18-0719 v3.1/Giant Panda Exhibit, Calgary Zoo/Alternative Cleaning Product Standards
Regarding LBC 3.0 I08 - Healthy Indoor Environment Plan, Cleaning Product List objective:
Our LBC project is located in Canada, and as such, cleaning products sold here are not under the jurisdiction of the US EPA's Safer Choice program. We are seeking approval of an alternative compliance methodology for Canadian (and other non-US) projects via complying with Underwriters Laboratories' EcoLogo standards.
Other green building rating systems such as LEED v4 O&M and WELL v1 2018Q1 allow non-US projects to use any Type 1 eco-labeling program as defined by ISO 14024: 1999 developed by a member of the Global Ecolabelling Network to show their cleaning products comply. This allows for greater flexibility in choosing potential cleaning products, potentially reducing increased shipping and packaging impacts by selecting a more locally-produced or concentrated cleaning product.
For example, for our project to meet the Imperative requirements by purchasing EPA Safer Choice certified cleaning products, the cleaners would need to switch from purchasing concentrated cleaning products to un-concentrated cleaning products. This will create additional waste, from both a packaging and logistics perspective - extra smaller bottles in cardboard boxes being shipped more frequently. This does not align with project goals.
The team has noted that there is an existing LBC exception that approves the Environmental Choice New Zealand standard for use in lieu of the EPA's Safer Choice program. This NZ standard is also referenced as an equivalent ISO 14024: 1999 Type 1 ecolabel to the EPA Safer Choice program in both LEED and WELL.
On these grounds, we request that an equivalency be granted to allow other ISO 14024: 1999 Type 1 ecolabel programs, such as the UL EcoLogo program, to be used to show compliance with the Cleaning Product List objective.
- prioritize products with "prohibited components" and "toxicity" information, and
- advocate to UL to require ingredient transparency on all eco-labels similar to the EPA Safer Choice standard. See https://www.epa.gov/sites/production/files/2015-02/documents/ingredient_disclosure_guidance.pdf
Post ID 7066