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EPA Can Help Consumers 

Identify Household and Other 

Products with Safer Chemicals

by Strengthening Its “Design 

for the Environment” Program 

Report No. 14-P-0349 September 9, 2014

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL
Report Contributors: Laurie Adams

Daniel Carroll

Jerri Dorsey

Gabby Fekete

Jeffrey Harris

Abbreviations

DfE Design for the Environment

EPA U.S. Environmental Protection Agency

OIG Office of Inspector General

PM Performance Measure

Cover photo: EPA photo illustrating the use of household cleaners.

(Design for the Environment website) 

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14-P-0349

September 9, 2014

Why We Did This Review

We conducted this review of the 

U.S. Environmental Protection 

Agency’s (EPA’s) “Design for 

the Environment” (DfE) Safer 

Product Labeling Program to 

determine how effectively the 

program highlights safer 

products for consumer use. 

For more than 15 years, the 

DfE Safer Product Labeling 

Program has labeled products 

that meet the criteria to be 

considered safer for families 

and the environment. According 

to the EPA, the DfE logo means 

that the product contains only 

those ingredients that pose the 

least concern among chemicals 

in their class. DfE products 

include car care products, 

carpet cleaners, dish and hand 

soaps, floor care products, 

laundry detergents, and glass 

cleaners.

The report addresses the

following EPA goal or

cross-agency strategy:

 Ensuring the safety of 

chemicals and preventing 

pollution.

Send all inquiries to our public

affairs office at (202) 566-2391

or visit www.epa.gov/oig.

The full report is at:

www.epa.gov/oig/reports/2014/ 

20140909-14-P-0349.pdf

EPA Can Help Consumers Identify Household 

and Other Products with Safer Chemicals by 

Strengthening Its “Design for the Environment”

Program 

 What We Found

We found that the current DfE logo does not 

adequately communicate to the consumer that the 

product is a safer product. We also found a risk that 

an EPA endorsement of DfE products may be

implied by the current logo, but EPA endorsement is 

not allowed. The EPA also lacks sufficient controls over the use of its DfE logo by 

former program participants. This can be misleading for consumers and is a 

violation of the DfE partnership agreement.

We also found that the EPA asserts that DfE products are cost effective, but this 

has not been determined or reviewed. Further, there are weaknesses in both 

former and proposed performance measures used by the DfE program and the

EPA cannot accurately determine the program’s impact on pollution prevention.

Addressing the issues noted should further EPA goals, better promote safer 

products, and support DfE brand recognition among consumers.

 Recommendations and Agency Planned Corrective Actions

We recommend that the Assistant Administrator for Chemical Safety and Pollution 

Prevention improve the DfE logo, periodically review program participants’ 

compliance with partnership agreements and address noncompliance with those

agreements, remove statements on the EPA’s website that imply that DfE 

products are cost effective, and improve performance measurement. The EPA 

agreed with our recommendations and proposed acceptable corrective actions. 

The agency fully addressed one recommendation and it is therefore closed, while

the remaining recommendations are resolved with corrective actions underway.

 Noteworthy Achievements 

DfE has evaluated and approved more than 2,500 products to carry the DfE logo. 

The EPA updated the Safer Chemical Ingredients List in 2014, adding over 

50 chemical ingredients and bringing the number of safer chemical ingredients to 

approximately 650. DfE has also developed a new database system that will 

enable the agency to better manage chemical, partner and product information in 

a cloud-based system. 

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

Strengthened controls 

in the DfE program can 

help consumers better 

identify safer products.
September 9, 2014

MEMORANDUM

SUBJECT: EPA Can Help Consumers Identify Household and Other Products with Safer Chemicals

by Strengthening Its “Design for the Environment” Program 

Report No. 14-P-0349

FROM: Arthur A. Elkins Jr.

TO: Jim Jones, Assistant Administrator

Office of Chemical Safety and Pollution Prevention

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe problems the 

OIG has identified and corrective actions the OIG recommends. This report represents the opinion of the 

OIG and does not necessarily represent the final EPA position. Final determinations on matters in this 

report will be made by EPA managers in accordance with established audit resolution procedures. 

The EPA office having primary responsibility for the issues evaluated in this report is the Office of 

Chemical Safety and Pollution Prevention’s Office of Pollution Prevention and Toxics.

Action Required

You are not required to provide a written response to this final report because you provided agreed-to 

corrective actions and planned completion dates for the report recommendations. The OIG may make 

periodic inquiries on your progress in implementing these corrective actions. Should you choose to 

provide a final response, we will post your response on the OIG’s public website, along with our 

memorandum commenting on your response. You should provide your response as an Adobe PDF file 

that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as 

amended. 

We will post this report to our website at http://www.epa.gov/oig. 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
EPA Can Help Consumers Identify 14-P-0349

Household and Other Products with Safer Chemicals

by Strengthening Its “Design for the Environment” Program

Table of Contents

Purpose...................................................................................................................... 1

Background ............................................................................................................... 1

Responsible Office.................................................................................................... 2

Noteworthy Achievements ....................................................................................... 2

Scope and Methodology........................................................................................... 3

Results of Review ..................................................................................................... 3

EPA’s DfE Goals Can Be Enhanced Through Logo Improvements..................... 4

EPA’s DfE Website Has Unsupported Program Benefit Claims .......................... 5

Weaknesses Exist in EPA’s Measurement of DfE Program Results ................... 5

Conclusions............................................................................................................... 6

Recommendations .................................................................................................... 7

Agency Comments and OIG Evaluation .................................................................. 7

Status of Recommendations and Potential Monetary Benefits ............................. 8

Appendices

A Agency Response to Draft Report................................................................... 9

B Distribution ....................................................................................................... 12
14-P-0349 1

Purpose

Our objective was to determine how effectively the U.S. Environmental 

Protection Agency’s (EPA’s) “Design for the Environment” (DfE) Safer Product 

Labeling Program is highlighting safer products for consumer use.

Background

The DfE program is one of the EPA’s pollution prevention programs. The EPA’s 

pollution prevention programs are designed to reduce or eliminate waste at the 

source by modifying production processes, promoting the use of non-toxic or 

less-toxic substances, implementing conservation techniques, and re-using 

materials. The DfE achieves pollution prevention by promoting safer product 

design and green chemistry. Based on data reported by the EPA, DfE is being 

reported as the agency’s most successful pollution prevention program in 

reducing reported pounds of hazardous materials—the DfE alone accounted for 

nearly half of all EPA-claimed pollution reductions in recent years. 

The DfE program incentivizes companies to manufacture products that contain 

safer chemicals than other alternative products on the market. Companies can join 

the program and label their products as DfE-certified if they have met the 

program’s standards. The process used by the EPA to qualify products for the DfE 

labeling program is illustrated in figure 1. 

Figure 1: DfE Product Qualification Process

 Source: DfE program.
14-P-0349 2

The DfE logo, as shown in figure 2, is the EPA’s label 

for safer chemical products. For over 15 years, the DfE 

Safer Product Labeling Program has labeled products 

that meet the criteria to be considered safer for families 

and the environment. According to the EPA, when the 

DfE label appears on a product, it means that each 

ingredient in the product has been screened for potential 

human health and environmental effects and that the 

product contains only those ingredients that pose the 

least concern among chemicals in their class. DfElabeled products include all-purpose cleaners, dishwasher detergents, car care 

products, carpet cleaners, dish and hand soaps, floor care products, laundry 

detergents and softeners, leather cleaners, toilet bowl and tub/tile cleaners, 

window/glass cleaners, and wood cleaners.

Applicants for the DfE label must fully disclose all ingredients to the DfE 

program and a qualified third-party profiler. Currently there are two third-party 

profiler companies. For each DfE product, a third-party profiler compiles hazard 

information on each chemical ingredient, including its detailed structure, 

physical-chemical properties, human health and environmental toxicology, and 

regulatory status. A product is only allowed to carry the DfE label if each 

ingredient is among the safest in its ingredient class. Additionally, the product as 

a whole has to meet safety criteria, qualify as high performing, and be packaged 

in an environmentally friendly manner. Once products are approved by DfE, each 

manufacturer must sign a partnership agreement that outlines the program’s 

requirements, including audits and product renewals. 

Responsible Office

The EPA office having primary responsibility for the DfE program is the Office 

of Chemical Safety and Pollution Prevention’s Office of Pollution Prevention and 

Toxics.

Noteworthy Achievements

DfE has evaluated and approved more than 2,500 products to carry the DfE logo.

In 2012, the EPA developed the Safer Chemical Ingredients List, which contains 

chemicals that meet the criteria of the DfE Safer Product Labeling Program. In 2014, 

the EPA updated the list by adding over 50 chemicals, bringing the number of safer 

fragrance chemical ingredients to over 150 and the total number of safer chemical

ingredients to approximately 650. 

Additionally, DfE has developed the “DfE Product Portal” database, providing

pertinent program-related information within one internal database system. 

According to the EPA, the primary function of this database is to manage 

chemical, partner and product information in a cloud-based system. The new 

Figure 2: DfE Logo

Source: DfE website. 
14-P-0349 3

system will address shortcomings of the prior, outdated database and address 

functional needs of the program. For example, the database will lend itself to 

faster review of partnership applications and access to historical data related to 

partnership history and decisions.

Scope and Methodology

We conducted our work from November 2013 through July 2014. We conducted 

this performance audit in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives.

We reviewed relevant materials, including laws, policies, procedures and reports. 

We documented the universe of DfE consumer products. We randomly selected a 

sample item from each of the eight product categories that had 25 or more 

approved products and we reviewed the files held by the EPA for those products. 

Specifically, we reviewed the requirements under the program, documentation 

provided by the third-party profilers, audit results and product labels. We also 

reviewed a sample of 30 products to determine compliance with label 

requirements.

We interviewed key agency staff, including the DfE Program Chief and the staff 

charged with reviewing third-party profiler decisions, developing alternatives 

assessments and new sector standards, reporting on performance measures, and 

promoting the DfE program. We interviewed the head toxicologists at the two 

third-party profilers who conduct the product assessments for the DfE program. 

We reviewed the program’s goals and measures, with particular focus on how the 

measures are calculated and reported over time. We conducted a brief inspection 

at the retail-store level to assess consumer ability to easily detect safer product 

labeling information.

Results of Review

The DfE program intends to help consumers make wise choices by identifying 

safer products. However, we found issues in the design and use of the program 

logo that impede brand recognition. There is also the potential for consumers to 

draw the interpretation that EPA endorses DfE products, which is not allowed, 

and potential misuse of the logo by former program participants. Also, the agency 

asserts that DfE products are cost effective, but this has not been determined or 

reviewed. Further, we found weaknesses in how the performance of the DfE 

program is measured. 
14-P-0349 4

EPA’s DfE Goals Can Be Enhanced Through Logo Improvements

The EPA states that the DfE label helps consumers easily choose safer products.

However, we identified factors in the design and placement of the label that could 

impede product promotion and DfE brand recognition. We also found issues 

potentially impacting the integrity of the DfE logo.

The current DfE logo does not adequately communicate to the consumer that the 

product is a safer product. DfE has acknowledged that the DfE mission to 

promote “safer chemical based products” is not conveyed by the current logo. The 

agency received stakeholder feedback showing that the logo does not fully and 

effectively communicate DfE’s mission. Furthermore, the manufacturers’ typical 

placement of the DfE label on the back of its products inhibits the promotion of 

“safer chemical based products.” Consumers would need to pick up, turn around 

and examine a product to see the DfE labeling. 

The prominent use of “U.S. EPA” on the logo (see figure 2) may lead consumers 

to draw the interpretation that EPA endorses products that have the label. DfE 

program documents state that EPA/DfE recognition does not constitute 

endorsement of a product. According to the DfE partnership agreement, partners 

agree to include on any advertising of the DfE-qualifying products an 

endorsement disclaimer.1 The disclaimer disavows any EPA product 

endorsement. Additionally, partners are to work with the EPA to find an 

appropriate place (e.g., company website) to include the disclaimer.

According to EPA staff, because of the length of the disclaimer statement, most 

manufacturers place the disclaimer on their websites. To test this, we randomly 

sampled 30 DfE products and found this language was not included on the 

webpages for all but one of the products sampled. Therefore, there is a substantial

risk that an EPA endorsement of DfE products is implied and could be so 

perceived by consumers. The EPA may need to strengthen controls in this area or 

remove the “U.S. EPA” from the DfE logo to eliminate any perceived EPA 

endorsement.

The EPA also lacks sufficient controls over the use of its DfE logo by former DfE 

program participants. We found one instance in which the DfE logo was used on a 

website of a DfE partner that is no longer in the program. We also found a past 

program participant that acknowledges on its website that it no longer carries the 

DfE label on its products but that many of its products are still “DfE recognized.”

 

1 Required Disclaimer: EPA/DfE recognition does not constitute endorsement of this product. The Design for the 

Environment logo signifies that the formula for this product, as «Company Partner» has represented it to the EPA, 

contains ingredients with more positive health and environmental characteristics than conventional cleaners. 

EPA/DfE relies solely on «Company Partner», its integrity and good faith, for information on the composition, 

ingredients, and attributes of this product. EPA/DfE has not independently identified, i.e., via chemical analysis, the 

ingredients in the product formula, nor evaluated any of a Company’s noningredient claims. EPA/DfE provides its 

evaluation only as to the environmental and human health characteristics of the product, based on currently available 

information and scientific understanding.
14-P-0349 5

This is misleading for consumers, inconsistent with the program’s purpose of safe 

product promotion, and a violation of the DfE partnership agreement. 

We also found the logo for the Safe Detergent Stewardship Initiative has a design 

similar to the DfE program logo. Since the two programs have separate and 

distinct eligibility requirements, it is important that their logos also be distinct to 

avoid confusing or misleading consumers.

EPA’s DfE Website Has Unsupported Program Benefit Claims

The EPA’s website states that:

EPA’s Design for the Environment program helps consumers, 

businesses, and institutional buyers identify cleaning and other 

products that perform well, are cost-effective, and are safer for 

the environment.

However, the DfE program does not have controls in place to ensure one of these 

three claims—cost effectiveness. The DfE review process includes an assessment 

of each of the ingredients in a potential product to ensure that the product contains 

only those ingredients that pose the least concern among chemicals in their class.

We found that the files documenting the process for accepting partners into the 

DfE program were adequate and maintained. However the agency does not have 

evidence in its files to support that DfE products are cost effective. The current 

review process to qualify products does not include any review of cost 

effectiveness. The agency should ensure that language describing the program’s 

benefits is accurate and not misleading.

Weaknesses Exist in EPA’s Measurement of DfE Program Results

The EPA has used results from the DfE program to support two of the agency’s 

Government Performance and Results Act measures. Specifically:

 Performance Measure (PM) 264, pounds of hazardous materials reduced 

through pollution prevention.

 PM P25, percent increase in use of safer products. 

However, DfE results data are not appropriate or valid to support either measure. 

This is significant because DfE accounted for nearly half of all EPA-claimed 

hazardous material reductions (PM 264) in recent years. 

DfE’s contribution to PM 264 was calculated by multiplying the average annual 

production volume of safer products by the number of DfE labeled products at 

year end. However, the use of average production volume is inconsistent with the 

definition for PM 264. PM 264 is supposed to measure the reduction of hazardous 

materials, but the DfE metric focused on production of safer chemicals. Thus, this 
14-P-0349 6

metric did not reflect the amount of hazardous materials reduced as reported 

under PM 264. In addition, an outdated formula was used to generate the DfE 

average production volume. The formula was based on data from eight 

participating manufacturers in 2006, but as of February 2014 half of those 

manufacturers were no longer partners in the DfE program.

DfE program results data were also used to show EPA progress on the percent 

increase in the use of safer products (PM P25). However, as noted above, the DfE 

program measured the overall production of products with safer chemicals and 

not changes in the use of safer products. Therefore, using DfE program results 

data to support PM P25 was inappropriate.

During our review, the EPA modified how DfE results were reported. DfE results 

have been removed from the agency’s performance measure that reports pounds 

of hazardous materials reduced through pollution prevention. The agency will 

also no longer use calculated average production volume of safer chemicals in 

support of any measures. The agency has decided to no longer report on the 

measure of percent increase in use of safer products.

Beginning with fiscal year 2015, a new DfE program measure will be used to

track program results. This measure calculates the number of products that have 

earned the DfE label and the number of chemicals listed on the Safer Chemical 

Ingredients List. This new DfE measure provides relevant and updated 

information on outputs. However, while the new measure is important, it has key 

limitations. Counts of products that are labeled safer and chemicals on the Safer 

Chemical Ingredients List do not provide evidence that consumers are actually 

purchasing and using these products instead of other products and, thus, having 

the desired pollution prevention and risk reduction impact. Without measures that 

better capture the use or sale of DfE products, the EPA will be limited in 

accurately projecting the outcomes and impacts of this program, including its

desired impact on pollution prevention.

Conclusions

The DfE program is designed to help consumers make wise choices by identifying 

safer products. There are more than 2,500 products that carry the DfE logo, and 

the EPA has expressed interest in continuing to grow the program. The current 

DfE logo design and EPA-acknowledged low consumer recognition of the logo 

impedes the agency’s goal to promote safer chemical-based products through the 

DfE program. Further, use of the logo by those who left the program, as well as

by other EPA programs with different eligibility requirements, could negatively 

impact the overall integrity and value of the DfE logo. Improving the DfE logo 

should further the EPA’s goals, better promote safer products, and support DfE 

brand recognition among consumers. In addition, having valid measures that 

capture DfE program results will strengthen the EPA’s ability to accurately 

determine program benefits and contributions to pollution prevention. 
14-P-0349 7

Recommendations

We recommend that the Assistant Administrator for Chemical Safety and 

Pollution Prevention: 

1. Design a unique DfE logo that better conveys the program’s objective and 

eliminates any appearance of an EPA endorsement.

2. Periodically review program participants’ compliance with the DfE 

partnership agreement as it relates to appropriate use of DfE program 

language, including disclaimers and labeling requirements.

3. Develop and implement controls for accomplishing removal of the DfE 

logo from the websites of partners who leave the program. 

4. Take appropriate action to address noncompliance with DfE partnership 

agreements discovered as a result of this review.

5. Remove statements on the EPA’s website that imply or suggest that the 

EPA has determined that DfE products are a cost-effective choice, unless 

valid work to support that assessment has been completed.

6. Develop robust, transparent and adequately supported performance 

measures that capture the DfE program’s results.

Agency Comments and OIG Evaluation

The agency agreed with our findings and recommendations, and provided 

corrective actions and estimated completion dates that meet the intent of the 

recommendations. The agency has fully addressed recommendation 5 and,

therefore, it is closed. Based on the agency’s written response to the report and a 

meeting to discuss the agency’s response, we have determined that the remaining 

recommendations are resolved and open with corrective actions ongoing. No

further response to this report is required. The agency’s detailed response is in 

appendix A. The agency also provided a technical comment on the draft report, 

which we have incorporated into our report as appropriate. 
14-P-0349 8

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 7 Design a unique DfE logo that better conveys the 

program’s objective and eliminates any 

appearance of an EPA endorsement.

O Assistant Administrator for 

Chemical Safety and 

Pollution Prevention

3/31/15

2 7 Periodically review program participants’

compliance with the DfE partnership agreement as 

it relates to appropriate use of DfE program 

language, including disclaimers and labeling 

requirements.

O Assistant Administrator for 

Chemical Safety and 

Pollution Prevention

12/31/14

3 7 Develop and implement controls for accomplishing 

removal of the DfE logo from the websites of 

partners who leave the program.

O Assistant Administrator for 

Chemical Safety and 

Pollution Prevention

6/30/15

4 7 Take appropriate action to address noncompliance 

with DfE partnership agreements discovered as a 

result of this review.

O Assistant Administrator for 

Chemical Safety and 

Pollution Prevention

6/30/15

5 7 Remove statements on the EPA’s website that 

imply or suggest that the EPA has determined that 

DfE products are a cost-effective choice, unless 

valid work to support that assessment has been 

completed.

C Assistant Administrator for 

Chemical Safety and 

Pollution Prevention

8/8/14

6 7 Develop robust, transparent and adequately 

supported performance measures that capture the 

DfE program’s results.

O Assistant Administrator for 

Chemical Safety and 

Pollution Prevention

9/30/15

1 O = Recommendation is open with agreed-to corrective actions pending.

C = Recommendation is closed with all agreed-to actions completed.

U = Recommendation is unresolved with resolution efforts in progress.
14-P-0349 9

Appendix A

Agency Response to Draft Report

August 8, 2014

MEMORANDUM

SUBJECT: Response to Office of Inspector General Draft Report No. OPE-FY14-0008

“EPA Can Help Consumers Identify Safer Chemical Products by Strengthening

Its “Design for the Environment” Program,” dated July 9, 2014

FROM: James J. Jones

Assistant Administrator for Chemical Safety and Pollution Prevention

TO: Arthur A. Elkins, Jr.

Inspector General

Thank you for the opportunity to respond to the issues and recommendations in the subject report. 

This memorandum provides the Agency’s response to OIG’s recommendations, and identifies 

corrective actions the Agency will be taking in response. 

One item in the draft OIG report, which we did not comment on in our response to the 

discussion draft, pertains to the use of the DfE logo by another EPA pollution prevention 

initiative. The example cited in page 5 of the draft report is the DfE Safer Detergents 

Stewardship Initiative (SDSI). We propose a technical correction to the OIG report to replace 

the subject paragraph to more completely reflect how DfE has managed use of the DfE Safer 

Product Labeling Program logo (Attachment A). 

The report contains a total of six recommendations. Below we list each recommendation and 

the OCSPP response, including timeframes for implementation.

Recommendation 1. Design a unique DfE logo that better conveys the program’s objective and 

fully eliminates any appearance of an EPA endorsement. 

OCSPP agrees. We are in the process of redesigning the DfE logo to enhance its ability 

to communicate with consumers, attract the interest of product and chemical 

manufacturers, and increase the frequency of the logo’s use on products to meet the 

human and environmental health protection goals of the program. We have worked with 

the Agency’s Office of General Counsel to ensure that the redesigned logo complies with 

ethics considerations on use of the EPA name and potential endorsements.

Timeline. We will be gathering stakeholder and public comment on our logo designs this 

summer and fall. We plan to have a new, more effective logo for use on DfE-labeled 

products early in 2015. Completion date: Q2/FY15. 
14-P-0349 10

Recommendation 2. Periodically review program participants’ compliance with the DfE 

partnership agreement as it relates to appropriate use of DfE program language, including 

disclaimers and labeling requirements. 

With respect to DfE partner posting of endorsement disclaimers, the DfE program will 

enhance its regular auditing procedures to ensure that auditors look for the disclaimer 

language and note its absence in audit reports.

Timeline. We have instructed the third party auditors to include inspection for 

endorsement disclaimers in their audits and reports. The revised auditing process has 

been initiated (DfE email correspondence dated August 4, 2014); all desk audits 

beginning October 1, 2014 will include this component. Completion date: Q1/FY15 and 

ongoing.

Recommendation 3. Develop and implement controls for accomplishing removal of the DfE 

logo from the websites of partners who leave the program. 

The DfE program will increase efforts to ensure that former partners do not use the logo.

When a new program management system comes online, DfE will be able to better 

monitor and enforce appropriate use of the logo by current and former partners, as well as 

partner posting of the endorsement disclaimer.

Timeline. The new program management system is expected online this spring as a 

program monitoring tool, including to help ensure appropriate logo and endorsement 

disclaimer use. Completion date: Q3/FY15 and ongoing.

Recommendation 4. Take appropriate action to address noncompliance with DfE partnership 

agreements discovered as a result of this review. 

As stated in our response to recommendations 2 and 3, the DfE program will increase its 

follow-up activities to address and remedy partner noncompliance, and we expect our 

new program management system to help considerably in this regard. 

Timeline: As indicated in our response to recommendation 3, the new program 

management system is expected online this spring. Completion date: Q3/FY15 and 

ongoing

Recommendation 5. Remove statements on the EPA’s website that imply or suggest that the 

EPA has determined that DfE products are a cost-effective choice, unless valid work to support 

that assessment has been completed. 

OCSPP will remove this claim from the DfE web site and outreach materials. DfE 

historical documents may also contain reference to cost-effectiveness. DfE will 

implement this change in technical documents as they are updated.

Timeline. DfE has removed this claim from its web site and outreach materials. 

Completed: Q4/FY14
14-P-0349 11

Recommendation 6. Develop robust, transparent and adequately supported performance 

measures that capture the DfE program’s results. 

OCSPP agrees that DfE performance measures capturing outcomes need to be developed.

The new program management system referenced above will help capture relevant data 

such as production volumes and sales information on DfE-labeled products.

Timeline. DfE continues to work on new outcome-oriented performance measures and 

hopes to have them in place this fall. The new program management system should 

begin capturing these measures by the summer of 2015. Completion date: Q4/FY15.

If you have any questions or need further information about this response, please contact 

Deborah Hartman, OCSPP’s Audit Liaison at (202) 564-1488.
14-P-0349 12

Appendix B

Distribution

Office of the Administrator

Assistant Administrator for Chemical Safety and Pollution Prevention

Agency Follow-Up Official (the CFO)

Agency Follow-Up Coordinator

General Counsel

Associate Administrator for Congressional and Intergovernmental Relations

Associate Administrator for External Affairs and Environmental Education

Deputy Assistant Administrator for Chemical Safety and Pollution Prevention

Audit Follow-Up Coordinator, Office of Chemical Safety and Pollution Prevention