Apri13, 2014 

Document Control Office (7407M) 

Office of Pollution Prevention and Toxics (OPPT) 

Environmental Protection Agency 

1200 Pennsylvania Ave. N.W. 

Washington, D.C. 20460 

\..01\.. \..UIIliUI I'IIUIIIU~I 

359499 rn•r ,.. __ ... __ , 1\lo .-.... --

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 

Thank you forthe opportunity to provide these comments regarding the EPA Draft Guidelines for product Environmental Performance Standards and 

Ecolabels for Voluntary Use in Federal Procurement. As an organization dedicated to the advancement of environmental innovation in the building envelope, 

W(). appreCiate and support the overall approach to environmental performance standards grounded in the key principles of modem consensus processes. By 

including the principles of open and balanced participation, consideration of all 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 of concern 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 of overall risk assessment as the best approach to identifying potential and actual environmental 

or human health danger of a product. Stated simply, many materials may be considered potentially hazardous, but a useful understanding of the actual hazard 

requires an assessment of the risks involved. Key elements of risk assessment currently lacking in hazard-based approaches include the establishment of 

scientific threshold levels of exposure that may produce adverse health effects as well as validated exposure paths by which any particular hazardous 

ingredient may directly affect building occupants. As a result, hazard-based protocols provide little or no information to that may help a building owner or 

designer make decisions based on the actual risk posed by a building product. 

In order to provide a more balanced approach to the concepts of hazard and risk, we recommend that Section II, #13 be revised as follows: 

"Product environmental criteria focus on the assessed risks of chemicals, and require safer substitutes to the extent possible, considering existing 

data and availability of functional alternatives. 9

" 

In addition, we recommend that Footnote 9 also be revised to support risk assessment in addition to hazard identification: 

"A risk-based approach, grounded in Green Chemistry principles, can reduce the use of hazardous substances, and lower overall risk to people 

and the environment. Key to this focus is an understanding of the actual risks of chemicals in terms of effect levels and exposure pathways, as 

well as the availability of safer alternatives." 

We thank you for the opportunity to provide these comments, anq we look forward to the formal release of the guidelines." 

Sincerely, 

Lori Jones 

d~r 

Product Stewardship Manager 

Firestone Building Products, LLC 

NOBODY COVERS YOU BETTERTM 

http://www. firestonebpco.com