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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 — ProtectChildrensHealth.rtf

  2. OGS should accept products listed or certified by other organizations and not rely solely on the Green Seal standards — CleaningProductCertification.rtf

  3. The Guidelines should require the use of non-toxic (bio-based) cleaning products — NonToxicCleaningProducts.rtf

  4. The Guidelines need to address the use of cleaning products with fragrances — Fragrances.rtf

  5. Products must not contain compounds that persist or bio-accumulate in human or animal tissue or in the environment –- Bioaccumulating.rtf

  6. The VOC (volatile organic compound) levels should be changed in the Guidelines — VOCs.rtf

  7. Cleaning products contained in Single use Aerosol Cans or those with ozone depleting propellants should not be used — AerosolCans.rtf

  8. Cleaning products should not contain compounds that contribute to Atmospheric Greenhouse Gases, Ground Level Smog or Ozone Depletion — GasesOzone.rtf

  9. The Guidelines do not adequately address ingredients that may be potential carcinogens, teratogens, mutagens or endocrine disrupters — Carcinogens.rtf

  10. Cleaning products should not contain Nonyl Phenol Ethoxylates (NPE) or Alkyphenol Ethoxylate (APE) — NPEsandAPEs.rtf

  11. For all cleaning products, the water supply should be purified and free of chlorine and residual chlorine — ChlorinatedOrganics.rtf

  12. Cleaning products should not contain chlorine, chlorinated or brominated solvents — Solvents.rtf

  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 — Heavymetals.rtf

  14. The Guidelines should limit phosphate cleaning product compounds — Phosphates.rtf

  15. Safety provisions are necessary for the use of cleaning products and should meet federal wellness policy — ProductSafety.rtf

  16. The Guidelines should limit the use of cleaning products that contain air fresheners and or fragrances — AirFresheners.rtf

  17. The Guidelines should contain specific criteria covering floor care products which are safe to use or proven to be effective — FloorCare.rtf

  18. The Guidelines should require supplier disclosure of cleaning product ingredients — SupplierDisclosure.rtf

  19. Caution is needed with any partnering with “Consultants” with implementation of the Guidelines — Consultants.rtf

  20. A rigorous Quality Assurance/Quality Control program should apply to all cleaning products — QualityAssurance.rtf

  21. The Guidelines should require raw material product suppliers to certify their materials — RawMaterialCertification.rtf

  22. Cleaning products testing should conform to American Society for Testing Materials standards (ASTM) — ASTMStandards.rtf

  23. OGS guidelines should specify the use of products that are non-toxic or have the lowest level of toxicity — LowToxicity.rtf

  24. The list of approved cleaning products should identify environmentally safe cleaning product cost competitiveness with traditional cleaners — CostEffectiveness.rtf

  25. The Guidelines should require companies to provide cost information for their products on the approved product list — CostInformation.rtf

  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) — ProductTiers.rtf

  27. The use of cleaning products should be non-corrosive to skin or inanimate surfaces — NonCorrosiveProducts.rtf

  28. The use of petroleum distillate based cleaning products should be limited — PetroleumProducts.rtf

  29. Cleaning products should be non-combustible below 150 degrees F — NonCombustibleProducts.rtf

  30. Automatic dispensing systems should be utilized for cleaning products — AutomaticDispensing.rtf

  31. The Guidelines should examine the use of Electrolyzed Oxidative Water for safer cleaning — OxidativeWater.rtf

  32. The Guidelines should require the use of cleaning products and processes that reduce asthma triggers — Asthma.rtf

  33. The Guidelines should address the use of cold water versus hot water cleaning — HotColdWaterCleaning.rtf

  34. The Guidelines should examine the need for cleaning product efficacy testing and its relationship to the Green Seal certification process — ProductEfficacyTesting.rtf

  35. The Guidelines should include other testing standards as a way to certify vacuum cleaners — NewCleaningTechnology.rtf

  36. The Guidelines should allow preferred source purchasing — PreferredSourcePurchasing.rtf

  37. The Guidelines should restrict the use of disinfectant/sanitization cleaning products — RestrictDisinfectants.rtf

  38. The Guidelines should address the use of hands soaps — Handsoap.rtf

  39. Several of the Best Management Cleaning Practices need to be modified — BestManagementPractices.rtf

  40. The Guidelines should address the use of paper products — PaperProducts.rtf

  41. The Guidelines should allow for the addition of new products to the sample list of approved cleaning products — NewProductsforSampleList.rtf

  42. The September 1, 2006 implementation date of the Law should be extended — SchoolImplementationDate.rtf

  43. The Guidelines should reduce the burden on the Laws required school reporting requirements — SchoolReportingRequirements.rtf

  44. The State should develop advanced custodial cleaning practices — AdvancedCleaningPractices.rtf

  45. Changes are needed to the Guideline Appendices — GuidelineAppendixChanges.rtf

  46. Investigate the use of new green cleaning technology and equipment — NewCleaningEquipment.rtf

  47. The Guidelines should define “cleaning” — DefineCleaning.rtf

  48. The Guidelines should contain other cleaning technology considered to be equally beneficial and effective as their chemical counterparts — BeneficialCleaningTechnology.rtf

  49. The Guidelines should address the need for lab testing and the use of out-of-state testing laboratory certified cleaning products — OutofStateProductTesting.rtf

  50. The Guidelines should require the use of recyclable cleaning packaging and not require products to be used in concentrated form — RecyclablePackaging.rtf

  51. The Guidelines should address other products used in schools — UseofOtherProducts.rtf

  52. Guidelines formatting, changes and related public comments — GuidelineChanges.rtf

  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 — CleaningProductCategories.rtf

  54. The Guidelines should eliminate the cleaning product self-certification process — SelfCertificationofProducts.rtf

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