Apri13, 2014 Document Control Office (7407M) Office ofPollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Ave. N.W. Washington, D.C. 20460 \..01\.. \..UIIliUI**I'IIUIIIU~I** 

# 359499

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Re: Comments regarding the EPA Draft Guidelines for product Environmental Performance Standards and Ecolabels Docket ID number EPA-HQ-OPPT-2013-0579 .To whom it may concern, 

# Ttrestone BUILDING PRODUCTS Firestone Building Products Company, LLC 250 West 96th 

### Street Indianapolis, IN 46260 Phone: 317-575-7000 Fax: 317-575-7100

Thankyou forthe opportunity to provide these comments regarding the EPA Draft Guidelines for productEnvironmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement. As an organization dedicated to the advancement ofenvironmental innovation in the building envelope, W().appreCiate and supportthe overall approach to environmental performance standards grounded in the key principles ofmodem consensus processes. By including the principles ofopen and balanced participation, consideration ofall viewpoints, efforts to resolve objections, the opportunity for appeal, and overall timeliness and transparency in the development and communication process, the Draft Guidelines provide a solid foundation for effective performance standards and labeling. Without a doubt, these principles need to be emphasized in green standards development, where true consensus processes have too often been ignored or compromised. The only area ofconcern we wish to comment on involves the concept of"intrinsic hazard" as described in the Section II, # 13, and Footnote 9. Specifically, we are concerned that this guideline neglects the importance ofoverall risk assessment as the best approach to identifying potential and actual environmental orhuman health danger ofa product. Stated simply, many materials may be considered potentially hazardous, but a useful understanding ofthe actual hazard requires an assessment ofthe risks involved. Key elements ofrisk assessment currently lacking in hazard-based approaches include the establishment of scientific threshold levels ofexposure that may produce adverse health effects as well as validated exposure paths by which any particularhazardous ingredientmay directly affect building occupants. As aresult, hazard-based protocols provide little or no information to that may help abuilding owner or designer make decisions based on the actual risk posed by abuilding product. In order to provide a more balanced approach to the concepts ofhazard and risk, we recommend that Section II, #13 be revised as follows: "Product environmental criteriafocus on the 

### assessedrisks ofchemicals, and require safer substitutes to the extent possible, considering existing data andavailability offunctional alternatives.9" In addition, we recommend that Footnote 9 also be revised to support risk assessment in addition to hazard identification: "A

### risk-basedapproach, grounded in Green Chemistry principles, can reduce the use ofhazardous substances, and lower overall risk to people and the environment. Key to this focus is an understanding ofthe 

### actual risks of chemicals in terms of effectlevels andexposurepathways, as wellas the availability ofsafer alternatives." We thank you for the opportunity to provide these comments, anq we look forward to the formal release ofthe guidelines." Sincerely, Lori Jones

# d~r Product Stewardship Manager Firestone Building Products, LLC



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