20-0226 Cleaning Product Equivalent for South Africa

QUESTION

Our LBC project is located in Cape Town, South Africa - and cleaning products sold here are not under the jurisdiction of the US EPA's Safer Choice program. Our project is therefore applying for approval of an alternative compliance methodology for South African projects via complying with the ecospecifier global Green Tag ™️ Certification and Rating scheme, which is a world first Life Cycle Analysis (LCA) based ISO compliant ecolabel and Environmental Product Declaration (EPD) scheme with Green Building Council accreditation as a third party certifier.

Ecospecifier guarantees to consumers and professionals alike that all key manufacturer health & environmental claims are third party verified and assessed in a rigorous, scientific manner using a Life Cycle Thinking (LCT) analysis in combination with the unique Ecospecifier Cautionary Assessment Process or ES CAP health and eco-toxicity screen that considers the impacts of composition down to 0.1-0.001% (ES CAP and Product Category Specific Standards ranges) using Australian, European, US Standards and others as appropriate, all under the ISO 9001 Certified Quality Management System.

More specifically, Green Tag verified products are compliant to the following:

ISO 14024 - Type 1 Ecolabel Rating system

ISO 14040 - Peer reviewed and audited LCA

ISO 14025 - Type 111 Environmental Product Declarations (EPDs)

ISO 14065 - Greenhouse Gas Analysis for Conformance Assessment Bodies

ISO 9001 - Certified Quality Management System.

There are a range of Rating Tools which formally recognize GreenTag, and this includes:

Global - WELL™, LEED ®, BREEAM® International (ISO 14025 EPDs), EarthCheck & Infrastructure Sustainability (IS) International Rating Tool, Green Globes
Australia - GreenStar® Rating Tools
Africa & New Zealand - GreenStar® Rating Tools, HomeStar® New Zealand
Governments' Recognition - Malaysian MyHIJAU, Singapore Green Mark International
Country Specific - LOTUS™ Vietnam, BEAM Hong Kong, EstidamaPearl Design Rating Scheme compliance (Abu Dhabi).

About Global GreenTag Cleaning Product Standard:

The GreenTag Cleaning products Standard was developed in accordance with expertise and input from a range of key organisations including EcoLAB, ACCORD (the Australian Cleaning Products Association that also operates the 'recognised' Cleaning Product certification Program), BCSA (the Building Services Contractors Association), Green Sash (cleaning services certification), 5 Star Healthy (cleaning services and products certification), National Cleaning Supplies Association, Tuwai Specialties Pty Ltd (applied cleaning product industrial chemist consultancy), The National Toxics Network, and the Apparel & Textiles Industries Group.

LCARate™ Marks (shown here combined with a GreenRate™ result) are US, Canada, Australia and South Africa registered Certifcation Marks that provide certified products with a tiered rating system, beyond typical 'pass/fail' ecolabels.

This deeply scientific process clearly indicates your product's detailed sustainability performance giving your customers easily understood performance claims and increasingly more product performance indicators as needed.

GreenTag Trust Mark Ratings are based on a weighted average of six sustainability assessment criteria (SAC) scores to also produce:

GreenTag EcoPOINT score;
LCARate Product Scorecard;
LCA based CarbonRATE™ Tag; and
ISO compliant EPDs.

As part of the assessment process, all ingredients (substances or preparations) exceeding 0.01% by weight of the final product is considered and required to submit Material Safety Data Sheets (MSDS) or CAS-numbers for all raw ingredients, including fragrances, colorants, preservatives etc.

More information on the scheme can be found here:

http://www.ecospecifier.co.za/about-us/

The project is of the opinion that the GreenTag standard is more applicable to the South African content and is similar to the EPA Safer Choices in how product ingredients are assessed.

On these grounds, we request that an equivalency be granted to allow other ISO 14024 Type 1 ecolabel programs, such as GreenTag, to be used to show compliance with the Cleaning Product List objective.

Note:

The project team also provided supplementary information summarized below, including additional detail on the Green Tag standards listed. The Institute was also provided with a copy of the GreenTag Standard for Cleaning Products.

The Global GreenTag™ Standard* is a whole of sustainability standard with perhaps a wider array of issues than US EPA Safer Choice Label and has declaration levels an order of magnitude lower (perhaps more comprehensive) than Safer Choices in that it requires declarations to 100ppm of each ingredient not just the product.

The GreenTag™ Standard also has:

Fit for purpose requirements (Section 4.01)
Life Cycle Requirements (Section 4.02)
Preferred Packaging Requirements (Section 4.02.04)
Biodegradability of surfactants (Section 4.02.05)
Material Qualities including pH of some cleaning products (Section 4.03)
The GCAP Hazard Assessment Process (Appendix 1.0) is a more sophisticated multi-life-stage risk assessment that looks not only at ingredient hazards, but specifically at hazards in the factory and healthiness in use Ethical Supply Chain and Local Manufacturing requirements.

From the research we have conducted, we have not been able to identify any other system in South Africa focused on rating cleaning products and their components, and based on the insight we have on the Green Tag system we feel that it provides sufficiently stringent requirements. The GreenTag™ Cleaning product standard is also recognised by the Green Building Council of South Africa, the Green Building Council of Australia as well as the New Zealand Green Building council (where the Green Star green building certification system is applied). In South Africa the Green Star system is more widely used than any other green building rating system. In addition, the GreenTag™ Cleaning Product standards is also recognised by the WELL Standard and Green Globes.

What really stands out for us about the GreenTag™ standards, in addition to the information provided above, is that extensive Stakeholder Process associated with this standard:

GreenTag™ goes through extensive Stakeholder Engagement Processes in developing Standards, and they established a local African National Advisory Committee (AfNAC) as part of their processes. The operation of the committee relates to the localisation of the Global GreenTag™ International Standard and its adoption for use in Africa and to advise the GreenTag™ Program Director about any potential changes to the Standard if it is perceived that changes are desirable to meet African conditions. The African National Advisory Committee is comprised of representatives of industry bodies or associations and includes up to 12 members where each is selected from one of the following national organisation types:

Professional Association Representatives
Environmental/Community NGO Representatives
University Representative
Government Representative
Manufacturing Sector Industry Association Representatives

ANSWER

The information provided by the project team demonstrates comparable intent as well as equal or superior specificity and rigor between the GreenTag label in South Africa and the US EPA Safer Choice label, which justifies a determination of equivalency for purposes of cleaning product compliance under all versions of LBC for projects in South Africa.