2516.01_Attachment 6 - Pilot Collection Instrument

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EPA ICR No. 2516.01: Attachment 5

April 14, 2016

Welcome to the 2016 Pilot EPA Assessment of Ecolabels and Standards!
This file is intended for those organizations who have volunteered to participate in the pilot for the Assessment of [Furniture, Flooring, or Paints & coatings]
ecolabels and standards.
For background on the purpose, history and participants in the EPA pilot project, see: http://www.resolv.org/site-guidelines/
Note that one organization should identify as the lead organization for each standard assessed.

ORIENTATION
This file contains the following three worksheets:
Worksheet 1: Instructions
• This worksheet provides background, orientation, instructions and contact details for the Assessment.
Worksheet 2: Scoping Questions
• This worksheet has a set of six questions intended to determine the scope of the Assessment. It also collects basic contact information for your organization.
• Answers to questions provided on this worksheet will not be assessed.
Worksheet 3,4,5,6: Pilot Criteria
• These four worksheets provide the detailed criteria being piloted in each of the four Sectionsof the EPA Guidelines, along with space for your organization to
provide a response to each criterion, and a description of the associated sources of evidence provided with your submission.
• Column [A] provides the number of each criterion.
• Column [B] notes whether each criterion (or sub-criterion) is considered “baseline”, “leadership” or “informational” for the purposes of the pilot Assessment.
Informational criteria are not considered in scoring.
• Column [C] provides the pilot criteria for the section of the Assessment. Column C also also provides any explanatory footnotes associated with the criterion; and
the EPA Guidelines that the criteria address.
• Column [D] describes some of the potential sources of evidence that could be submitted by your organization to support the response made. These are
suggestions, not requirements.
• Column [E] provides space for your organization to provide a response and/or comment on the criterion.
• Column [F] provides space for your organization to provide the name of the specific documents submitted as evidence with the Assessment, along with the
specific section or page number that supports the response(s) made in Column E.
• Column [G-K] will be used by IEc for the assessment.
Worksheet 7: Assessment Results
• This worksheet will be used by IEc to summarize the assessment results.

CONTACT
The Assessment is being conducted by Industrial Economics, Inc. (IEc) under contract to Resolve and the US EPA.
Please send questions to [email protected] and a representative from IEc will respond to you within two business days.
If you have questions about the overall project, please contact Alison Kinn Bennett at US EPA at [email protected]

Note: SDOs are required to pass
three leadership criteria, including
3 in Section 2, to be eligible for
"exceeds EPA's 2016 criteria"
designation.

INSTRUCTIONS

Step 1: Confirm participation by providing your responses to the “Scoping Questions”
• To confirm your organizations’ participation in the Assessment, first submit responses to Scoping Questions on the second tab by [date]. The rest of the workbook
can be blank at this point.
• Send this to [email protected]
Step 2: Establish timeline
• Following Step 1, you will receive an email from the Assessment team at IEc confirming receipt of this submission and communicating a timeline for the
remainder of the Assessment.
Step 3: Initial submission
• Answer questions in Worksheets 3-6 Pilot Criteria (Columns [E-G])
• Submit this workbook along with all supporting evidence by email to [email protected]. All file names should include the name of your
organization. If your organization is submitting multiple standards or ecolabels for assessment, all file names should also include the name of the standard or
ecolabel being addressed.
o Please clearly mark any confidential information (attachments or responses to criteria) as CONFIDENTIAL in the name of the file or in the text provided.
o The email from the Assessment team in Step 2 provides the deadline for submission of this material.
o Please send responses in excel. A word version of the criteria is available for your review (only).
Step 4: Completeness check
• The Assessment team at IEc will conduct an initial “completeness check” of the responses provided by your organization. IEc will check for clarity and any gaps in
evidence.
• IEc will note any gaps or questions in the worksheet, and send it back to your organization.
• IEc will also establish a deadline to re-submit material, which will be included in the email with the worksheet, [one] week after IEc sends.

Step 5: Re-submission (if required)
• If the assessors noted any gaps or required clarifications, your organization should submit an updated response.
• The re-submission should consist of the additional evidence and or updated language in the worksheet.
• Any new text in the worksheet should be clearly marked using colored highlights and/or a different font color than the original submission.
• The first set of documents sent as evidence are not required to be re-submitted; only those that are new or that have been updated.
Step 6: Assessment
• The Assessment team at IEc will conduct the Assessment based on the information submitted.
Step 7: Assessment results
• The EPA, the panelists, and Governance Committee members will review the Assessment results and form part of their recommendations to the EPA for the pilot
program.
• The Assessment team at IEc will send a report with a summary of results to your nominated contact person.

PILOT ASSESSMENT
General Information Requested
The following information is requested of organizations completing the assessment.

Question

Response/Comment

1. Name of Standard/Ecolabel
2. Who is the lead organization for this assessment?
3. Who is the primary contact person for this assessment?
4. Email address for primary contact person
5. Phone number for prmary contact person
6. To what product category(ies) does the ecolabel or standard
apply?
7. Which Section(s) of this assessment did your organization
address?
8. If there are Sections not addressed, please explain why they
are not applicable
9. Please provide any readily available documentation to
elucidate product availability for the federal marketplace
including:
- presence of a competitive bidding climate,
- indication of business demographics (i.e. disabled
veterans, women owned, small or micro businesses),
- and/or percent of the market certified to the
standard/ecolabel for that product category.

File Name
N/A
N/A
N/A
N/A
N/A

Flooring
Paints and Coatings

N/A

Furniture

N/A
N/A

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

File Name(s) and Section or
Page Number

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

SECTION I: PROCESS FOR DEVELOPING STANDARDS
Consistent with Section 12(d) of the National Technology Transfer and Advancement Act (PL 104 – 113) and the Office of Management and Budget Circular A-119, EPA Recommendations give preference to Voluntary Consensus Standards (VCS) (defined below). Other standards may be
considered in cases where VCS are inconsistent with law or otherwise impractical (e.g. in cases where VCS do not exist, a VCS does not address a particular environmental or human health impact, or a VCS would not be as effective at meeting the criteria outlined in Section II).

I.1

L

I.2

B

I.3

B

I.4

B

I.5

B

I.6

B

The standard is a voluntary consensus standard as defined
by OMB A119 Section 4.5
If a standard is an ANSI approved American National
Standard, then the SDO is assumed to meet and need not be -ANS Document #
assessed to Section I criteria: 2-7; 9; 11; and 13-18. Other
-Other (to be determined by EPA)
organization’s standards development processes may also
meet the OMB A-119 definition of voluntary consensus
standard.
-Documentation of interest categories defined by SDO.
-Evidence of outreach to actively recruit members from preThe SDO actively sought participation6 from directly and
defined interest categories.
materially affected stakeholders including producers, users,
-Outreach plan to identify and contact a diverse set of
public interest groups, locally affected groups/persons, and
stakeholders.
others.
-Evidence of active outreach such as email invitations and
Addresses the following Draft Guideline(s):
communications with a diverse set of stakeholders.
I.1 Open Participation
Or, where documentation cannot be located for standards
I.4 Progress/Updates are communicated
developed prior to 2012, attestation by the SDO indicating
the criteria was met.
Key standard setting activities7 were announced in suitable
8
media in order to encourage participation in standards
-Examples of announcements made in suitable media
development activities by stakeholders directly and
Or, where documentation cannot be located for standards
materially affected by the standard.
developed prior to 2012, attestation by the SDO indicating
Addresses the following Draft Guideline(s):
the criteria was met.
I.4 Progress/Updates are communicated

Timely and adequate9 notice was made to generate
stakeholder participation in key standard setting activities.
Addresses the following Draft Guideline(s):
I.4 Progress/Updates are communicated

-Schedule of notifications published on key standards
activities and deadlines imposed for participation.
-Notifications of key standards activities indicating when
posted.
-For example, time periods prescribed are 30-days for
comment on draft standards.
Or, where documentation cannot be located for standards
developed prior to 2012, attestation by the SDO indicating
the criteria was met.

Directly and materially affected stakeholders – including
producers, users, public interest groups, locally affected
groups/persons, and others – were able to participate in the
-Instructions for accessing information on key activities.
standard development process in a timely manner10
-Publicly accessible online postings of draft documents and
including by accessing draft standards documents, providing
comment periods.
input to draft standards documents, receiving meaningful
-Policy for a minimum number of days in a comment period.
written response regarding how their input is acted on or
-Comments on draft documents received from stakeholders.
not acted on, and where voting/balloting is used, having
-Meeting minutes showing stakeholder participation.
their input made available to the voting members and
-online posting of written comments.
considered before a final vote is taken on the standard.
-online posting of written responses to Comments from the
Note: Participation does not necessarily include a voting
SDO.
role, but goes beyond public notification that a draft exists.
-Other Evidence of stakeholder participation as supplied by
Addresses the following Draft Guideline(s):
SDO.
I.1 Open Participation
I.5 Transparent
I.6 Consideration of all viewpoints
-Instructions for accessing information on key activities.
-Policy on posting meeting minutes, comments & responses,
Minutes of all committee and decision-making body
complaints & appeals.
meetings, comments and responses thereto, and complaints
-Meeting minutes of decision making body with
and appeals made during the standard development process
documentation of prompt date of posting.
were available to stakeholders for inspection in a timely
-Complaints and appeals made.
manner.
-Comments and responses thereto posted publicly to the
Addresses the following Draft Guideline(s):
SDO/standards website.
I.4 Progress/Updates are communicated
Or, where documentation cannot be located for standards
I.5 Transparent
developed prior to 2012, attestation by the SDO indicating
the criteria was met.

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
B/L/I Proposed Final Assessment Criteria

I.7

B

I.8

I.9

L

L

1.10

L

I.11

B

I.12

B

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4
A procedure or a policy ensures fair and equitable
-Policy/ procedure for ensuring stakeholder input during
consideration of timely stakeholder input during the
standards development process are fairly considered.
standard-development process11. Input on the standard
-Access to all, but for assessment, review a sample of
12
received was documented, adjudicated , and responded to stakeholder comments and responses to comments on draft
by the SDO in accordance with its procedures.
documents – direct responses to individuals or general
Addresses the following Draft Guideline(s):
responses to key themes.
I.5 Transparent
-Other evidence of stakeholder participation as supplied by
I.6
Consideration
of
all
viewpoints
SDO
Option 1: There was no fee or travel requirement to

Criter
-ia #

participate in the development of the standard.
OR
Option 2: If there was a fee, it is minimal or offset by sliding
scale for individual/NGO/academic stakeholders. The SDO
provided travel funds to hardship parties/stakeholders
without financial means to attend in-person meetings,
virtual access to meetings, fee waivers, and/or other
mechanism to retain stakeholders’ ability to participate in
standards activities.
Addresses the following Draft Guideline(s):
I.1 Open Participation.
Membership
of the decision-making body was not

-Notification that participation is free.
-Fee schedule showing sliding scale / waivers.
-Travel funds policy.
-Evidence of virtual access to meetings (e.g. webinar
recordings, conference call lines)

unreasonably restricted on the basis of technical
qualifications or other such requirements (e.g., membership
-Roster of voting members of decision- making body.
in an organization). Restrictions for the purposes of
-List of restrictions (if any) on voting membership of
achieving a predefined target size of the body, achieving a
decision-making body. Explanation as to why they are
balance of stakeholders, and engaging diverse expertise shall
reasonable.
be considered reasonable restrictions.
Addresses the following Draft Guideline(s):
I.3 Reasonable voting qualifications
The SDO achieved a balance of interest in the decisionmaking body by ensuring that no single interest category
-Guidelines/Policy for balance of interest in forming
constituted more than a one-third (33%) of the membership decision-making body parallel with ANSI Essential
of that body if there are 4 or more interest categories, or
Requirements 1.3 and 2.3.
40% of the membership if there are 3 designated interest
-Documentation that no more than 1/3 of decision- making
13
categories.
body is from one interest category, or 40% if there are only 3
Addresses the following Draft Guideline(s):
interest categories.
I.7 Diversity of Interests
-Guidelines/procedures that reflect that no interest category
or organization can dominate decision- making.
-Evidence that no directly and materially affected party has
submitted a written complaint about dominance (see ANSI
Essential Procedures Section 2.2)
Decision making procedures/guidance ensured that no single
-Evidence that guidance/ procedure was followed; e.g.
interest category or organization can dominate14 resolutions
voting records on key decisions.
made by the decision-making body.
-Policy references or parallels ANSI Essential Requirements
Addresses the following Draft Guideline(s):
“Lack of Dominance” criteria at 1.2 and 2.2: “The standards
1.x Lack of Dominance [SUBMITTED FROM GC MEMBER ON
development process shall not be dominated by any single
V2.0]
interest category, individual or organization. Dominance
means a position or exercise of dominant authority,
leadership, or influence by reason of superior leverage,
strength, or representation to the exclusion of fair and
Standards Development Organization has a conflicts of
equitable consideration of other viewpoints.”
interest15 policy or procedure that addresses potential
conflicts of interest and in particular, that funding sources
-Documentation of policy or procedure on conflicts of
for standards development are fully disclosed.
interest.
If significant external funding is made by one or more parties
-Original sources of funding for standards development are
to support standard development, the SDO shall put in place
disclosed to stakeholders throughout the process.
supplemental procedures to ensure that no domination
-Formal policy separating functions of organization if there is
occurs and balance of interests is respected in the standard
a potential conflict of interest.
development process.
-Potential conflicts of interest are disclosed at the
“Significant funding” shall mean more than $10,000 or its instakeholder outreach stage so that parties with competing
kind equivalent, or 20% or more of the anticipated funding
or adverse interests can be invited to participate in the
needs of the SDO for standard development.
standard development process and the integrity of balance
Addresses the following Draft Guideline(s):
requirements is maintained.
I.5 Transparent
1.x Lack of Dominance [SUBMITTED FROM GC MEMBER ON
V2.0]

File Name(s) and Section or
Page Number

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

I.13

I.14

I.15

B

Reasonable efforts to achieve consensus are made by the
decision-making body and SDO.16
Addresses the following Draft Guideline(s):
I.9 Consensus effort

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

-Policy/ procedure that lays out decision making process and
consensus definition including: applicable definition of what
constitutes consensus, how it is reached, and that the
standard setting process includes procedures for registering
comments.
-Policy/procedure shows an adequate process for resolving
objections; objectors are each advised as to the reasons why
the objection was resolved or not resolved; and the
members of the decision making body are able to change
their votes after reviewing the comments.
-Agenda and/or minutes of key meetings showing that
efforts towards consensus were on the agenda, and
appropriate time was given to reach decisions and reach
consensus. Examples include:
 Documentation reflects that key development
committees selected their own chairmen from the relevant
stakeholder group and chairmen were not “selected” by
administrators in the NGO.
 Documentation reflects frequent straw votes were made
at the committee, work group, and technical committee
levels.
 Documentation shows that where straw votes suggested
significant disagreement, additional discussion was
scheduled (see agenda and/or minutes)
 Proceedings reflect a lack of written criticism, complaint,
or “no votes” in straw or final voting
 Proceedings reflect that where disagreement was
sustained, the SDO made efforts to bring in a third party
mediator, changed the chairmanship, changed committee
composition, referred the matter back to a technical or
development committee, or otherwise offered
mediation/dispute resolution assistance to resolve the
disagreement.

B

Objections regarding procedures received during the
standard setting process are documented and made
available to interested parties in a timely manner by the
standard development organization. Objectors are advised -Documentation of a diverse sample of the objections
as to their right of appeal.
received during the standard setting process.
If an objection is made in writing, the SDO makes a timely
-Agendas and/or minutes of key meetings showing
and meaningful response to the objection, which response is objections and their resolution.
in writing and made available.
-Sample of records of communication between the objector
If an objection is continuing and is not resolved in the
and the SDO reflecting work toward resolution.
development process, objectors are ultimately advised as to Or, where documentation cannot be located for standards
their right and scope of appeal.
developed prior to 2012, attestation by the SDO indicating
Addresses the following Draft Guideline(s):
the criteria was met.
I.5 Transparent
I.9 Consensus effort
I.10 Efforts to Resolve Objections

B

A documented appeals mechanism is published to address
procedural appeals following the final decision.
Addresses the following Draft Guideline(s):
I.11 Appeals mechanism

-Proof that the relevant policy/procedure was made public
and or available to participants before the standard
development process (e.g. website posting, email, etc.)
Or, where documentation cannot be located for standards
developed prior to 2012, attestation by the SDO indicating
the criteria was met.

File Name(s) and Section or
Page Number

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

I.16

B

I.17

B

I.18

I.19

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

The process for initiating the appeal is straightforward,
requires simple notice (articulation) of the basis for the
appeal, and does not impose redundant or unnecessary
-Appeals policy and procedures available (easy to find with a
costs, paperwork or documentary requirements.
clear process defined in straightforward language).
A reasonable time17 is offered from the time of the final vote -Documentation of policy and/or disclosure of any financial
to the deadline for lodging notice of appeal
imposition made on stakeholders undertaking an appeal.
Addresses the following Draft Guideline(s):
I.11 Appeals mechanism
I.12 Appeals Open
-SDO documents that at the outset of the standard
development process, it searched for potentially conflicting /
incompatible standards in existence or under development.
-If standards identified as conflicting/incompatible,
documentation of outreach to other standards developer
and effort to resolve issue.
At the outset of the standard development process the SDO
-Evidence may be that the SDOs sought to merge efforts.
identified existing standards that may be in conflict or
Evidence may also be that a request was made to a critical
incompatible with the draft standard and demonstrated
stakeholder or an accreditation body to help lead discussions
effort to coordinate and/or resolve
to align or merge efforts.
conflicts/incompatibilities with those standards, or merge
Or
standards, as appropriate.
-Rationale for why an existing standard was not approached,
Addresses the following Draft Guideline(s):
including, for example, because of an insufficient level of
I.13 Good faith on conflicts
protection or fundamental geographical factors or
fundamental technological problems.
Or, where documentation of outreach to other standards
developers cannot be located for standards developed prior
to 2012, attestation by the SDO indicating the criteria was
met.

B

Standard has been opened for either revision or
reaffirmation at least every five years. For a younger
standard, it is scheduled to be revised or reaffirmed at least
every 5 years.
Addresses the following Draft Guideline(s):
I.14 Standards Updated
II.3 Data Quality and Reliability

-Policy or standard text stating schedule for expected
revision or re-affirmation of the standard.
-Text supplied shows that standard is scheduled to be
revised/ reaffirmed every 5 years or less from the date of the
last standard version.

L

The SDO shall make available to the participating
stakeholders an analysis of the environmental and human
health hotspots affecting the product category and for the
life cycle stages under consideration. Such analysis shall
utilize documented hotspot methodologies for identifying
and analyzing such hotspots. Any participant shall be given
the opportunity to provide supplementary information if
they wish.

- Documented hotspots (or related) methods and findings.
- Evidence that these findings were shared or made available
to stakeholder as part of standard development process.
– Procedure or policy indicating that stakeholders were able
to introduce supplementary information.

File Name(s) and Section or
Page Number

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

File Name(s) and Section or
Page Number

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

It is within the IAE’s purview to request multiple sources of evidence or determine if multiple sources are needed for a criteria to be sufficiently evaluated.
Per the revised OMB Circular A119 Section 5b, there is a preference for the use of voluntary consensus standards. The Circular does not preclude the use of other standards in rulemaking, procurement, or other program activities in cases where voluntary consensus standards do not exist or use of existing voluntary
consensus standards would be inconsistent with law or otherwise impractical, including where use of a voluntary consensus standard would not be as effective at meeting the agency’s regulatory, procurement or program needs. EPA has determined that American National Standards meet the definition of voluntary
consensus standards per the revised OMB A119 available at https://www.whitehouse.gov/sites/default/files/omb/inforeg/revised_circular_a-119_as_of_1_22.pdf. Other organization’s standards development processes may also meet this definition; EPA would update this criterion and sources of evidence accordingly.
6
Active outreach may include but are not limited to identifying and contacting stakeholders, inviting participation, and maintaining appropriate communications with stakeholders.
7
Key standard setting activities represent the significant stages of the standard's development, including any action to create, revise, reaffirm, or withdraw a standard, the establishment of a new decision-making body; Selection and scoping of product categories and product functional characteristics; Call for members/
participation (voting, participating, and/or commenting); Selection and development of environmental/ human health criteria; Availability of proposals for comment and/or vote; Responses to comments posted; Modified proposals as a result of comments available for comment and/or vote; Announcement of final
action; Complaints and/or appeals received; Publication of standard; Other key activities as determined by the SDO.
8
Suitable media should match up to the methods utilized and available to materially affected persons (including public interest groups, affected local and indigenous persons). Suitable media could include (but are not limited to): maintenance of an open email subscription list/ list serve throughout the SD process, email
notifications, publication of press releases, online publication, newsletters, use of social media (such as Linked-in announcements and updates), posting of notifications in external standards’ or trade media bulletins and news-services such as ANSI’s “Standards Action”. Note: A posting on a website to check back for more
information and updates periodically is not considered sufficient.
9
Sufficient time varies by key standard activity but is generally defined as keeping stakeholders up to date and engaged in the standard setting activities, and providing sufficient time for response from stakeholders. For example, ANSI essential requirements stipulates 30-day comment periods for proposals 5 pages or
less in length, 45-days for readily available proposals (available within 1-day of a request to receive it), or 60-days if the above 2 options are not applicable.
10
Timely manner is defined as keeping stakeholders up to date and engaged in the standard setting activities, and providing sufficient time for response from stakeholders.
11
The standard setting process includes key steps starting with the announcement of a new standard or review of an existing standard, and ending with the publication of the standard and all activities between.
12
Adjudicate - make a formal judgment or decision about a problem or disputed matter. (from Google)
13
Per OMB A119 sect 2e(ii), “The standards development process should be balanced. Specifically, there should be meaningful involvement from a broad range of parties, with no single interest dominating the decision-making.” Definition of “balance of interest” may also be informed by ANSI Essential Requirements
(2015), which defines and “balance” as “a) no single interest category constitutes more than one-third of the membership of a consensus body dealing with safety-related standards or b) no single interest category constitutes a majority of the membership of a consensus body dealing with other than safety-related
standards. In addition, the Draft EPA Guidelines footnote #3 states that in the case of standards development organizations: “additional steps have been taken by a number of SDOs to further ensure a balance of diverse interests (e.g. limiting number of votes per organization, confirming accuracy of affiliations, actively
recruiting additional members from other stakeholder categories).”
14
ANSI Essential Requirements 1.2 defines “dominate” as “to take a position or exercise of dominant authority, leadership, or influence by reason of superior leverage, strength, or representation to the exclusion of fair and equitable consideration of other viewpoints.”
15
Conflict of interest – a situation in which a person or organization is in a position to derive personal benefit from actions or decisions made in their official capacity. (from Google)
16
Per OMB A119 Section 2e(v) “Consensus is defined as general agreement, but not necessarily unanimity. During the development of consensus, comments and objections are considered using fair, impartial, open, and transparent processes.”
17
A reasonable time to file a notice of appeal, as long as the paperwork and documentation burden is limited, is generally considered to be at least 15 days from the date of the final vote.
4
5

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

SECTION II: ENVIRONMENTAL EFFECTIVENESS OF THE STANDARD

II.1

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4
-Text of the standard provides a clear protocol for measuring
whether a product has achieved the standard’s target
level(s) of performance for the hotspot(s) addressed

Meaningfully and Measurably addresses relevant
HOTSPOTS
-SDO justification for each of the impact categories claimed
Addresses the following Draft Guidelines:
to be meaningfully and measurably addressed.
II.1 Align with Relevant Standards
II.2 Measurability and Significant Measurable Difference
- for baseline credit, minimally, the Text of the standard
II.4 Performance-Based
requires a management plan approach to addressing the
II.5 Hotspots
hotspot
II.6 Multiple Environmental Impacts
-for Leadership credit, the Text of the standard requires
II.7 Lifecycle Stages
specific approaches and/or measures to demonstrate
All Baseline impact areas (“B”) need to be addressed unless
performance outcomes are achieved per the hotspot
demonstrated by the SDO to be non-applicable for the
product subtype. At least two additional impact areas (line
-Note that both performance criteria and prescriptive
items) need to be addressed for Leadership credit to the
criteria may appear in the same standard.
sub-criterion (i.e., II.1.1, II.1.2, II.1.3, and II.1.4). Therefore,
there are four (4) potential Leadership credits available in
-Unacceptably vague criteria for a hotspot would include
II.1).
those stating that an entity should “be involved in” or
“promote” an activity, approach, or philosophy without
-Text of the standard provides a clear protocol for measuring
specifying resulting performance or prescriptive outcomes.
II.1.1 For standards claiming to address the pre-extraction
whether a product has achieved the standard’s target
and raw materials sourcing stages, the standard
level(s) of performance for the hotspot(s) addressed
meaningfully and measurably addresses:
Flooring & Furniture:
-SDO justification for each of the impact categories claimed
• B – Land use change, ecosystem services loss, and habitat to be meaningfully and measurably addressed.
degradation
• B- Biodiversity/endangered species,
- for baseline credit, minimally, the Text of the standard
• B-Soil health, compaction & erosion (carbon, siltation,
requires a management plan approach to addressing the
eutrophication, biodiversity of soil fauna)
hotspot
• L-Sustainable yield
-for Leadership credit, the Text of the standard requires
• L-Energy use, fossil fuel use, global warming potential,
specific approaches and/or measures to demonstrate
and/or greenhouse gas emissions
performance outcomes are achieved per the hotspot
• L-Criteria air pollutants, air toxics, and photochemical smog
• L-Pollution discharges to water
-Note that both performance criteria and prescriptive
Paints/Coatings:
criteria may appear in the same standard.
• L-Percent recycled, renewable and/or bio-based content
• L- Energy use, fossil fuel use, global warming potential,
-Unacceptably vague criteria for a hotspot would include
and/or greenhouse gas emissions
those stating that an entity should “be involved in” or
And
“promote” an activity, approach, or philosophy without
specifying resulting performance or prescriptive outcomes.

File Name(s) and Section or
Page Number

Completeness
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Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

II.1.2 For standards claiming to address the manufacturing -Text of the standard provides a clear protocol for measuring
stage, the standard meaningfully and measurably addresses: whether a product has achieved the standard’s target
Flooring & Furniture:
level(s) of performance for the hotspot(s) addressed
• B- Energy use, fossil fuel use, global warming potential,
and/or greenhouse gas emissions
-SDO justification for each of the impact categories claimed
• L- Ozone depletion potential
to be meaningfully and measurably addressed.
• L-Criteria air pollutants, air toxics, and photochemical smog
• L-Pollution discharges to water
- for baseline credit, minimally, the Text of the standard
• L-Water use
requires a management plan approach to addressing the
• L-Solid waste generation
hotspot
Note that chemicals of concern have also been identified as a -for Leadership credit, the Text of the standard requires
potential hotspot in the manufacturing stage. These issues specific approaches and/or measures to demonstrate
are addressed in criteria II.5, II.6, and II.7.
performance outcomes are achieved per the hotspot
Paints/Coatings:
• None identified - LCAs indicate that the manufacturing
-Note that both performance criteria and prescriptive
stage is a minor contributer to the overall impacts of
criteria may appear in the same standard.
paints/coatings
Note that chemicals of concern have also been identified as a -Unacceptably vague criteria for a hotspot would include
potential hotspot in the manufacturing stage. These issues those stating that an entity should “be involved in” or
are addressed in criteria II.5, II.6, and II.7.
“promote” an activity, approach, or philosophy without
And
specifying resulting performance or prescriptive outcomes.

File Name(s) and Section or
Page Number

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

II.1.3 For standards claiming to address human health
impacts of the product in the installation/use stages, the
standard incorporates by reference or aligns with:
Flooring:
• B - “Standard Method for the Testing and Evaluation of
Volatile Organic Chemical Emissions from Indoor Sources
Using Environmental Chambers, Version 1.1” (2010) (CDPH
Standard Method 1.1-2010) (This is the emission testing
method for California Specification 01350.)
Note that chemicals of concern have also been identified as a
potential hotspot in the installation/use stage. These issues
are addressed in criteria II.5, II.6, and II.7.
Furniture:
-Text of the standard provides a clear protocol for measuring
• B - ANSI/BIFMA X7.1 Standard for Formaldehyde and TVOC whether a product has achieved the standard’s target
Emissions.
level(s) of performance for the hotspot(s) addressed
• L - “Standard Method for the Testing and Evaluation of
Volatile Organic Chemical Emissions from Indoor Sources
-SDO justification for each of the impact categories claimed
Using Environmental Chambers, Version 1.1” (2010) (CDPH to be meaningfully and measurably addressed.
Standard Method 1.1-2010) (This is the emission testing
method for California Specification 01350.) (Note that if this - for baseline credit, minimally, the Text of the standard
VOC leadership criterion is met, ANSI/BIFMA X7.1 Standard requires a management plan approach to addressing the
does not need to be incorporated by reference.)
hotspot
• L- California’s furniture flammability standard (Technical
-for Leadership credit, the Text of the standard requires
Bulletin 117-2013) and requires products to be labeled as
specific approaches and/or measures to demonstrate
not containing flame retardant chemicals consistent with the performance outcomes are achieved per the hotspot
manner described in Section 19094 of the California Business
and Professions Code
-Note that both performance criteria and prescriptive
Note that additional chemicals of concern have also been
criteria may appear in the same standard.
identified as potential hotspots in the installation/use stage.
These issues are addressed in criteria II.5, II.6, and II.7.
-Unacceptably vague criteria for a hotspot would include
Paints/Coatings:
those stating that an entity should “be involved in” or
• B -California Air Resources Board’s (CARB) Suggested
“promote” an activity, approach, or philosophy without
Control Measures (SCM) 2007 for VOC content for
specifying resulting performance or prescriptive outcomes.
Paints/Coatings.
• L -“Standard Method for the Testing and Evaluation of
Volatile Organic Chemical Emissions from Indoor Sources
Using Environmental Chambers, Version 1.1” (2010) (CDPH
Standard Method 1.1-2010) (This is the emission testing
method for California Specification 01350.)
• L- South Coast Air Quality Management District (SCAQMD)
Rule 1113 for VOC content.
Note that additional chemicals of concern have also been
identified as potential hotspots in the installation/use stage.
These issues are addressed in criteria II.5, II.6, and II.7.
And

File Name(s) and Section or
Page Number

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Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

-SDO justification for each of the impact categories claimed
to be meaningfully and measurably addressed.
II.1.4 For standards claiming to address the end of life stage,
- for baseline credit, minimally, the Text of the standard
the standard meaningfully and measurably addresses:
requires a management plan approach to addressing the
For all sectors:
hotspot
• B - Solid waste generation (e.g., design for disassembly,
-for Leadership credit, the Text of the standard requires
product take-back programs, remanufactured/repurpose
specific approaches and/or measures to demonstrate
capabilities, or minimizing disposal impacts).
performance outcomes are achieved per the hotspot
Note that additional chemicals of concern have also been
identified as potential hotspots in the installation/use stage.
-Note that both performance criteria and prescriptive
These issues are addressed in criteria II.5, II.6, and II.7
criteria may appear in the same standard.

II.2

II.3

II.4

L

B

B

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4
-Text of the standard provides a clear protocol for measuring
whether a product has achieved the standard’s target
level(s) of performance for the hotspot(s) addressed

-Unacceptably vague criteria for a hotspot would include
those stating that an entity should “be involved in” or
“promote” an activity, approach, or philosophy without
specifying resulting performance or prescriptive outcomes.
The standard and/or supplementary materials that
accompany the standard clearly identifies any known trade- -Text of standard, supplementary materials that accompany
the standard addressing trade-offs among impacts (if
offs among approaches to address multiple impact areas.
applicable, as determined by the SDO).
Addresses the following Draft Guideline(s):
II.6 Multiple Environmental Impacts
-SDO documentation of example information sources used in
developing the environmental and/or human health
performance criteria in the standard, including peer review
The environmental and/or human health criteria in the
panel statement, dates of oldest and most recent sources
standard are based on recent available research (at the time
cited, identity of any independent experts consulted as part
the standard was developed) that was peer-reviewed and
of the research, and, if applicable, SDO documentation of life
available for stakeholder review. Additionally, standards
cycle assessment data reviewed.
developers used the most appropriate types of assessment
-If any life cycle assessment was conducted as the basis of
methods for the determination of the impacts or attributes.18
the criteria, it is consistent with ISO 14040 and ISO 14044,
Addresses the following Draft Guideline(s):
complying with the critical review process.
II.3 Data Quality and Reliability
-Alternatives assessment criteria are in accordance with the
National Academy of Sciences (NAS) Framework to Guide
Selection of Chemical Alternatives.
N/A if all environmental attributes and environmental and
If a weighting scheme is used, the standard or
human health impacts have equal value; no additional
supplementary materials that accompany the standard fully weighting or adjustment is made for certain categories or
and transparently explains the weighting methodologies,
types of criteria.
including the decision science/tool selected and connection -Text of standard or supplementary materials that
between scoring and the single attributes or single impacts.19 accompany the standard describes the weighting
Addresses the following Draft Guideline(s):
methodologies.
II.8 Weighting Methodologies
-Documentation clearly describing the basis used for the
weighting.

File Name(s) and Section or
Page Number

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Gaps or
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IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

II.5

B/L/I Proposed Final Assessment Criteria

L

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

-Text of standard: criteria require hazard reduction through
one or more of the approaches listed.
-SDOs indication of the source(s) consulted in developing
criteria to address chemicals of concern. If SDO does not cite
any of the sources listed below, it must provide
documentation of source(s) consulted and provide evidence
that source (s) are reputable. For a hazard list to be
considered ‘reputable’ it shall be based on scientific
evidence, be peer-reviewed, and be developed by experts
free of any conflicts of interest regarding the outcome of the
assessments. Hazard lists should also be constructed
through an open-stakeholder process. To provide
transparency, formal documentation on the methodology
used to compile the list, including key assumptions, shall be
publicly available. The standard shall include a formal
mechanism to consider form-specific (e.g. respirable dust vs.
liquid vs. solid) hazards (such as titanium dioxide).
Carcinogens
•Listed by the International Agency for Research on Cancer
as:
-Group 1: carcinogenic to humans
-Group 2A: probably carcinogenic to humans
•Listed by the National Toxicology Program as:
-Known human carcinogen
-Reasonably anticipated human carcinogen
•Meet the criteria under the Globally Harmonized System of
Classification and Labeling (GHS) for the carcinogenicity
hazard class (codes H350, H351)
Mutagens
•Globally Harmonized System of Classification and Labeling
(GHS)
-Category 1A: Chemicals known to induce heritable
mutations in germ cells of humans
The standard includes environmental and human health
-Category 1B: Chemicals which should be regarded as if they
protection criteria to decrease the toxicological hazard20 of induce heritable mutations in the germ cells of humans
the product through one or more of the following:
-Category 2: Chemicals which cause concern for humans
alternatives assessment; safer substitution; reduction or
owing to the possibility that they may induce heritable
elimination of hazardous substance(s); or alternative design mutations in the germ cells of humans
approaches. Chemical substances of concern include
Reproductive toxicants
carcinogens, mutagens, Persistent, Bioaccumulative, Toxics •Listed under the State of California Safe Drinking Water and
(PBTs), reproductive toxicants, and chemicals on the
Toxic Enforcement Act (Prop 65) for reproductive or
complete and current EPA Toxics Release Inventory (TRI).
developmental toxicity
The SDO used reputable information sources in identifying •Meet the criteria under the Globally Harmonized System of
chemicals of concern.
Classification and Labeling (GHS) for the Reproductive
The standard fully and transparently explains its
Toxicity hazard class (codes H360 Categories 1A and 1B,
methodology for the criteria. Alternatives assessment
H361, H362)
criteria are in accordance with the National Academy of
PBT substances
Sciences (NAS) Framework to Guide Selection of Chemical
•Stockholm Convention Persistent Organic Pollutants
Alternatives.
U.S. – Canada Binational Toxics
Addresses the following Draft Guideline(s):
•Toxics Release Inventory (TRI) PBT chemicals
II.9 Intrinsic Hazards
•Chemicals listed in 40 CFR 372.28 due to their PBT
characteristics
•RCRA Waste Minimization Priority Chemicals
EPA TRI complete, current list (also at 40 CFR 372.65):
http://www2.epa.gov/sites/production/files/2015-11/tri_ch
emical_list_for_ry15_11_5_2015_1.xlsx
Others sources used could include, but are not limited to:
•The Toxic Substance Control Act Test Submission Database
(TSCATS): http://www.ntis.gov/products/ots.aspx and
http://yosemite.epa.gov/oppts/epatscat8.nsf/ReportSearch?
OpenForm
•Hazardous Substances Data Bank (HSDB):
http://toxnet.nlm.nih.gov/
•Integrated Risk Information System (IRIS):
http://www.epa.gov/IRIS/
•The National Toxicology Program (NTP):
http://ntp.niehs.nih.gov/

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Page Number

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Notes

II.5

Criter
-ia #

L

complete and current EPA Toxics Release Inventory (TRI).
The SDO used reputable information sources in identifying
chemicals of concern.
The standard fully and transparently explains its
methodology for the criteria. Alternatives assessment
criteria are in accordance with the National Academy of
Sciences (NAS) Framework to Guide Selection of Chemical
Alternatives.
Addresses the following Draft Guideline(s):
II.9 Intrinsic Hazards

B/L/I Proposed Final Assessment Criteria

developmental toxicity
•Meet the criteria under the Globally Harmonized System of
Classification and Labeling (GHS) for the Reproductive
Toxicity hazard class (codes H360 Categories 1A and 1B,
H361, H362)
PBT substances
•Stockholm Convention Persistent Organic Pollutants
U.S. – Canada Binational Toxics
•Toxics Release Inventory (TRI) PBT chemicals
Count of Leadership criteria met (need to meet at least six overall, including at least three from
•Chemicals listed in 40 CFR 372.28 due to their PBT
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)
characteristics
•RCRA Waste Minimization Priority Chemicals
EPA TRI complete, current list (also at 40 CFR 372.65):
Criteria and Evidence
SDO Submission
http://www2.epa.gov/sites/production/files/2015-11/tri_ch
Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
File Name(s) and Section or
Completeness Gaps or
emical_list_for_ry15_11_5_2015_1.xlsx
4
to IAE review)
Page Number
Check
Clarifications
Others
sources used could include, but are not limited to:
•The Toxic Substance Control Act Test Submission Database
(TSCATS): http://www.ntis.gov/products/ots.aspx and
http://yosemite.epa.gov/oppts/epatscat8.nsf/ReportSearch?
OpenForm
•Hazardous Substances Data Bank (HSDB):
http://toxnet.nlm.nih.gov/
•Integrated Risk Information System (IRIS):
http://www.epa.gov/IRIS/
•The National Toxicology Program (NTP):
http://ntp.niehs.nih.gov/
•US EPA HPV Challenge Program: http://www.epa.gov/hpv/
•The Distributed Structure-Searchable Toxicity Database
Network (DSSTox): http://www.epa.gov/ncct/dsstox/
•Acute Exposure Guideline Levels (AEGLS):
http://www.epa.gov/oppt/aegl/pubs/chemlist.htm
•The Agency for Toxic Substances & Disease Registry
(ATSDR) Toxic Substances Portal:
http://www.atsdr.cdc.gov/substances/index.asp
•US EPA: Public Databases Routinely Searched for Hazard
Information: http://www.epa.gov/hpvis/hazardinfo.htm
•U.S. Environmental Protection Agency’s (EPA) Design for
the Environment Program (DfE)—DfE’s Alternatives
Assessment Criteria:
http://www.epa.gov/dfe/alternative_assessments.html
•U.S. Environmental Protection Agency’s (EPA) TRACI - The
Tool for the Reduction and Assessment of Chemical and
other environmental Impacts

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

L

-Text of standard indicating it is solely a process and
The standard includes criteria to require or incentivize
production method (PPM) standard, or a standard that does
disclosure (either publicly or to a third party) of all
not address the environmental or human health
intentionally added chemical substances present in each
performance of a finished product.
homogenous material in the final product at 1000 parts per -Text of standard requires chemical disclosure at the
million (.1%) or greater.
specified threshold(s).
Note: If the standard is a process and production method
-SDOs indication of the source(s) consulted in developing
(PPM) standard, this Guideline is not applicable, and will not criteria to address chemicals of concern. If SDO does not cite
be used in scoring.21
any of the sources listed below, it must provide
Addresses the following Draft Guideline(s):
documentation of source(s) consulted and evidence that
II.10 Ingredient Disclosure
source (s) are reputable. (See II.5 Sources of Evidence “Lists
of Lists”)

L

The standard includes criteria to require or incentivize public
disclosure of the intentionally added chemical substances of
concern present in each homogenous material in the final -Text of standard requires chemical disclosure at the
product at 100 parts per million (0.01%) or greater. Chemical specified threshold(s).
substances of concern include carcinogens, mutagens,
-SDOs indication of the source(s) consulted in developing
Persistent, Bioaccumulative, Toxics (PBTs), reproductive
criteria to address chemicals of concern. If SDO does not cite
toxicants, and chemicals on the complete and current EPA any of the sources listed below, it must provide
Toxics Release Inventory (TRI).
documentation of source(s) consulted and evidence that
The SDO used reputable information sources in identifying source (s) are reputable. (See II.5 Sources of Evidence “Lists
chemicals of concern.
of Lists”)
Addresses the following Draft Guideline(s):
II.10 Ingredient Disclosure

II.8

L

Where they may exist, standard incentivizes the
manufacturer to publicly disclose any of the following:
-the results of existing LCAs,
-an Environmental Product Declaration (EPD) pursuant to
ISO standards; and/or
-the results of other environmental and human health
impact assessments
Addresses the following Draft Guideline(s):
II.11 Impact Assessment Disclosure

II.9

L

II.6

II.7

I

I

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

File Name(s) and Section or
Page Number

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Notes

-Text of standard: standard requires or gives credit for public
disclosure of results of existing LCAs and/or other existing
assessments of environmental and human health impacts.

Innovation. The standard meaningfully and measurably
-Text of criteria and explanation of how the approach is
addresses environmental and/or human health impacts in
innovative and how it results in improved environmental
some way not already recognized in the above criteria.
and/or human health performance.
Informational: To further EPA’s understanding in this area,
we are seeking information from SDOs on how to determine
whether the environmental and/or human health protection
criteria in the standard result in products that exceed the
Optional, to be determined by the SDO
industry average level of environmental and/or human
health performance for this product category.
Addresses the following Draft Guideline(s):
II.2 Measurability and Significant Measurable Difference
Informational: To further EPA’s understanding in this area,
we are seeking information from SDOs on how and when the
environmental and/or human health protection criteria in
Optional, to be determined by the SDO
the standard uses quantitative vs qualitative measures.
Addresses the following Draft Guideline(s):
II.2 Measurability and Significant Measurable Difference

Impact assessment methodologies for issues of toxicity, land use, biodiversity, water use and other spatially explicit impacts are nascent in LCA and there is not sufficient scientific evidence to reflect their effectiveness. For those impact areas, LCA is not sufficient in determining relative importance and other methods
(e.g., traditional toxicity risk assessment studies, hazard identification, biodiversity surveys/IUCN redlist threats, peer-reviewed scientific literature) should be utilized in making these determinations. Given the vast data gaps in life cycle assessment databases on these impact areas, even if new methods exist, the results
of the studies cannot be relied upon to determine importance.
19
There are a number of potential concerns surrounding weighting and aggregating of impacts. Weighting and aggregation of impacts introduces levels of subjectivity above and beyond the inherent uncertainty in any given impact indicator result. Therefore, such approaches run the risk of reducing transparency—
diminishing the opportunity to improve purchasers’ environmental literacy and hiding potential environmental and/or human health trade-offs.
20
An intrinsic hazard is the potential for harm based on the chemical structure and properties that define its ability to interact with biological molecules. A hazard-based approach, grounded in Green Chemistry principles, can reduce the use of hazardous substances, and lower overall risk to people and the environment.
While intrinsic hazard assessment may be the most cautious approach to identifying potential chemicals of concern, intrinsic hazard assessment does not necessarily reflect the overall safety/risk of the product and it does not represent the findings of a comprehensive risk assessment, as it does not consider possible or
probable exposure pathways. As such, the results of such an assessment do not necessarily reflect product safety nor the potential trade-offs associated with alternatives/substitutes elsewhere in a product's lifecycle nor impacts on the functional ("fitness for use") performance of the product. Finally, hazard
assessments may not distinguish between hazardous raw materials versus post-reacted and finished products.
21
PPM standards address unfinished (not final) products and have a more limited focus on performance issues related to specific aspects of production or preproduction, such as (for example) extraction or transport.
18

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

SECTION III: CONFORMITY ASSESSMENT22
III.1

B

III.2

L

III.3

B

III.4

L

III.5

B

III.6

L

III. 7

L

III.8

B

III. 8.1 B

-Accreditation certificate (as supplied in III: 1)
The CAB is defined and is independent from the organization
-Declaration that the CAB is independent from the producer.
whose products/services are being assessed for conformity.
-Organizational structure/chart of CAB entity showing
Addresses the following Draft Guideline(s):
independence from producers.
III.2 Independence
-Ownership structure of CAB explained/declared.
-Relevant text from policy/procedure on CAB entities
The standard, ecolabel and/or SDO are neutral as to the
showing independence from the SDO.
specific CAB entity being used; and more than one CAB can
-Accreditation requirements and or /screening procedure for
23
assess conformance to the standard.
determining independent CAB.
Reference: ISO/IEC 17007
-Declaration that the CAB is independent from the SDO
Addresses the following Draft Guideline(s):
-Demonstration that more than one CAB can provide CA
III.2 Independence
services to the standard, e.g. with public information.
-Quality procedures, advisory body minutes, management
The CAB periodically reviews risks to its impartiality, and
meeting minutes
takes appropriate steps to mitigate identified risks.
-Results of reviews and actions taken.
The CAB offers a sliding scale of conformity assessment fees
-Documentation of sliding fee scale (does not need to be
or other means to be accessible to small businesses.
publicly accessible). Demonstration of accessibility to small
Addresses the following Draft Guideline(s):
businesses.
III.3 Sliding fee scale
The CAB publicly discloses the scoring methodology and
levels achieved by products that conform to the standard;
-Documentation of scoring and levels achieved by products
and describes how the public can access this information.
that conform to the standard.
Addresses the following Draft Guideline(s):
-Description of where and how this information is made
III.x Information on Scoring [New Guideline SUBMITTED
publically available.
FROM GC MEMBER ON V2.0]
The CAB publicly discloses the credits achieved by products
that conform to the standard; and describes how the public
can access this information.
Addresses the following Draft Guideline(s):
III.x Information on Scoring [New Guideline SUBMITTED
FROM GC MEMBER ON V2.0]

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

-Documentation of credits/criteria achieved by products that
conform to the standard.
-Description of where and how this information is made
publically available.

The CAB provides public access to or disclosure of up to date
-Example description of means of CAB financial support
information on the means by which it obtains financial
-Description of where and how this information can be
support.
accessed.
Reflects ISO/IEC 17065 - 4.6
The CAB demonstrates (through accreditation by a member
24
-Accreditation certificate from a recognized accreditation
body to ILAC or IAF) conformance to relevant standards
within the ISO/IEC 17000 series, e.g., ISO/IEC 17065 {for the body meeting ISO/IEC 17011.
ecolabeling certification program scope in accordance with -The accreditation body meets international norms for
accreditation.
(ISO 14020)}; ; 17025 (testing); 17024 (personnel); 17020
-SDO criteria showing requirements for CAB.
(inspection).
-Copy of current certificate and scope of accreditation by
OR
CAB.
Apply the evaluation factors below, which are consistent
with the requirements of internationally accepted standards -CAB is accredited by a signatory of an international peer
evaluation organization.25
for operations of a conformity assessment body.
-The accreditation body has been evaluated in conformance
Addresses the following Draft Guideline(s):
to ISO/IEC 17011.
III.1 Follow relevant conformity assessment standards
III.4 Accreditation
Objective & Impartial Structure.
Organizational chart and management system of the CAB
-Policy on management system.
reflect impartiality of decision making on conformity
-Policy/ procedures showing independence.
assessment.
Reflects ISO/IEC 17065 - 5.1.1

III. 8.2 B

Formal decision-making procedures and thresholds are
-Procedures showing thresholds for determining
documented demonstrating rules for when conformance or
conformance.
nonconformance is determined by the CAB.

III. 8.3 B

Free from Undue Pressures.
The CAB does not allow commercial, financial or other
pressures to compromise impartiality, including ensuring
that personnel (management and staff) are free from such
pressures.
Reflects ISO 17065/IEC - 4.2.2

-Policy / procedure demonstrating that staff and
management remain impartial in their CA work and are not
subject to undue pressure.

File Name(s) and Section or
Page Number

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Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

B/L/I Proposed Final Assessment Criteria

III. 8.4 B

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

The CAB has a procedure or policy to ensure that the
personnel conducting conformity assessment have not had a
-Policy / procedure for managing conflicts of interest of staff.
professional relationship in the past two years nor on- going
-Policy that cover past and present relationships specific to
financial connection with the organization to which they are
the CA being undertaken.
providing their services.
Reflects ISO/IEC 17065 4.2 AND 5.2

III. 8.5 B

Documented Procedures.
Procedures are documented for CAB processes. For example,
-List of documented relevant policies and procedures.
procedures may be documented through a quality
-Documentation of quality management system, including a
management system that provides general management
copy of the internal audit and management review, log of
system documentation (e.g. manual, policies, and definition
complaints and comments, and corrective actions taken.
of responsibilities); control of documents; control of records;
-Other relevant documentation of procedures for conducting
management review; internal audit; corrective actions;
CA.
preventive actions.
Reflects ISO/IEC 17065 - 8.1

III. 8.6 B

Take All Necessary Steps to Evaluate Conformance.
The CAB demonstrates that it takes all steps necessary to
determine conformance with the standard, following the
principles of ISO 17000: 200426.
Reflects ISO/IEC 17065 – 7.4.1; 7.1.2; 7.2, 7.3, 7.4, 7.5, 7.6

III. 8.7 B

Role separation.
The CAB demonstrates that the process for making
conformity decisions includes an independent review that
the product has met the specified requirements.
Reflects ISO/IEC 17065 7.6

III. 8.8 B

Certification Conditions Specified.
The CAB demonstrates that it documents how and when
-Policy/procedure on how and when conformance is
conformance is granted, maintained, extended or suspended granted, maintained, extended or suspended; AND policy on
or withdrawn.
communication of this information
Reflects ISO/IEC 17065 - 7.6.2

III. 8.9 B

In the event that non-conformity is substantiated, the CAB
has a procedure that considers and decides on appropriate
action such as increased surveillance, reduction in the scope
-Policy / procedure on appropriate actions in cases of nonof the certification to remove non-conforming products,
conformity.
suspension of the certification or withdrawal of the
certification.
Reflects ISO/IEC 17065 - 7.11.1

III.
8.10

B

Records Management.
The CAB has procedures for ensuring documents are
identified, stored, protected, retrieved and retained and
disposed of to ensure the protection of confidential
information.
Reflects ISO/IEC 17065 - 8.4.1

III.
8.11

B

Dispute Resolution Procedures.
The CAB has a documented policy or procedures for
-Policy/procedure for complaints and appeals.
receiving, evaluating, resolving, and documenting complaints
-Sample records of complaints, and or appeals and corrective
and appeals.
actions taken.
Reflects ISO/IEC 17065 - - 7.13.1 (ISO/IEC 17065 takes out
term “disputes”).

III.
8.12

B

Traceability Procedures.
The CAB has traceability or chain-of-custody procedures
where this is necessary to ensure qualified products meet
the standard.

-Policy/procedure used to evaluate the product/process.
-Copy of an application to demonstrate all required
information is contained.
-Document describing application review process.
-Record that demonstrates that certification decisions were
adequately justified.
-Policy/Procedure describing the evaluation process and who
makes the CA review and decision.
-Procedure for quality management system.
-Policy / procedure documenting staffing roles for the CA
process.

-Policy/procedure for document control and retention
policy.
-Policy/ procedure to protect client confidentiality.
-Evidence of quality management system covering document
management and client confidentiality.

-Policy/ procedures for traceability/chain of custody by CAB
demonstrating conformance with the criteria.
OR justification of how this is not applicable.

File Name(s) and Section or
Page Number

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criteria and Evidence
Criter
-ia #

III.
8.13

III.
8.14

B/L/I Proposed Final Assessment Criteria

B

Periodic evaluation of marked products.
When continuing use of a conformity-assurance mark on a
product is authorized, the CAB periodically conducts
surveillance of marked products to ensure ongoing validity
of continued conformance.
Reflects ISO/IEC 17065 - 7.9.3

B

Content of Declarations of Conformity.
The CAB provides declarations of conformity that clearly
conveys information on: the name and address of the CAB;
the date conformity assurance is granted (if applicable);
name and address of the client; the scope of the conformity
-Example declaration of conformity meeting criteria listed.
assurance; the term or expiration date of conformity
assurance (if applicable); the signature or other defined
authorization of the person(s) of the CAB assigned such
responsibility.
Reflects ISO/IEC 17065 - 7.7.1 & 7.7.2

III.
8.15

B

III.
8.16

B

III.
8.17

B

III.
8.18

B

III.
8.19

B

III.
8.20

B

SDO Submission

Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
to IAE review)4

File Name(s) and Section or
Page Number

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

-Policy/procedures on how long products can display the
certification mark demonstrating conformance.
-Policy/procedure indicating surveillance activities.
-Copy of market surveillance report.

Suitable Action for Misuse.
The CAB has established procedures to control the use of its
licenses, certificates, marks of conformity, and any other
mechanisms for indicating a product is conformant, including -Policy / procedure to take action on incorrect, misleading,
market surveillance. Procedures describe actions to take for or unauthorized use of marks or licenses.
incorrect, misleading or un-authorized use of its mark and
licenses.
Reflects ISO/IEC 17065 - 4.1.3.1, 7.11.1, 7.9.3 and 7.9.4
Quality Objectives.
The CAB has a documented commitment to fulfilling quality
-Policy / procedure indicating commitment to quality
objectives and/or an established quality management
-Quality management system documentation.
system that is implemented in the CAB’s organization.
Reflects ISO/IEC 17065 - 8.2.1.
Sufficient Personnel.
-Description by CAB on how it ensures that its staff is
The CAB has a process to ensure that they have sufficient
qualified for CA activities.
personnel with the education, training, technical knowledge -Description of staffing requirements.
and experience necessary for performing conformity
-Qualifications stated in job advertisements for certification
assessment functions.
staff.
Reflects 17065/IEC - 6.1.1.1
-Records/ CVs of personnel reflecting required qualifications
Adequate Facilities & Equipment.
-Description of facility and equipment required to conduct
The CAB has all the facilities and equipment needed to carry
certification.
out its work; if testing is required by the standard,
-If testing is required for certification, laboratories are in
competent and/or accredited laboratories are utilized.
conformance with ISO 17025 or equivalent standard.
Broadly reflects ISO/IEC 17065 - 7.3.1
Transparent Process.
The CAB maintains through publications, electronic media or
other means, and makes available upon request, information
-Documentation of appropriate and timely information
about the conformity assessment process including the rules
disclosed publicly or available on request about the CAB
and procedures for granting maintaining, extending,
certification processes.
reducing the scope of, suspending, withdrawing or refusing
conformity assurance.
Reflects ISO/IEC 17065 - 4.6
Information on Fees.
The CAB provides general information on fees, and/or makes -Example communication to applicants that includes
this information available to applicants and clients.
information on fees.
Reflects ISO/IEC 17065 - 4.6

If a standard does not have an associated second- or third-party conformity assessment program, or it is determined that a supplier’s declaration is sufficient for a particular product standard, then this section of the Guidelines would not be applicable. Moreover, the Nov 2013 FAQ noted in answer to the question “Will
3rd party certification of products be required to meet the guidelines?” that the draft guidelines do not require manufacturers to seek third party conformity assessment. The EPA and the Federal interagency group that developed the draft guidelines recognized that the appropriate method of conformity assessment
may vary across product categories based on cost, risk, and other factors.
23
Note that the revenue from conformity assessment is often necessary to offset the significant investment in standards development and, to address any issues (perceived or real) related to conflicts of interest, organizations should separate the management and operations of conformity assessment and standards
development.
24
Examples of US-based members to ILAC and/or IAF include ANSI; A2LA; IAS; LAB; NVLAP.
25
For example, those who are members of the International Accreditation Forum, http://www.iaf.nu/articles/Accred_Body_Members_by_Name/52
26
ISO 17000: 2004: Vocabulary and General Principles. See: http://www.iso.org/iso/catalogue_detail.htm?csnumber=29316
22

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criter
-ia #

B/L/I Proposed Final Assessment Criteria

Criteria and Evidence
SDO Submission
Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
File Name(s) and Section or
to IAE review)4
Page Number

SECTION IV: MANAGEMENT OF ECOLABELING PROGRAMS27

B

The ecolabel program has a documented commitment to
fulfilling quality objectives and/or an established quality
management system28 that is implemented in the
organization.
Addresses the following Draft Guideline(s):
IV.1 Document Commitment to Quality

-Policy / procedure indicating commitment to quality.
-Evidence of a documented Quality management system
documentation.

B

The ecolabel program has established a methodology and
procedure to evaluate the effectiveness of addressing
environmental and/or human health impacts covered by its
standard.
Addresses the following Draft Guideline(s):
IV.2 Evaluate Effectiveness

-Procedure for completing the evaluation including a
discussion of impact categories addressed, methods, data
sources, indicators, time line.
-Description of the methodology selected; including any
methodology standards or norms referenced such as impact
evaluation or the ISEAL Impacts code29.

IV.3

L

An evaluation, by the ecolabel program or a third-party, of
the effectiveness of a standard in reducing environmental
and/or human health impacts has been completed within
the previous 5 years.
Addresses the following Draft Guideline(s):
IV.2 Evaluate Effectiveness

-Copy of completed report and publication date.
-Description of methods and data sources used.

IV.4

L

IV.5

B

IV.6

B

IV.7

B

IV.8

L

IV.9

B

IV.1

IV.2

IV. 10 B

Results of the evaluation are publicly available.
-Evidence that evaluation reports are publicly available; for
Addresses the following Draft Guideline(s):
example, publication of report online, website link, or
IV.2 Evaluate Effectiveness
statement that report available on request.
The ecolabel program has a documented and publicly
-Policy/procedure for complaints and appeals.
available policy or procedures for receiving, evaluating,
-Sample records of complaints, and/or sample of appeals
resolving, and documenting complaints and appeals
and corrective actions taken.
concerning the management of the ecolabel program.
-Public website address for complaints and appeals.
Addresses the following Draft Guideline(s):
IV.3 Dispute Resolution Process
The ecolabel program makes publicly available the
stakeholders30 who are involved in the ongoing governance
-Public website address with stakeholders listed.
and/or operations of the ecolabel program.
-Description of availability of information on stakeholders.
Addresses the following Draft Guideline(s):
IV.4 Disclose Stakeholders
The ecolabel program does not allow commercial, financial
or other pressures to compromise the confidentiality,
objectivity or impartiality of its operations and decisions that
-Policy / procedure demonstrating that staff and
affect awarding the mark or registration, including ensuring
management are able to remain impartial in its decisions
that personnel (management and staff) are free from such
concerning the ecolabel program.
pressures.
Addresses the following Draft Guideline(s):
IV.6 Free from Undue Pressures
The ecolabel program provides public access to, or
-Description of the types and sources financial support the
disclosure of, up- to-date information on the types of
ecolabel program relies on to support its work, such as
financial support received for administering the ecolabel
application fees, license fees, royalties, membership fees,
program.
grants, sale of other goods and services, etc.
Addresses the following Draft Guideline(s):
-Description of where and how this information can be
IV.8 Information on Financial Support
accessed.
The ecolabel program provides general information on fees,
-Fee schedule information OR
and makes this information available to applicants.
-Process by which stakeholders and applicants can request
Addresses the following Draft Guideline(s):
information on fees (from ecolabel program, CAB or both).
IV.9 Information on Fees
The ecolabel program makes publicly available (free of
charge or for a reasonable cost) the criteria and/or standard. -Internal URL for accessing the criteria and/or standard and
Addresses the following Draft Guideline(s):
how interested parties can access the standard.
IV.10 Publicly Available Criteria

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criter
-ia #

Criteria and Evidence
SDO Submission
Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
File Name(s) and Section or
to IAE review)4
Page Number
-Declaration that no other conditions or limits are placed on
The ecolabel program grants the label, mark, or registration products or applicants in granting the use of the mark
if the product is demonstrated to be in conformance with
beyond those required by the standard and or administrative
the applicable standard, and the applicant meets the
or technical requirements of the program.
administrative and technical requirements of the program -Policy or procedure stating the conditions by which the
(such as paying fees, and accepting license agreements).
label/mark/declaration will be granted and an explanation as
Addresses the following Draft Guideline(s):
to its purpose and why they are reasonable.
IV.11 Grant the Use of the Mark
-Statement of which organization conducts these activities –
the ecolabel program, CAB, or both.
The ecolabel program has established procedures to control
the use of its licenses, certificates, marks of conformity, and
-Policy / procedure to take action on incorrect, misleading,
any other mechanisms for indicating a product meets the
standard. Procedures describe actions to take for incorrect, or unauthorized use of marks or licenses.
-Statement of which organization conducts these activities –
misleading, or un-authorized use of its mark and licenses
the ecolabel program, CAB, or both.
including suspension or removal of the mark if warranted.
Addresses the following Draft Guideline(s):
IV.12 Suitable Action for Misuse
The ecolabel program has established procedures to
-Policy / procedure requiring market surveillance by ecolabel
periodically conduct market surveillance to check for
program and/or the CAB.
incorrect, unauthorized use of its licenses, certificates, and -Statement of which organization conducts these activities –
marks of conformity, and is responsive to complaints of
the ecolabel program, CAB, or both.
misuse or misinterpretation in the marketplace.
-Procedure or resource for receiving complaints of misuse or
Addresses the following Draft Guideline(s):
trademark violations
IV.12 Suitable Action for Misuse
-Example of a market surveillance report.
If an ecolabel is associated with more than one
-Consumer testing to make sure ecolabels associated with
standard/certification, those ecolabels are markedly
more than one standard are clearly interpreted as to the
different from each other in application as not to confuse
differences.
the marketplace or inflate a sense of compliance.

B/L/I Proposed Final Assessment Criteria

IV. 11 B

IV. 12 B

IV. 13 L

IV. 14 L

IV. 15 L

IV. 16 L

IV. 17 L

Ecolabel programs participate in mutual recognition
-Documentation of participation in associations and fora
activities such as equivalency assessments; formal mutual
such as ISO, ISEAL Alliance, Global Ecolabelling Network,
recognition of standards; and/or technical, administrative, or ASTM, etc.
CA procedures.
-Documentation of public statement in which ecolabel
Addresses the following Draft Guideline(s):
programs and or standards are mutually recognized and on
IV.13 Mutual Recognition
what grounds.
-Example of the Directory in current use by the ecolabel
The ecolabel program makes publically available a directory
program and/or CAB.
of conformant products and their brand owner. The
-Instructions as to how access to the directory is provided to
directory is up to date, and/or has been updated in the last 6
the public.
months.
-Date of last update to the directory is provided.
Addresses the following Draft Guideline(s):
-Demonstration that the directory was updated in the last 6
IV.14 Publicly Available Directory
months prior to the pilot assessment.
IV.15 Current Directory
-Dates of when products are added to directory provided.
The ecolabel program’s directory of conformant products
-Explanation or demonstration of how the directory is able
and their brand owner can be searched so that users can
to be searched.
find conforming products and suppliers
-Note that “searched” is not meant to imply a full online
Addresses the following Draft Guideline(s):
database. Search functions are also found in commonly used
IV.16 Searchable Directory
tools such as MS Word, MS Excel and Adobe PDF.

I

Informational: To further EPA’s understanding in this area,
we are seeking information from ecolabel programs on
if/how they provide regional information regarding labeled
products (e.g., information on the location of suppliers;
national or sub-national regions where products are
available on the market.)
Addresses the following Draft Guideline(s):
IV.17 Regional Information

I

Informational: To further EPA’s understanding in this area,
we are seeking information from ecolabel programs on
-Example of analysis of marketplace uptake of the ecolabel
if/how the ecolabel program conducts or participates in a
products including market share, recognition in institutional
periodic analysis and/or publishes the uptake of the ecolabel procurement guidelines of the ecolabel or standard, or other
in the marketplace.
indicators of the ecolabel’s presence.
Addresses the following Draft Guideline(s):
-Example of market report published.
IV.18 Analyses of Market Uptake

-Directory showing supplier addresses/location information.
-Directory showing where products are available (country,
state, other sub-national region).

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Count of Leadership criteria met (need to meet at least six overall, including at least three from
Section II, to be eligible for "exceeds EPA's 2016 criteria" designation)

Criter
-ia #

B/L/I Proposed Final Assessment Criteria

I

Criteria and Evidence
SDO Submission
Example Sources of Evidence (one may be sufficient subject SDO Response/Comment
File Name(s) and Section or
to IAE review)4
Page Number

Completeness
Check

Gaps or
Clarifications

0

IAE Assessment
Y/N Justification

Notes

Informational: To further EPA’s understanding in this area,
we are seeking information from ecolabel programs
-Definition of interest/stakeholder categories relevant to the
regarding rules and procedures that aim to ensure a balance
ecolabel program.
of interests among stakeholders in the program’s
-Documentation of formal rules and procedures for ensuring
governance.
balance of interest.
Addresses the following Draft Guideline(s):
IV.5 Balance of Interests

The Management of Ecolabeling Programs Guidelines would not apply to product environmental standards that are not associated with an ecolabel.
A quality management system is a formalized system that documents the structure, responsibilities, and procedures required to achieve effective quality management. American Society for Quality (ASQ) Quality Glossary. Accessed online 12/3/2015 at http://asq.org/glossary/q.html. An example of as standard for
quality management system is ISO 9000, see http://www.iso.org/iso/home/standards/management-standards/iso_9000.htm.
29
The ISEAL Code of Good Practice for Assessing the Impacts of Social and Environmental Standards (Impacts Code). Accessed online 12/3/2015 at: http://www.isealalliance.org/our-work/defining-credibility/codes-of-good-practice/impacts-code
30
Stakeholders are defined as those organizations or individuals directly and materially affected by the ecolabel program and who have an ongoing relationship with the program and are involved in either its governance and/or operations.
27
28