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EPA: Its Role and Product Registration |
By Stan Halpern
Environmental Cleaning Consultant |
Editor's note: I have always been confused as to what the EPA is supposed to do and what EPA registration on a product means. Stan Halpern, an Environmental Cleaning Consultant,from Healthy Clean Buildings,straightened me out recently. I hope this clears up any confusion for you too.
| Q. |
What
is the EPA's role in registering "environmentally-safe" products?
"I am never quite sure what the EPA mean by "environmentally-safe"
since I bought one product that was EPA registered and it could kill
you if you had direct physical contact! Since a number of people who
we cater to have MCS in a mild or severe form - my rule of thumb is
if you can ingest it and not be sick then it should be OK! |
| A. |
Let
me clear this confusion up for you...
The U.S.
Environmental Protection Agency was established as an independent
federal agency on December 2, 1970. It's mission is to protect human
health and to safeguard the natural environment--air, water, and land--upon
which life depends. This agency (EPA) endeavors to accomplish its
mission systematically by proper integration of a variety of research,
monitoring, standard-setting, and enforcement activities. As a complement
to its other activities, EPA coordinates and supports research and
anti-pollution activities of State and local governments, private
and public groups, individuals, and educational institutions. EPA
also monitors the operations of other Federal agencies with respect
to their impact on the environment. |
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| Q. |
What
is the purpose of the EPA? |
| A. |
The
EPA's purpose is to ensure that:
All Americans are protected from significant risks to human health
and the environment where they live, learn and work.
- National
efforts to reduce environmental risk are based on the best available
scientific information.
- Federal
laws protecting human health and the environment are enforced
fairly and effectively.
- Environmental
protection is an integral consideration in U.S. policies concerning
natural resources, human health, economic growth, energy, transportation,
agriculture, industry, and international trade, and these factors
are similarly considered in establishing environmental policy.
- All
parts of society--communities, individuals, business, state and
local governments, tribal governments--have access to accurate
information sufficient to effectively participate in managing
human health and environmental risks.
- Environmental
protection contributes to making our communities and ecosystems
diverse, sustainable and economically productive.
- The
United States plays a leadership role in working with other nations
to protect the global environment.
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| Q. |
What
about Product Registration? |
| A. |
ANY
PRODUCT WHICH MAKES CLAIMS TO KILL ANY LIVING ORGANISMS,
such as insects (insecticides), bacteria (disinfectants), algae (algaecides),
mold & mildew (fungicides), weeds (herbicides); and so forth, MUST
be registered with the federal E.P.A. An E.P.A. registration number
has absolutely NO BEARING on being "Environmentally-Friendly" or "Environmentally-Safe"
( especially, in terms of allergies or multiple chemical sensitivities)
from product usage IF THE INGREDIENTS OF THE PRODUCT ARE DEEMED LEGAL
TO USE BY THIS AGENCY. These pesticides, according to the printed
label, indicate the best way to reach, dispose, and apply the registered
product against targeted pests. Lets take an example: everyone knows
that household bleach is generically 5.25% (by wt.) sodium hyperchlorite.
If the bleach product is registered with the E.P.A. (like "CLOROX"),
it can make claims regarding sanitizing or disinfecting surfaces against
(killing) bacteria, according to the label usage, based upon this
registration. However, if the bleach product is unregistered with
the E.P.A. (such as private label supermarket bleach), it can ONLY
make claims of "cleaning" and "whitening" although generically the
chemical make-up is exactly the same. Without the E.P.A. registration
number on the package, no statements or product performance regarding
the lowering of bacterial counts or "killing bacteria" on hard surfaces,"sanitizing",
"germicidal" or "disinfecting" can be made by the same chemically
formulated product. This may sound confusing, so here's an example:
A restaurant knows it must sanitize its cooking utensils according
to health laws in its daily operations. Bleach is referred to as the
"universial sanitizer". The owner purchases "the cheap" bleach off
the supermarket shelf without an E.P.A. registration number for such
purpose. Weeks later, a Board of Health inspector notices this type
of bleach being used and fines the restaurant for "non-compliance"
of health laws since no sanitizing claims on the label are made by
the bleach being used. Although the restauranteur argues that the
chemical make-up is the same as "CLOROX", he/she has no recourse with
the health authority since an unregistered product cannot make any
bacterial "kill" claims... THEREFORE, , AN EPA REGISTRATION NUMBER
HAS NO BEARING ON THE TOXICITY OR HAZARDOUS INGREDIENTS OF A PRODUCT.
IT JUST MAKES A "KILL" CLAIM OF A LIVING ORGANISM BASED UPON THE INGREDIENTS
OF THE PRODUCT AND PROPER USAGE ACCORDING TO LABEL DIRECTIONS. Words
like "environmentally-friendly" and "environmentally-safe" are sales
and marketing hype terms to make a product SOUND as if it is "safe"
and "healthy" to use. |
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| Q. |
So
what does Biodegradable mean? |
| A. |
I
am sure that you have heard the term 100 percent completely biodegradable.
(the ability of a product to breakdown completely and its component
return to the environment without polluting it) Did you know that
pure sulfuric acid is completely 100% biodegradable? (not the healthiest
or safest of products to have around). Some products making this claim
completely biodegrade in 30 years (to the unknowing consumer). With
an "environmentally-preferable" product, more than half should biodegrade
within 28 days with the balance within a few months after its application
to be safe and healthy. |
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| Q. |
What
are environmentally preferable products? |
| A. |
Here's the thorough explanation of the background of "environmentally-
preferable":
In February 1993, Public Building Services (PBS) of the federal government's
General Service Administration (GSA) began the "Cleaning Products
Pilot Program". At that time, the objective was to identify specific
"ENVIRONMENTALLY-PREFERABLE"( the only viable, legally-binding environmental
cleaning chemical term assigned by the federal (and state) governments
for products with credentials regarding testing/performance criteria
and impact on the environment and health/safety of individuals) cleaning
products with reduced health and safety concerns for use in cleaning
over 7,000 federal buildings. Up to that date, most of the publicly
available environmental information on products consisted of UNSUBSTANTIATED
VENDOR CLAIMS OR "HOME REMEDIES" ( with descriptions like "Environmentally-Friendly"
and "Environmentally-Safe"). PBS officials wished to define and identify"
green" cleaning products. Product usage was chosen as the key focus
for assessment since it was indicative for the greatest direct health
risk from the cleaning products to custodial workers to occupants.
Consequently, specific environmental attributes were identified to
help assess the environmental preferability of commercially available
cleaning products (OR THE INACCURATE DESCRIPTION, "ENVIRONMENTALLY-SAFE"
which really should be described ONLY as "Environmentally-Preferable"
as defined by the federal and state government with such programs.).
These attributes are:
1) Skin irritation potential;
2) Chronic health risks from skin and inhalation exposure;
3) Quickness of ultimate biodegradation;
4) Accumulation Factor (Bio-Concentration Factor of an ingredient
to accumulate into the food chain
5) Percentage of V.O.C.(volatile organic compounds) which increases
the potential for offgassing
6) Amount of product packaging waste;
7) Presence of ozone depleters;
8 ) Dispensing Method in regards to potential exposure to concentrated
cleaning solutions;
9) Degree of flammability;
10) Amount of cosmetic additives (fragrances and dyes); and
11)Impact on energy requirements.
These 11 standards and criteria established the ONLY basis for "environmentally
GREEN preferable" cleaning products. Presently, there are ONLY 5 states
which have a statewide "ENVIRONMENTALY PREFERABLE CLEANING PRODUCT"
Purchasing Program (California, Massachusetts, Minnesota, Delaware,
Maryland). These states even have more stringent criteria for their
definition of "environmentally-preferable" based on the 1993 federal
guidelines. The cornerstone of our "HEALTHY CLEAN BUILDINGS' cleaning
program-H2Orange2-is the frontrunner in the Massachusetts "Environmentally-Preferable"
Cleaning Products Purchasing Program. ALL participating end-users
adopting OUR "environmentally-preferable" cleaning program have removed
minimally 8 "toxic or hazardous" substances from its cleaning operations
or MORE; reduced 90 % of the different amounts of cleaning products
used; created a NEW "Environmental Guardian" mindset for administrative,
departmental, and custodial staffs towards their indoor work environments
(versus the conventional janitor or custodian labels ); and improved
cleaning standards through a simpler, easy-to-understand, more practical
cleaning program. End-users involved in this program are reporting
a minimum of 15% (or better) savings in their cleaning supply budget
through the elimination of the multitude and duplication of products
previously being used. Additionally, this program addresses controversial
indoor environmental issues such as "Sick Building Syndrome"; "I.A.Q.
(Indoor Air Quality); "Multiple Chemical Sensitivities" (MCS); allergic
triggers; and other similar ' building occupant' concerns. |
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| Q. |
What
do you suggest are the criteria for "Environmentally-Preferable cleaning
programs in commercial, school, and public buildings; and homes? |
| A. |
"End-user
requires a proven, field-tested "HEALTHY & SAFE" Building Chemical
Cleaning System which utilizes a maximum of only 2 chemical components
to daily clean an entire facility, or their home. The goals and
objectives of this program is to improve indoor air quality and
limit building occupants', especially children's and custodial worker's
exposure to chemical residues by replacing, reducing, or eliminating
existing, conventional, more "toxic" and "hazardous" cleaning chemicals
with healthier, safer, and environmentally-sensitive alternatives."
IN ANY EVENT, ANY CLEANING SYSTEM DEEMED OFFICIALLY "ENVIRONMENTALLY-PREFERABLE"
(OR UNOFFICIALLY "ENVIRONMENTALLY-FRIENDLY" -OR-"ENVIRONMENTALLY-SAFE")
MUST MEET OR EXCEED ALL OF THESE STANDARDS AND CRITERIA
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This system, wherever applicable, MUST be EPA registered as a
disinfectant, sanitizer, and/or virucide.
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This system, wherever applicable, MUST be registered with the
particular state's Department of Environmental Conservation as
a disinfectant, sanitizer, and/or virucide.
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This system must comply with ALL standards and criteria set forth
by the 1993 federal guidelines established by the Public Buildings
Service (PBS) of the General Services Administration (GSA) known
as the "Cleaning Products Pilot Project" to identify specific
"environmentally-preferable" cleaning chemicals with reduced health
safety concerns.
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This system must be contracted and accredited as "environmentally-preferable"
for cleaning under a state purchasing division attesting to having
such a state-wide environmental program.
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This system must be recognized and listed by an environmental
organization, such as "GREEN SEALS", as recommended for commercial
cleaning. (Both of our system's components-H2Orange2 and A-Ben-Aqui
are both "GREEN SEALS" recommended).
(**Contracted as "Environmentally-Preferable" as a cleaning product
by the State of Massachusetts---Listed by "Green Seals" as a recommended
cleaner.)
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This system must comply with the 1999, jointly-published guideline
"HEALTHIER CLEANING & MAINTENANCE: PRACTICES AND PRODUCTS FOR
SCHOOLS" by the Healthy School Network and the New York State
Association for Superintendents of Buildings and Grounds.
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The system must have the capabilities of being automatically dispensed
to guarantee proper usage and so custodial DO NOT have to directly
handle products, wherever applicable. In the event that products
meet all of the standards and criteria stated above, then, and
only then, can be it deemed OFFICIALLY as "environmentally-preferable"
(or unofficially "environmentally-safe" or "environmentally-friendly").
If not, then the environmental terms attached to the product is
nothing more than sales and/or marketing hype.
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STAN
HALPERN is an environmental cleaning consultant for over 28 years.
He advises facility directors, professional cleaning contractors,
homeowners, and 'do-it-yourselfers' with their cleaning problems each
and every day. As an environmental cleaning consultant, he takes great
pride in recommending responsible "environmentally-preferable" solutions
to facility managers in commercial, school, and public buildings regarding
the healthiest and safest ways to address cleaning and maintenance
problems in their buildings. |
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LAURI
HALPERN, Stan's wife, is President and sole owner of "HEALTHY CLEAN
BUILDINGS"-dedicated to "safe cleaning products that care". |
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Click
for more about Healthy Clean Buildings products |
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HEALTHY
CLEAN BUILDINGS
4 Wilmington Drive,
Melville, New York 11747
telephone: 631-643-1882
Web:www.cleaningpro.com
E-mail: cleaning@fnol.net
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All Rights Reserved.
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