ISSA has called upon Green Seal® to devise a path forward that would drive out the substantial costs associated with revisions it has proposed to its environmental standard for institutional and industrial cleaners (GS-37), in comments submitted earlier this year by ISSA Legislative Affairs Director Bill Balek. Also, as a member of the GS-37 Revision Executive Committee, ISSA acted as a catalyst in effecting a positive change to the voting procedures that will be used by stakeholders voting on the GS-37 revisions.
In addition to the costs associated with the price of certification, ISSA noted in its comments that the proposed revisions to GS-37 would likely require the generation of additional data at the price of thousands of dollars per product. “Ultimately, if left unchecked, these and other costs associated with certification will act as a financial barrier to small- and medium-sized formulators of cleaning products,” Balek said.
In its comments, ISSA also urged Green Seal to address the process of transitioning to a new GS-37 standard, an issue that heretofore has gone unaddressed. Given the huge financial and operational implications the transition process has for industry, ISSA’s Balek urged Green Seal to consider a process that would “grandfather” currently certified products to soften the blow.
ISSA’s comments were submitted as part of the public-comment phase in the process of revising GS-37. Green Seal anticipates that it will release a final revised version of GS-37 by June 2008, after the proposed revisions undergo one more comment period that will be limited only to registered stakeholders.
Other issues addressed in ISSA’s comments include proposed volatile organic compound, or VOC, limitations, packaging requirements, asthmagens, dispensing system concentrates, and other related subjects.
If you would like a copy of the full text of ISSA’s comments on the proposed revisions to GS-37, please send an e-mail with “ISSA GS-37 Comments” in the subject line to Bill Balek at
