2516.01_Attachment 7-2

May 18, 2015
Submitted Electronically
Docket Number: EPA-HQ-OPPT-2014-0838
Public Comments on Assessment of Environmental Performance Standards and
Ecolabels for Federal Procurement
Ms. Julie Shannon
Chemistry, Economics, and Sustainable Strategies Division
Office of Pollution Prevention and Toxics
Environmental Protection Agency
1200 Pennsylvania Ave, NW
Washington, DC 20460-0001
Dear Ms. Shannon,
UL LLC appreciates the opportunity to comment on the Environmental Protection Agency
(EPA) request for comments on Notice EPA-HQ-OPPT-2014-0838FRL-9923-58 “Agency
Information Collection Activities; Proposed Collection and Comment Request; Assessment
of Environmental Performance Standards and Ecolabels for Federal Procurement” (the
Notice).
UL is a mission-driven, global, independent, safety science company with more than a
century of expertise dedicated to promoting safe living and working environments. Since our
founding in 1894, UL’s engineers and staff have helped develop safety standards and
product-testing protocols, conducted independent product safety testing and certification,
and inspected manufacturing facilities around the world. UL is driven by our global safety
mission, which promotes safe living and working environments. Further, UL also participates
in many international standards development technical committees as well as international
conformity assessment schemes and national certification programs in an effort to
continually advance our mission, and to work towards international harmonization where
possible.
Building on our product safety expertise and history, UL also develops standards for
sustainable products, tests and evaluates product chemical emissions, manages several
environmental certification programs, and certifies environmental product declarations in
accordance with established product category rules. UL’s sustainability-focused
certifications and programs, such as GREENGUARD and ECOLOGO®, are recognized and
referenced in more than1,000 sustainable product specifications and purchasing guidelines.
Additionally, UL is the exclusive provider of GREENGUARD Certification for products that
meet stringent chemical emissions requirements and ECOLOGO Certification for products
that meet multi-attribute, life cycle-based sustainability standards.
UL is keenly aware of the impact that “greenwashing” has on consumer and institutional
purchaser decision-making. Our “Sins of Greenwashing” reports
(http://sinsofgreenwashing.com/) illustrate how prevalent the practice is and the need for
robust ecolabels to help instill confidence that consumers are making informed choices. For
these reasons, we applaud EPA’s efforts to assess environmental performance standards
and ecolabels for use in federal procurement and are eager to have our standards and

labels included in the pilot projects for building flooring, paints/coatings/removers, and
furniture.
In addition to volunteering our ecolabels for evaluation in the pilot, UL is also interested in
participating in the “purchase category panels” being formed to develop the product
category checklists against which the various labels will be evaluated against.
UL would be pleased to further discuss the content of our submission with you and your
team. Please contact me with any questions. Thank you for your time and consideration.
Sincerely,

Derek Greenauer
Director,
Global Government Affairs, UL LLC
[email protected]
202-296-8092
CC:
Mark Rossolo, Manager, Public Affairs, UL Environment