By Steve Ashkin

Green Cleaning continues to accelerate.  And perhaps nothing illustrates this better than recent developments involving the posting of a new procurement schedule from the State of New York and Green Seal’s draft Standard for Cleaning Services.  Since their post on the respective websites just a short time ago, I have received dozens of calls and emails about these documents and want to share some thoughts with you. 

Please know that the following is not intended to be complete or thorough, and above all I would like to encourage you to review the documents and comment.  For only when we work collaboratively can we develop the best Standards to meet everyone’s needs.

New York State
I have had the opportunity to provide input to the development of New York’s draft document, although my comments were focused on developing the overall approach, definitions, and commentary on specifications for cleaning chemicals.  All in all, I am pleased with the New York State effort, not because it’s perfect, but rather because of how far it has come from where it originally started. 

Collaborating with the Healthy Schools Network out of New York, along with untold advocates, manufacturers, children’s and environmental health advocates the draft morphed from focusing primarily on product performance to one that will make a difference for schools (and the children in them) in New York State.

I was also happy that the draft was based on existing standards and efforts in other areas like those from the US Green Building Council’s LEED for Existing Buildings and the Healthy Schools Campaign’s Quick & Easy Guide to Green Cleaning in Schools, as opposed to the State ‘reinventing the wheel’.  So while New York State followed the Green Seal Standards they do NOT require the products to be “certified” reducing barriers to participation.

The importance of following these “roadmaps” was that New York State will help to expand demand for green products, rather than creating alternative requirements that would fracture demand.  New requirements would increase confusion, slow down the rate in which Green Cleaning is being adopted in the marketplace, and force manufacturers to make additional new products resulting in higher costs for manufacturers and distributors, as well as for New York State schools.

I believe the document needs more fine tuning especially with some of the equipment requirements and in its discussions about carpet care and the issues associated with the use of hot versus cold water.  A few of the other improvements that I will be recommending include a category to replace traditional drain openers with bacteriological products as well as using bacteriological carpet spotters, grease digesters and more – as if you haven’t guessed it, I’m a big fan of using nonpathogenic (not harmful to living organisms) bacteria for cleaning as the mimic how nature does things a concept called biomimicry.  I would also like to see some effort to identify the amount of biobased materials used in the product.

Information on the New York State program can be found at http://www.ogs.state.ny.us/bldgadmin/environmental/default.html and are due by May 3rd, 2006.

Green Seal
I have to admit that this is a very challenging commentary as I feel conflicted between my personal friendship with the folks at Green Seal and the responsibility I feel as a leader of the Green Cleaning Movement.  Ultimately, I feel that creating the best Standard will ultimately serve everyone’s needs – even if it means asking some very difficult questions.  So the following are some brief thoughts and I hope you will read their documents and comment directly to Green Seal.

As you may recall, I was originally retained by Green Seal to work as part of their “development team” on their new proposed Standard for Cleaning Services.  However, after just a short period I removed myself so that I could be a more active participant and have an unencumbered voice in the process – as I am doing now.

I think the Green Seal document is a good one.  Like the New York State program, it seems to be based heavily on existing programs – in this case LEED-EB and Pennsylvania’s Guidelines for Creating High-Performance Green Buildings.  I especially like the requirement of a detailed plan that accounts for vulnerable occupant populations such as children, asthmatics, and pregnant women.  And I am pleased to see that Green Seal has opened its Standards to other standard setting organizations, such as Environmental Choice. 

I must admit that I am disappointed with the lack of openness of the process itself.  Many of the people who contacted me also expressed their disappointment that there were long periods of silence from Green Seal between comment periods.  Plus, most comments went unknown except to the development team who alone decided what was, and what was not deemed relevant.  While I suspect that the approach used by Green Seal meets some form of consensus-based process, I would have preferred a much more open and transparent process due to the importance of the Standard and the level of interest from our industry.

I also was disappointed that Green Seal has not expanded its mission to address the concept of “green” to include a more holistic viewpoint of sustainability, as the Green Movement is beginning to understand it.  In this respect I am specifically referring to the “triple bottom line” and the need for activities to meet not only the environmental and economic requirements, but to recognize and address the third issue which deals with social impacts.  It is my opinion that a building cannot truly claim that it has a “certified” Green Cleaning program without it insuring that its workers are receiving a “living wage”, benefits and the like – and this issue must be driven by the building owners and property managers. 

I firmly believe that cleaning contractors cannot unilaterally increase wages as they will no longer be cost competitive.  But if building owners and property managers require that all bidders must pay the same living wage they will in affect level the playing field and remove the incentive to reduce wages and eliminate benefits for our workers.  If Green Seal chooses to add a provision simply requiring that a plan be in place for buildings with such a requirement, it would go a long way to addressing sustainability and the triple-bottom line.  And if they would do this then everyone will win and this will truly be a leadership standard in which everyone will benefit.

But the real challenge for me is that this proposed Standard requires auditing which is yet to be defined and the cost remains unknown.  Thus, to me the document remains incomplete.  And while this has been a common process for Green Seal – for example they did not provide auditing requirements and cost estimates when developing their GS-37 Standard on cleaners.  But having spent most of my career in the cleaning chemical manufacturing business, I had some sense of what it would take to meet the test requirements and felt it was not unreasonable.  Unfortunately, I have no similar feel for this new Standard.

Thus, the questions that I will be asking Green Seal have to do with clarifying the entire process from Standard to auditing to certification.  For example, I would like to know if a service provider will have to implement the program in 100% of their locations to meet the Standard.  This would work well for small contractors and individual in-house operations, but would not work well for mid-sized and large contractors.  And frankly without creating an opportunity to get the major players involved, Green Seal may inadvertently create a disincentive for them to begin their green journey.  And it is these larger players who offer the greatest opportunities to reduce the overall health and environmental impacts associated with our industry simply because of their size.

Also I am curious about the rigor of the audit.  As you know, I have promoted GS-37 because I felt that purchasing people could use it with confidence.  The review of product formulas and an audit of the manufacturer’s facility gave purchasers confidence when buying green products.  But the new draft Standard for Cleaning Services leaves me to question how Green Seal will be able to have a thorough audit considering how much needs to be covered.  And if the audit is not thorough, then we can not have confidence in the certification.

And this leads back to the question about cost.  If Green Seal’s process including the audit is too expensive, then this will create other barriers to small contractors. 

To this end, I think the draft would make a good “guide”, but feel that there are too many unanswered questions for me to promote it to the building owners, purchasers, contractors and others with whom we work.  So my comments to Green Seal will include a request for greater openness and transparency of the process, along with more information on how the Standard will be bundled with the audit and its full cost.  As we have come to learn, an activity cannot be sustainable unless it simultaneously meets environmental, health, and economic needs -- and Green Seal has to help us understand how their Standard will address all three.

Due to the potential impact to our industry, I encourage you to review the complete document which can be found at http://www.greenseal.org/draftdocs.htm.  Comments to Green Seal are due by May 2nd, 2006.