There are no national standards on sustainability for products. In this vacuum, the U.S. Environmental Protection Agency (EPA) is seeking public comment regarding the EPA’s role (within its authority provided in the 1990 Pollution Prevent Act) in the ‘‘green’’ or sustainable products process. In order to affect EPA’s final policy, private companies must provide written comments by October 19, 2010. Such comments must provide information, address policy and legal issues, and include proposals concerning EPA’s role and ultimate strategy defining how EPA can make a meaningful contribution to the development, manufacture, designation, and use of sustainable products.
The EPA is seeking views on the following questions and issues:
• What do you see as the major policy and research challenges, opportunities, and trends impacting the development, manufacture, designation, and use of sustainable products?
• What do you see as EPA’s overall role in addressing these challenges and opportunities?
• In particular, how do you see EPA’s role in:
o Assembling information and databases.
o Identifying sustainability ‘‘hotspots’’ and setting product sustainability priorities.
o Evaluating the multiple impacts of products across their entire life cycle.
o Defining criteria for more sustainable products.
o Generating eco-labels and/or standards.
o Establishing the scientific foundation for these eco-labels and/or standards.
o Verifying that products meet standards.
o Stimulating the market.
o Developing end-of-life management systems (reuse, recycling, etc.).
o Measuring results, evaluating programs.
EPA’s Assistant Administrator for Research and Development (Dr. Paul Anastas) recently declared that sustainability is EPA’s “North Star” for its future programs. Many of the new political appointees at EPA have long histories of supporting sustainability, particularly the substitution of less toxic substances in consumer products. Thus, this announcement may well be the first step in developing a significant role for EPA in determining how to implement sustainability. It is likely that EPA will seek to incorporate its road map into the Toxic Substances Control Act bills pending in Congress. Whether sustainability enhances a company’s market or may endanger its market, companies should comment now in order to be able to influence the direction of future policy and regulation. Those wishing to submit comments can find more information at the Federal eRulemaking Portal by clicking here and typing “Sustainable Products” in the keyword search box.
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