Attachment 10 -Public Comment RFC

April 29, 2022
Via electronic submission to regulations.gov
Office of Chemical Safety and Pollution Prevention
United Stated Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Re:

Agency Information Collection Activities; Proposals, Submissions, and
Approvals: Assessment of Environmental Performance Standards and Ecolabels
for Federal Procurement; Docket ID No. EPA-HQ-OPPT-2014-0838

To whom it may concern:
The Resilient Floor Covering Institute (RFCI) appreciates this opportunity to provide
comments to the United States Environmental Protection Agency (EPA) regarding its Information
Collection Request (ICR) in connection with its Assessment of Environmental Performance
Standards and Ecolabels for Federal Procurement (87 Fed. Reg. 11426 (Mar. 1, 2022)).
Attached please find comments of RFCI’s technical consultant Jane Rohde regarding this
ICR. If you have any questions regarding these comments or if RFCI can provide additional
information regarding this topic, please contact me ([email protected]) or RFCI legal
counsel Allison Foley, Venable LLP ([email protected]).
Sincerely,

Bill Blackstock
President and CEO, RFCI
Attachment

Comments of Resilient Floor Covering Institute
Docket ID No. EPA-HQ-OPPT-2014-0838
April 29, 2022
File name: Attachment1_Section IV.14_Machine readable directory.
The following comments relate to the referenced language contained in the document titled:
“ADDENDUM: Changes in the 2022 Update of the United States Environmental Protection
Agency’s Framework for the Assessment of Environmental Performance Standards and Ecolabels
for Federal Purchasing.”1
Reference Language:
SECTION IV: MANAGEMENT OF ECOLABELING PROGRAMS
New criteria: IV.14 – L – Machine readable directory. The ecolabel program’s public
directory of conformant products/services and their brand owner (as covered in IV.6)
provides the directory in such a way that other programs can efficiently access the
information, and the data are “machine readable”.
Comment: “Machine Readable” does not equate to the inclusion of an application program
interface (API) that connects one programmable database to another to easily access information,
which based on the Criterion and Evidence section of the updated Framework recommendations,
appears to be the goal. It is assumed that “Machine Readable” as referenced here would be
“digitized” information that can be “digitally scanned.” For example, the OpenEPD – an open data
format developed by Building Transparency – allows for the data to be extracted in a consistent
manner when digitized into the Embodied Carbon Construction Calculator (EC3) database and
tool. However, some ecolabels and certifications do not include data that needs to be extracted, as
they are compliant with a standard or other guideline that is consensus based, and there is a
certificate that is needed by the specifier for documentation demonstrating third party verification
and compliance to an environmentally preferrable product program and/or building rating system.
In working as a specifier and sustainability consultant, utilizing Mindful Materials, Sustainable
Minds Transparency Catalogue, and ecomedes (including SFTool, Business and Institutional
Furniture Manufacturer’s Association (BIFMA), and RFCI product category specific databases
and manufacturer dedicated databases) that include a direct link to the declaration (e.g.,
Environmental Product Declaration (EPD), Health Product Declaration (HPD)) or certificate (e.g.,
FloorScore, Level), it would not be helpful to the specifier or procurement agent to have digitized
information, but only the certificate, declaration, embodied carbon (Global Warming Potential
(GWP)) information, etc. Therefore, the following proposed language is provided for
consideration:
Proposed Language:
SECTION IV: MANAGEMENT OF ECOLABELING PROGRAMS
IV.14 – L – Ecolabel access. The ecolabel’s Program Operator public directory of
conformant products/services and their brand owner (as covered in IV.6) provides a
directory of certified products and support documentation that can be publicly accessed

1

Available at https://www.epa.gov/system/files/documents/2022-02/updated-framework-addendum_020222.pdf.

Comments of Resilient Floor Covering Institute
Docket ID No. EPA-HQ-OPPT-2014-0838
April 29, 2022
and is available for other public material and product databases directly through an API
and/or a link that provides the documentation required demonstrating compliance to an
accepted ecolabel.
Clarification Impacts: By providing ease of public access to information that is downloadable
and retrievable, the procurement agent and/or specifier can easily compile the various
sustainability and health and wellness ecolabels required for compliance to the Environmentally
Preferable Purchasing (EPP) Program. Although some databases benefit from the utilization of
digitized information for furthering accuracy within their collection process of data, this would not
always be relevant to various types of ecolabels that would be required by EPA and/or used by the
procurement agent or specifier. The current language combines both access (which is the goal) and
the electronic process for collecting data, which is certification or data specific, not ecolabel
specific. Therefore, the revised language is recommended for consideration for usability in support
of compliance to the EPP Program. The current language could be confusing as well as onerous
for compliance by those certifying products based on the type of ecolabel being provided (e.g.,
ecolabels based on product category specific and/or process and production method (PPM)
standards).
Thank you for considering these comments.
Respectfully submitted,
Jane M. Rohde, Technical Consultant
Resilient Floor Covering Institute

Additional commenter credentials and experience:
Jane M. Rohde, AIA, FIIDA, ASID, ACHA, CHID, LEED AP BD+C, GGA-EB, GGF
Principal, JSR Associates, Inc.
Technical Consultant, Resilient Floor Covering Institute
Ms. Rohde is a registered architect and certified interior designer and certified by the American
College of Healthcare Architects (ACHA) and the American Academy of Healthcare Interior
Designers (AAHID). As a consultant for RFCI, Ms. Rohde has led the task force for developing
the now public-facing resilient floor covering product category on Building Transparency’s EC3
tool, collaborated with the ecomedes® team to develop a resilient floor covering dedicated product
sustainability database, and has served as part of the Joint Committee for the revision of the
NSF/ANSI 332 Sustainability Assessment for Resilient Floor Coverings anticipated for
publication on May 15, 2022. In addition, Ms. Rohde sits on the General Services Administration
(GSA) Green Building Advisory Committee (GBAC), participates as a consultant on the ASHRAE
189.1 Standard Development Committee: WG08 Indoor Environmental Quality and WG09

Comments of Resilient Floor Covering Institute
Docket ID No. EPA-HQ-OPPT-2014-0838
April 29, 2022
Materials Work Groups, and is a voting member on the ASHRAE 189.3 Standard Development
Committee and participates specifically in WG08 Indoor Environmental Quality and WG09
Materials Work Groups.