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ACI Position on Environmentally Preferable Procurement Programs

The American Cleaning Institute (ACI) supports the hazard and exposure based risk assessment as the key principle of safety assessments of cleaning and detergent products and ingredients. This approach has been the foundation of ACI’s scientific work for decades. ACI does not support ingredient or product assessments and ranking schemes that would in one way or another compromise this underlying principle.

As such, ACI will support the development of EPP schemes and standards at the local, national, or Federal levels that are in line with the above mentioned principle, EPA criteria and definitions of EPP that comply with this principle, and FTC guidelines for environmental marketing claims. Specifically:

Yes No

Sound science and hazard/exposure based safety assessment (underlying ACI and member companies’ principle)

Environmental and Health Benefits based on all stages of product life cycle (Official definition of EPP in Executive Order 13101, 1998)

Holistic approach with consideration of environmental factors along with other product benefits such as performance (EPA Guidance on Environmentally Preferable Purchasing)

Accurate and meaningful information (EPA Guidance on Environmentally Preferable Purchasing)

Official guidelines for environmental claims (FTC Guides for the Use of Environmental Marketing Claims)

Reportable indicators across all relevant areas (AISE Sustainability Charter)
Assessments based on full life cycle of the product thereby ensuring that burdens are not shifted from one life cycle to another (AISE Sustainability Charter)

Open to continued innovation and flexibility

Agreed EPP principles should be consistent between the I&I and retail product sectors

Pass/fail criteria based on limited endpoints (e.g. ready biodegradation, acute toxicity cut-off levels)

Hazard-based only criteria

Targets addressing limited/narrow endpoints (e.g. amount of non-biodegradables per use)

Discrimination of certain ingredients, products and product categories based other than on sound scientific principles

Claims of environmental attributes unless based on sound science, compliant with FTC and EPA guidelines