that contribute to Atmospheric Greenhouse Gases, Ground Level Smog or Ozone Depletion — Gases Ozone
  9. The Guidelines do not adequately address ingredients that may be potential carcinogens, teratogens, mutagens or endocrine disrupters — Carcinogens
  10. Cleaning products should not contain Nonyl Phenol Ethoxylates (NPE) or Alkyphenol Ethoxylate (APE) — NPE's and APE's
  11. For all cleaning products, the water supply should be purified and free of chlorine and residual chlorine — Chlorinated Organics
  12. Cleaning products should not contain chlorine, chlorinated or brominated solvents — Solvents
  13. 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
  14. The Guidelines should limit phosphate cleaning product compounds — Phosphates
  15. Safety provisions are necessary for the use of cleaning products and should meet federal wellness policy — Product Safety
  16. The Guidelines should limit the use of cleaning products that contain air fresheners and or fragrances — Air Fresheners
  17. The Guidelines should contain specific criteria covering floor care products which are safe to use or proven to be effective — Floor Care
  18. The Guidelines should require supplier disclosure of cleaning product ingredients — Supplier Disclosure
  19. Caution is needed with any partnering with “Consultants” with implementation of the Guidelines — Consultants
  20. A rigorous Quality Assurance/Quality Control program should apply to all cleaning products — Quality Assurance
  21. The Guidelines should require raw material product suppliers to certify their materials — Raw Material Certification
  22. Cleaning products testing should conform to American Society for Testing Materials standards (ASTM) — ASTM Standards
  23. OGS guidelines should specify the use of products that are non-toxic or have the lowest level of toxicity — Low Toxicity
  24. The list of approved cleaning products should identify environmentally safe cleaning product cost competitiveness with traditional cleaners — Cost Effectiveness
  25. The Guidelines should require companies to provide cost information for their products on the approved product list — Cost Information
  26. 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
  27. The use of cleaning products should be non-corrosive to skin or inanimate surfaces — Non-Corrosive Products
  28. The use of petroleum distillate based cleaning products should be limited — Petroleum Products
  29. Cleaning products should be non-combustible below 150 degrees F — Non-Combustible Products
  30. Automatic dispensing systems should be utilized for cleaning products — Automatic Dispensing
  31. The Guidelines should examine the use of Electrolyzed Oxidative Water for safer cleaning — Oxidative Water
  32. The Guidelines should require the use of cleaning products and processes that reduce asthma triggers — Asthma
  33. The Guidelines should address the use of cold water versus hot water cleaning — Hot Cold Water Cleaning
  34. The Guidelines should examine the need for cleaning product efficacy testing and its relationship to the Green Seal certification process — Product Efficacy Testing
  35. The Guidelines should include other testing standards as a way to certify vacuum cleaners — New Cleaning Technology
  36. The Guidelines should allow preferred source purchasing — Preferred Source Purchasing
  37. The Guidelines should restrict the use of disinfectant/sanitization cleaning products — Restrict Disinfectants
  38. The Guidelines should address the use of hands soaps — Hand Soap
  39. Several of the Best Management Cleaning Practices need to be modified — Best Management Practices
  40. The Guidelines should address the use of paper products — Paper Products
  41. The Guidelines should allow for the addition of new products to the sample list of approved cleaning products — New Products for Sample List
  42. The September 1, 2006 implementation date of the Law should be extended — School Implementation Date
  43. The Guidelines should reduce the burden on the Laws required school reporting requirements — School Reporting Requirements
  44. The State should develop advanced custodial cleaning practices — Advanced Cleaning Practices
  45. Changes are needed to the Guideline Appendices — Guideline Appendix Changes
  46. Investigate the use of new green cleaning technology and equipment — New Cleaning Equipment
  47. The Guidelines should define “cleaning” — Define Cleaning
  48. The Guidelines should contain other cleaning technology considered to be equally beneficial and effective as their chemical counterparts — Beneficial Cleaning Technology
  49. 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
  50. The Guidelines should require the use of recyclable cleaning packaging and not require products to be used in concentrated form — Recyclable Packaging
  51. The Guidelines should address other products used in schools — Use of Other Products
  52. Guidelines formatting, changes and related public comments — Guideline Changes
  53. 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
  54. The Guidelines should eliminate the cleaning product self-certification process — Self-Certification of Products