May 15, 2012 Green Seal is in the process of developing a Standard for Laundry Care Products, GS-48. Comments from the public were solicited on a Proposed Standard from March 16, 2012 until May 4, 2012. Below are the comments received on the Proposed Standard for Laundry Care Products, GS-48. The comments have been sorted according to the topics and criteria in the Proposed Standard. Remarks not on the Proposed Revised Standard and any identifying remarks or reference to the commenter have been removed. By participating in Green Seal’s standard setting process, the following organizations that provided comments played an important role in Green Seal’s effort to encourage the design, manufacture and end use of environmentally superior products. Their assistance and involvement is greatly appreciated. Participating Organizations: American Association of Textile Chemists and Colorists American Cleaning Institute California Department of Public Health Diversey, Inc. Ecolab Inc. Massachusetts Department of Public Health Milliken & Company

1.0 SCOPE This standard establishes environmental, health, and social requirements for products that are used to clean, remove stains, and/or otherwise treat the softness, static or wrinkle characteristics of laundry. This standard incudes products designed for household or institutional use, including, but not limited to, laundry detergent products, fine washable laundry detergent products (for delicates), stain and spot removing products (pre-treatment and stand alone), laundry additives (bleaching, softening, sour, antichlor, and alkali booster products), fabric softener (liquids and sheets), anti-static products (liquid and sheets), fabric refresher products, anti-wrinkle products, laundry prewash products, laundry starch/sizing/fabric finish products, soap nuts/biobased detergents, and combination products that may serve several of these functions. This standard includes the above laundry care products used in institutional use facilities such as dry cleaning or commercial laundries, but it does not address the process, solvent use (or pure solvents), ozone generation and use, or facility itself. This standard includes products used in health care and food settings, which may include antimicrobial pesticide products (e.g., products covered by the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)). This standard includes fabric protectant products but does not address impregnating products with flame retardant or waterproofing properties. This standard does not address carpet or upholstery cleaning and maintenance products or footwear or leather care products. See Appendix A for an example list of products included in this standard. Due to the large number of possible cleaning products, processes, soil types, and cleaning requirements, the compatibility of the products with materials is not specifically addressed in this standard. Product users should follow the manufacturer’s instructions on compatibility. Where there is more than one criterion that applies, the more stringent criterion applies. This standard neither modifies nor supersedes laws and regulations. Compliance is required for all applicable laws and regulations for the manufacturing and marketing of products. Generally, the requirements included in this standard cover aspects above and beyond compliance issues. Words and phrases described in the standard that appear in italics have corresponding definitions located in the definitions section of the standard, Annex A. Criteria that include an asterisk (*) in the title are considered foundational criteria . Comment: The current scope of products represent a very broad spectrum of functions (cleaning, static control, fabric softening, fabric protection, fabric freshening). We believe the focus of the current standard should be narrowed to avoid confusion. We recommend that the standard separate household and institutional products. The use patterns in these two settings are vastly different, as are the products themselves. Performance

requirements, testing criteria, etc. are also extremely different and should be treated separately. We recommend that antimicrobial pesticide products (e.g., those covered by FIFRA) be removed from the standard’s scope. FIFRA-registered products are prohibited from carrying any ‘green’ logos/claims. In addition, the standard for cleaning fabrics in settings where antimicrobial products are required by law may be much more stringent than those mentioned within the Green Seal standard rendering use of the standard potentially harmful in those settings. Appendix 1 gives an example list of products included in the standard, not Appendix A. Comment: The scope of this standard is too broad. It covers a wide range of functions (soil removal to fabric production), as well as broad markets with different customer drivers ranging from household to commercial laundry markets. The statement from the standard quoted below is confusing: “This standard includes the above laundry care products used in institutional use facilities such as dry cleaning or commercial laundries, but it does not address the process, solvent use (or pure solvents), ozone generation and use, or facility itself.” It is not clear if the standard is specific to the wet cleaning side of a dry cleaning facility, or if the surfactant based detergent product additives for dry cleaning are within scope. Conversely, are solvent based products for commercial laundries excluded? The standard attempts to combine household, institutional and commercial laundry standards, yet separate attributes such as use concentrations, packaging ratios and endpoints which makes the standard unnecessarily complicated and confusing. These markets are served by products with different characteristics based on the fact that household users generally have the luxury of time whereas I&I users are constrained by time. To consider these products to serve the same purpose because their chemistries, is an oversight of the proposed standard. The I&I applications described vary significantly from their household counterparts. Institutional and commercial environments have a responsibility to protect public health through there cleaning activities whether in laundering linens for a hotel or healthcare environment. Green Seal should reflect the significant differences in market conditions between household and institutional and commercial applications. The standard, as proposed, does a poor job of distinguishing between these laundry applications. The standard specifically calls out “soap nuts” in the context of biobased detergents. It is not relevant to call out one specific source for a biobased detergent compound in this standard. The standard should describe biobased or renewable surfactants/detergent. If the definition of biobased is met, description of the source is unnecessary. If the standard is trying to ensure that biobased composition are not drawing from food sources, then that boarder objective should be called out specifically in the standard.

2.1.1 Laundry Detergent Performance Laundry detergent products shall demonstrate performance equivalent to or better than a comparative benchmark product. The benchmark product for household use products shall be the appropriate American Association of Textile Chemists and Colorists (AATCC) standard reference laundry detergent (powder at 66 g/test or liquid 100 g/test, without

optical brighteners) or a national market leading product in its category. The benchmark product for institutional use products shall be a national market-leading product in its category. Comment: I suggest to avoid any confusion for the AATCC standard reference detergents, please list the full names of the powder and liquid varieties as such: Powder - 1993 AATCC Standard Reference Detergent WOB Liquid - 2003 AATCC Standard Reference Liquid Detergent WOB Comment: 2.1.1 Laundry Detergent Performance – performance testing should be conducted at the temperatures as designed by ASTM D4265, not as described in 2.1 (Product Performance). Comment: Product performance is to be compared to an applicable benchmark. This benchmark is defined for household detergents, but there is no such specification for other products within the scope of this standard (i.e. prewash products, boosters, softeners and bleaches). Additionally, an applicable benchmark in the institutional, industrial, and commercial laundry markets is not one product, but rather a combination of products that can include a detergent, water conditioner (builder), booster, and bleaching agent. The ratio of these components (product combination) is varied via automatic dispensing delivery systems to provide the correct formulation based on soil load, fabric type, water and temperature conditions. The standard goes on to describe the benchmark for institutional products “shall be a national market-leading product in its category”. There is no clear definition or data source for definitions of market-leading product within a category, leaving it wide open broad and potentially inconsistent interpretation. The product performance test methods are defined for home style washers and dryers. The boundaries for “appropriate modifications” to these consumer market driven test methods have not been specified. Soil redeposition needs to be defined and/or a method needs to be included in the standard. In general soil redeposition is measured over the course of multiple wash cycles under controlled wash conditions, and this should be specified.

2.1.1.2 Color Care Laundry detergent products shall demonstrate that they maintain color fastness of cotton laundry using the procedure in ASTM D4265 or AATCC 124 (using machine washing) by assessing color change after 30 wash cycles with appropriate instrumental (e.g., ?E in accordance with International Organization for Standardization (ISO) J01 and J03 using a spectrophotometer) and visual analysis (e.g., AATCC gray scale evaluation) for determination.

Comment: In AATCC 124 there are two load sizes now. You may want to specify a 4 Lb load size, since this corresponds to the detergent amounts in the previous section. I suggest to list AATCC Evaluation Procedure 6 as a replacement for ISO J01, it is technically equivalent. Also, please consider adding AATCC Test Method 173 with ISO J03, as it is partially equivalent to that standard. Since this Standard references several AATCC and ASTM standards, it would be more appropriate.

2.1.1.3 Fabric Appearance Laundry detergent products shall demonstrate that they maintain the integrity of a mixture of cotton, synthetic, and blended textiles after treatment using the procedure in ASTM D4265 or AATCC 124 (using machine washing) by assessing textile color and surface (for pilling/abrasion) after 30 wash cycles with appropriate instrumental and visual analysis for determination Comment: ASTM 4265 and AATCC 124 do not evaluate pilling or abrasion appearance after laundering. I would suggest different wording in the parenthesis, maybe "for overall appearance". Comment: This specification does not define the threshold for colorfastness. For example a ?E of <5 is acceptable, or ?E <10 or from the benchmark passes for example. Furthermore, the specification assumes similar performance for all dye classifications, fabric types, and fabric constructions. Green Seal should consider performance compared to a benchmark with along with appropriate statistically designed testing and evaluation.

2.1.2 Stain Removing and Bleaching Performance Stain removing products and bleaching products shall demonstrate that they clean, avoid soil re-deposition, and remove stains on cotton laundry using ASTM D4265 with instrumental and visual analysis for determination and with performance as good as or better than an appropriate reference product or a national market leading product in its category for at least seven of the following stains, without failing in any stain: ballpoint pen ink, blood, blueberry, grass, makeup, mustard, spaghetti sauce, tea, and used motor oil (with appropriate controls for the comparison). Comment: I understand that the stain removal is compared against an appropriate reference product, but if that product does not remove all of the stains well, what constitutes passing? It seems if a reference product only rated a 2 on the stain scale, then all a comparative product would need to rate is 3, which i still noticeable. I am not sure if you want to list a requirement here, but alternate language may be needed to avoid confusion.

Comment: This section is specific to stain and spot removing products. This should be reflected in the heading. Suggested heading: “Stain and Spot Removal Performance”. This section specifies only testing on cotton “laundry” using ASTM D4265. Specification of only cotton substrates is restrictive when the ASTM itself suggests testing multiple fabric types. See the following quote (section 6.1): “The relative effectiveness of various laundry products or procedures for removing different types of stains will be influenced by the nature of the fabric substrate. Testing should encompass more than one type of fabric, with results tabulated separately for each fabric group. The fabric types most common in US laundry are polyester/cotton blends with permanent press finish, all cotton, all polyester and nylon”. We suggest addition of both poly/cotton and polyester fabric types to the specification. Soil re-deposition is a performance attribute required for laundry detergents, not for stain and spot removal products, therefore this performance requirement is miss-placed in this performance section. The standard requires that the performance must be as good as or better than the comparative benchmark product for 7 of the 9 listed stains. However, there is no discussion of a range or other statistical parameters. We suggest that a broader range of test stains be considered including: Mineral Oil Dust/Sebum Olive Oil Wine Lipstick Cocoa Coffee Carbon Black or Soot Redeposition (white cotton &white blend)

2.1.3 Softening Performance Softening products shall demonstrate that they perform equivalent to or better than an appropriate reference product or a national market leading product in its category using the Consumer Specialty Products Association (CSPA) DCC-13 series evaluating softness (13B), water absorbency (13D), and static control using one of described evaluation methods (13F). Comment: Washing and drying in a home type machine is very different than washing and drying in commercial type machines. Key differences include fabric to water ratio; mechanical action, loading levels, extraction speeds, and drying temperatures. All these differences substantially affect fabric softness, water absorbency, static control, smoothness and hand (feel) of fabrics. A commercial type washing procedure needs to be specified in order to be applicable to the

industrial/OPL market. The number of wash cycles needs to be defined. We recommend at least 5 cycles, and a statically designed test protocol.

3.0 PRODUCT-SPECIFIC SUSTAINABILITY REQUIREMENTS General comments regarding product-specific requirements shall be made here. Comment: Section 3.0 (Product Specific Sustainability Requirements) – This section is specific to environmental and human health requirements, and does not include all elements of sustainability. The principles of sustainability are environmental, social, and economic. It is inappropriate to use this term in this section: it should be removed.

3.1 *Formula Disclosure for Certification For certification to this standard, all of the formula components shall be disclosed to the certification program, including the chemical name, the Chemical Abstracts Service (CAS) registry number, and the levels (% by weight) of each component in the formula. Comment: Formulators may not know the fragrance component in their products because of CBI restrictions.

3.2 *Animal Testing To avoid new animal testing, previous test results will be accepted as evidence of meeting a criterion. When existing data is not available, the preferred methods for new testing include methods that replace, reduce, or refine animal use, particularly those recommended by the Interagency Coordinating Committee on the Validation of Alternative Methods or the European Centre for the Validation of Alternative Methods, unless indicated otherwise. In addition, other non-animal (in-vitro) test results, modeling data, data from structural analogs, and other lines of evidence may be accepted, provided that the methods are peer-reviewed and applicable. Specific in vitro or modeling methods may be noted in the standard, but additional options may be accepted by the certification program. Further, a mixture need not be tested if existing information demonstrates that each of the applicable components complies with the criterion. Comment: The second line should read, “When existing data are…”.

3.5 *Carcinogens and Reproductive Toxins The undiluted product shall not contain any components that are carcinogens or

reproductive toxins. The product shall not contain any components known to produce or release carcinogens. Comment: The requirement that the product not contain any ingredients that are known to cause these toxicities without consideration of the risk posed by those ingredients is inappropriate.

3.7 *Endocrine Disruptors The undiluted product shall not contain any components that are on the U.S. Environmental Protection Agency (EPA) List of Chemicals for Tier 1 Screening that have been shown to disrupt hormones (e.g., have estrogen- or androgen-mediated effects), tested according to the EPA Series 890 - Endocrine Disruptor Screening Program Test Guidelines. Comment: It is inappropriate to solely use the results from the Tier 1 screening to determine endocrine disruption. According to US EPA, the results of the Tier 1 screening assays are to be considered along with other scientifically relevant information on the chemical in a weight of evidence (WoE) approach. Where there are uncertainties, perhaps due to a false positive result during screening, EPA may repeat Tier 1 studies or endpoints, conduct some modification of a Tier 1 assay, or may move to Tier 2 testing. Therefore, basing disruption on Tier 1 results is premature. We recommend Green Seal amend this criterion to include US EPA’s further review of chemicals.

3.8 *Asthmagens The undiluted product shall not contain any components that have been identified as asthmagens. Refer to Annex D, Requirement D for potential exemptions for enzymes. Comment: We support the prohibition of asthmagens. We do not, however, support the exemption of enzymes from this criteria. To clear up a common misconception, the AOEC asthmagen criteria "Criteria for Designating Substances as Occupational Asthmagens on the AOEC List of Exposure Codes." was, indeed, developed to identify known asthmagens. The Introduction to this document clearly states that the purpose is to “develop a list of substances known to cause asthma de novo.” This list does not include substances or conditions that only aggravate existing asthma, which are called "triggers." The AOEC asthmagen criteria for designating asthmagens due to sensitization have been in place without change since at least 2002, so it is inaccurate to suggest that they are a moving target. The list of asthmagens developed based on these criteria reflects current scientific knowledge which does change with newly published data. This is and should be a desired outcome in order to be as protective as possible of workers and other vulnerable populations.

Also, the list is meant for use in all settings and nowhere is there any indication that it applies only to the manufacturing environment. Comment: We recommend this criterion be deleted. This term is not standardized. The designation of substances as “asthmagens” is under constant review by the Association of Occupational and Environmental Clinics (AOEC) as stated on their website. Therefore, this criterion is a moving target with ingredients being added and deleted from AOEC’s list and should not be included in the standard. ACI maintains that the term asthmagen, which is included in the asthma definition, should be deleted as it is not a standardized term. Further, as stated by AOEC itself, “…it is not desirable to use AOEC list as a basis for banning substances. As (explained) a number of times, the AOEC’s list was designed to be used after the diagnosis of asthma was made or strongly suspected to help clinicians identify potential triggers for asthma. It was not designed to point to substances and say substance X causes asthma, since people then have a natural tendency to take that to mean that in all cases, substance X causes asthma. (Our) list doesn’t include any PEL or TLV information or any other detail that would be needed to ban or even seriously limit use of a substance.” Further, AOEC’s list of asthmagens was misapplied since the list is intended for the neat materials in a production environment, not aqueous mixtures in an institutional environment. Therefore, the use of this list and its criteria are inappropriate for the standard. We again recommend that Green Seal should recognize and adopt the criteria for the classification and labeling of respiratory sensitizers under the Global Harmonized System of Classification and Labeling of Chemicals (GHS, specifically Chapter 3.4.3). The criteria for classification of respiratory sensitizers have been adopted by the United Nations. These classification criteria can be included by reference into GS-52, which would allow GS-37 to remain an evergreen document. The inclusion of this criterion would prohibit ingredients such as monoethanolamine and triethanolamine. Instead direction for safe use should be provided such as, “All nitrogen containing compounds should be formulated so that nitrosamines will not occur”. It is common formulator knowledge that when monoethanolamine and triethanolamine are formulated properly they will not cause nitrosamines. monoethanolamine and triethanolamine offer a unique functionality offering mild and effective skin care products. Please see the Journal of the American College of Toxicology report “Final Report on the Safety Assessment of triethanolamine, diethanolamine, and monoethanolamine” Volume 2, Number 7, 1983 for further details. Comment: I share the concern regarding the capacity of enzymes to cause asthma, as has been documented previously, and more recently in the article, “Occupational asthma and rhinitis due to detergent enzymes in healthcare,” by Adisesh et al Occupational medicine 2011;61:364-9. Green Seal has relied on AOEC asthmagen designation because of the strict criteria regarding evidence of asthmagenicity. The requirement for peer-reviewed literature documenting the capacity of a

chemical to cause asthma delays the identification of hazardous materials. Adisesh et al wrote that suppliers of formulated enzyme products were unable to identify the type of bacterial or fungal enzyme and IgE tests had low sensitivity. Many factors prevent gathering the evidence of harm. Knowing that enzymes can cause asthma should exclude them from GS-48 approval, or, in the alternative, adopt Dr. Ken Rosenman’s suggestion that the GS labels include a warning that the ingredients may cause and/or exacerbate asthma.

3.9 *Respiratory Sensitization The undiluted product shall not contain any components that have been identified as respiratory sensitizers. Refer to Annex D, Requirement D for potential exemptions for enzymes. Comment: We support the use of this criterion in addition to the use of the AOEC Asthmagen list. However, we do not support the exemption of enzymes from this criterion. Comment: We recommend that this section be amend to include exposure and risk assessments. The criteria does not take into account steps industry has taken to mitigate exposures to respiratory sensitizers such as improving delivery systems and forms of ingredients with sensitizing properties.

3.12 Volatile Organic Compound (VOC) Content The undiluted product, or concentrates diluted for use, shall contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. For product categories not regulated by CARB, the following limitations on VOC level (by weight) shall not be exceeded: • Laundry detergent products: 4% • Bleaching products, not sold as laundry detergent products: 8% • Softening products: 4% • Sour products: 4% • Other products: 1% The VOC content shall be determined either by summing the percent by weight contribution from all components of the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C or by the CARB Method 310, modified to not allow the exemption for fragrances specified under Method 310. Comment: Concerns exist with the proposed VOC limits for products. Currently, there is no regulatory VOC limit on laundry detergent. This is in large part due to the scientific rigor applied to assessing the VOC emissions from liquid laundry detergents (Wooley, Nazaroff and Hodgson, 1990). Where regulatory limits exist, Green Seal should consult the rules as applied by CARB,

EPA and other regulatory bodies in determining VOC levels and align the proposed standard with those rules specific to each product category within the scope of this standard. The CARB exemption for fragrances, for example, should be retained in this standard. Consumers who perceive a lower fragrance level in their laundry detergent or fabric softener may be inclined to use more to reach that level of fragrance performance they want.

3.13 *Toxicity to Aquatic Life The product as used shall not be toxic to aquatic life. A product is considered not toxic to aquatic life if the lowest available and most representative acute LC50 data for fish, daphnia, or algae is greater than or equal to 100 mg/L. For purposes of demonstrating compliance with this requirement, data for each of the product’s components at 0.01% or more in the product as used may be used to calculate a weighted average (as in section 3.3). The preferred sources of data come from the following appropriate protocols: ISO 7346-2 for fish, Organisation for Economic Co-operation and Development (OEDC) Test Guidance (TG) 203 for fish, OECD TG 202 for daphnia, and OECD TG 201 for algae. Comment: Consideration of aquatic toxicity should only be done in the context of environmental risk assessment. Directly applying these criteria for aquatic toxicity to products fails to consider the environmental fate of aqueous cleaning products which are typically disposed into wastewater treatment systems and, thus, do not directly enter the environment. The ability of a product to exert aquatic toxicity in the environment is a function of many factors beyond just its toxicity, including the mitigation due to fate mechanisms and dilution levels upon discharge into the environment.

3.14 *Aquatic Biodegradability Each of the individual organic compounds at 0.01% or more in the product as used shall exhibit ready biodegradability in accordance with the OECD definition, except for polymers. Biodegradability shall be measured according to any of the following methods: ISO 7827, 9439, 10707, 10708, 9408, 14593; OECD Methods 301A – F; or OECD 310. Specifically, within a 28-day test, the organic compound shall meet one of the following criteria within 10 days of the time when biodegradation first reaches 10%: • Removal of Dissolved Organic Carbon (DOC) > 70% • Biochemical Oxygen Demand (BOD) > 60% • % of BOD of Theoretical Oxygen Demand (ThOD) > 60% • % CO2 evolution of theoretical > 60% Per OECD guidance the 10-day window requirement does not apply to structurally-related surfactant homologues. For organic compounds at 0.01% or more in the product as used that do not exhibit ready biodegradability in these tests the manufacturer may demonstrate biodegradability in sewage treatment plants using the Coupled Units Test found in OECD

303A by demonstrating DOC removal > 90%. An exception shall be made for organic compounds that do not exhibit ready biodegradability, if the compound has low aquatic toxicity (acute LC50 ? 100 mg/L for algae, daphnia, or fish) and exhibits inherent ultimate biodegradability with biodegradation rates above 70% (measured as BOC, DOC, or COD), per ISO test methods 9887 or 9888 or OECD 302A-C Comment: The proposed revision to the standard requires that all organic ingredients are readily biodegradable, effectively excluding the use of certain performance chemicals such as polymers and chelants that are safe at the low levels that they are used but provide significant performance improvements allowing the use of less product for the same standard cleaning job. From a holistic Life Cycle Analysis (LCA) viewpoint, products without these performance chemicals may not have a superior environmental profile than products containing them.

3.16 *Chronic Aquatic Toxicity The product as used shall not contain any components at 0.01% or more that have chronic aquatic toxicity. Comment: The level stated here may be unnecessarily restrictive. Many ingredients need to be present in cleaning products at a higher level than 0.01% in order to be effective in use, and as a matter of standard use they will likely be diluted to well under 0.01% before entering aquatic systems. As such, this level might better be applied only to direct-release products. We would like to better understand how Green Seal arrived at this level determination, and we would need to further study its implications for certain ingredients in laundry products.

3.17 *Eutrophication • The household use undiluted product shall not contain phosphorus at more than 0.5% by weight. • The institutional use product as used shall not contain phosphorus at more than 0.5% by weight. Comment: It is well known that phosphorus can contribute to nutrient-loading in water bodies, leading to adverse effects on water quality. The relative loadings of phosphorus to surface waters from detergents should be put into context. The relative phosphorus contribution from cleaning products, particularly household cleaners, has been demonstrated to be negligible or non-existent (Legislative Report: Detailed Assessment of Phosphorus Sources to Minnesota Watersheds, Minnesota Pollution Control Agency, 2004; http://www.pca.state.mn.us/hot/legislature/reports/phosphorus-report.html).

3.18 Prohibited Components The undiluted product shall not contain the following components: • 2-butoxyethanol • Alkylphenol ethoxylates • Halogenated organic solvents • Heavy metals, including: lead, hexavalent chromium, or selenium; either in the elemental form or compounds • Nitro-musks • o-Phenylphenol • Ozone-depleting compounds • Phthalates • Polycyclic musks • Toxic Release Inventory Persistent, Bioaccumulative, and Toxic Chemicals • Triclosan Comment: All product ingredients should be assessed against the same criteria. Also, prohibiting all members of a class of ingredients (e.g., optical brighteners and phthalates) without regard to differences within the class inappropriately captures chemicals of varied impacts and creates disincentives to innovation within the class. For phthalates, there is little or no evidence that these have epidemiologic/human evidence of adverse effects (see Swan et al. 2005; Main et al. 2006; Duty et al. 2003, 2005; Juanjua et al. 2007). Finally, this criterion inappropriately focuses on the hazard potential of ingredients and not the risk they pose as a result of use in personal care products. Data show that APEs biodegrade under anaerobic conditions and that removal is greater than 99% in sewage treatment plants (Nimrod and Benson 1996; Keith 1997). Therefore, APEs are in the environment at concentrations well below effects concentrations. Because there is low likelihood of injury to the environment, this ingredient should be deleted from the criterion. We recommend that “Heavy metals…” should be changed to “Toxic Metals”; those metals should be listed. We recommend that Triclosan be deleted from the list of prohibited components. Triclosan is a substance that has been approved for uses by both US EPA and US FDA. Triclosan is a preservative in many cleaning products. Laundry products cannot maintain shelf life without the use of antimicrobials whose efficacy against bacteria and/or fungal growth is well documented.

3.20 Color Components Color components are prohibited. Comment: The proposed language for this section is as follows: 3.20 Color Components. Color components are prohibited.

I respectively ask Greenseal and its GS-37 standard committee to consider the following issues and modify the language. Regarding green standards, we are a strong supporter both by ensuring our products have a positive environmental profile to ensuring our processes are environmentally friendly. Our company is a leader in the area of sustainability and has been recognized in the industry for these efforts. We are also one of the few companies that is carbon negative. We also share in the goal of unifying standards across NGO's where possible as our mutual customers want to develop formulations that have universal acceptance. Please also note that our company has been instrumental in working with NGO's to understand the use of color in cleaning products, differences in colorant technologies with respect to environmental footprint, and proposing language for a responsible standard. Color is used in the household and I&I cleaning products for several reasons. There are two that are most consistent with Green Seal's basic philosophies: 1) Safety: On the I&I side, institutions, schools, gov't building, large office complexes, etc are routinely cleaned and serviced by outside companies using contract labor. In most cases, this is unskilled labor that may not be able read or speak English. The responsible use of color allows for companies to color code products to ensure that they are used for their intended purpose. Cleaning products are often transferred from the original package to secondary packaging by cleaning companies that sometimes have little to no labeling or safety information present. The use of color is a deterrent that prevents someone from accidentally mistaking the material as safe. 2) Perception of Quality: Detergents manufactures often have little control over the inherent base color of the detergent that is naturally somewhat yellow. This is caused by variation in surfactant color, impact of color imparted by fragrances, or yellowing of the base upon aging. Manufacturers used color to mask the base variation so that there is no confusion at the user level as to the quality of the product. In addition to these issues, GreenSeal's mission is to promote the use of green cleaning which is enabled when there is active participation by the mfgs. Many large multinationals have predominantly consumer businesses, but also manage smaller I&I lines that are based on the same manufacturing assets. Over 90% of the volume produced by these companies is colored today. To segregate uncolored product would add complexity that could discourage companies from seeking approval. Finally, there have been many discussions about developing consistent language among DfE, GreenSeal, and Ecologo, where appropriate to allow for companies to have the ability to make formulations decisions that allows for broad approval. At a minimum, I feel that GS-48 should contain the GS-37 language on the use of color. Currently, our company’s colorants fit the criteria that GS-37, EPA's DfE, and Ecologo have established. We also strongly believe that the use of our colorants is consistent with Green Seal's core philosophies around encouraging and promoting green chemistry.

I appreciate your consideration in revising Section 3.20 and will be available to work with your committee to address any further concerns or work with them to determine the appropriate revision if needed. Comment: Colorants in laundry products serve functional purposes. For liquids, a colored product is more easily detected for dosing purposes. Colored products are also easier to spot in cases of spillage. We recommend this criterion be deleted from the standard.

3.21 Optical Brighteners • The household use undiluted product shall not contain any components at 0.01% or more that are optical brighteners. • The institutional use as used product shall not contain any components at 0.01% or more that are optical brighteners. Comment: Prohibiting all members of a class of ingredients (e.g., optical brightener) without regard to differences within the class inappropriately captures chemicals of varied environmental impacts and creates disincentives to innovation within the class. For example, optical brighteners should be removed from the list of prohibited ingredients. Innovation may in the future offer a fully biodegradable and non-toxic brightener, which under this standard would be banned. Comment: The use of bluing agents should be considered as an option for reducing the use of optical brighteners. We recommend separating household and Institutional/Industrial/Commercial applications to avoid the confusion around ready to use, and use dilution optical brightener specification levels.

3.22 Concentration and Compaction The product may be sold ready-to-use, except for the following that shall be concentrated or compacted in order for the normal/medium load dose per kg of dry, soiled, laundry of the undiluted product to be at the following levels for household use and institutional use, accordingly: See Proposed Standard for table. Comment: ASTM standard testing includes an 8 lb. load of laundry, not 6 lbs. as stated here.

3.23 *Products Containing Enzymes Products that contain enzymes shall meet all Annex D criteria.

Comment: Some enzymes are known asthmagens. We don't feel there should be an exemption of this class of ingredients from the asthmagen and respiratory sensitizer prohibitions.

3.26 Product Stewardship Excellence Laundry detergent and softening products shall meet at least one of the following: • Meet the requirements in section 2.0 with very cold water. • Meet the requirements for “ultra-concentrated” products in section 3.22. • Be compatible for use in high efficiency (HE) machines or tunnel/continuous washing machines. • Be packaged in a recyclable primary package with the non-post consumer material weight, including lids and caps, at 0.035 g or less per g of product. • Be a closed dilution-control system or single dose system (e.g., pods, pouches, tablets). [NOTE: GREEN SEAL IS ESPECIALLY INTERESTED IN COMMENTS ABOUT THE APPROPRIATENESS OF THIS CRITERION. IF ALL BULLETS WERE TAKEN AS A WHOLE THIS OUTLINES THE PATH TO EXCELLENCE, BUT ONLY ONE OF THE BULLETS WOULD BE REQUIRED AS PROPOSED. IS THIS BEYOND LEADERSHIP – REPRESENTING ONLY A NICHE? SHOULD SOME BULLETS BE CONSIDERED A CRITERION RATHER THAN A PATH TO EXCELLENCE? SHOULD IT BE LEFT AS IS OR WITH SOME SLIGHT MODIFICATIONS?] Comment: While products may meet the requirements for very cold water washing, it is the consumer practice of washing in cold water that promotes sustainability and stewardship. Products that meet the requirements for ‘ultra-concentrated’ may exceed the aquatic toxicity limits. HE compatibility concerns any product which would cause sudsing, predominately detergent products. Currently, no testing standards exist for HE compatibility. Some detergent products claim on their labels HE compatibility when the HE load is dosed at half the amount recommended for traditional washers, which may impact cleaning efficiency. We recommend this criterion be deleted until testing methods are established.

4.0 MANUFACTURING SUSTAINABILITY REQUIREMENTS General comments regarding manufacturing requirements shall be made here. Comment: Section 4.0 (Manufacturing Sustainability Requirements) – This section is specific to manufacturing requirements, NOT sustainability. To simply report that you follow good manufacturing practices, energy water and waste usage and disposal, and to agree to established regulations regarding the work environment is not showing manufacturing sustainability. The principles of sustainability are environmental, social, and economic. It is inappropriate to use this term in this section: it should be removed.

5.3 Aerosol Packaging Aerosol packaging shall meet the following: • Manufacturers shall demonstrate that recycling programs for aerosol packaging are available to a substantial majority of communities where the product is sold. • Manufacturers shall provide documentation establishing why aerosol packaging is necessary for a given product addressing environmental, health, and performance considerations. • Aerosol packaging propellant shall meet all of the product-specific sustainability requirements in section 3.0 herein and shall not be a hazardous air pollutant. • For Section 3.3 Acute Toxicity herein, aerosol packaging components will be evaluated regardless of vapor pressure level. • The product contents from the nozzle to the point-of-delivery shall be in a form that does not contain any inhalable or respirable particles, such as but not limited to foams, or if the product contents are delivered in particle form the particles between 10-2.5 microns shall not comprise more than 1% of the total particles and no particles shall be below 2.5 microns. Comment: We would prefer that no aerosol packaging that delivers particulates be allowed.

5.4 *Disposable Wipes Products that are sold in a ready-to-use format may contain disposable wipes/towelettes/sheets or other disposable, single-use materials if they are made from 100% renewable materials and meet the state-of-the-art amount of recovered material content. An exception shall be made for reusable wipes/towelettes/sheets that are intended for multiple uses (e.g., three or more uses). [NOTE: GREEN SEAL IS PROPOSING A REVISION TO THIS FOUNDATIONAL CRITERION, WHICH WILL IMPACT OTHER STANDARDS WITH THIS CRITERION (GS-52 AND GS-53)] Comment: It is inappropriate to place a laundry product in packaging sustainability requirements. This should be moved.

5.6 *Other Restrictions Phthalates, bisphenol A, and chlorinated packaging material are prohibited from being intentionally introduced; an exception is allowed for primary packages that would not have added phthalates, bisphenol A, or chlorinated packaging material but for the addition of post-consumer material.

Comment: All product ingredients should be assessed against the same criteria. Also, prohibiting all members of a class of ingredients (e.g., phthalates) without regard to differences within the class inappropriately captures chemicals of varied impacts and creates disincentives to innovation within the class. For phthalates, there is little or no evidence that these have epidemiologic/human evidence of adverse effects (see Swan et al. 2005; Main et al. 2006; Duty et al. 2003, 2005; Juanjua et al. 2007). Finally, this criterion inappropriately focuses on the hazard potential of ingredients and not the risk they pose as a result of use in laundry product packaging. The restriction on BPA is not supported by current science. From a human health standpoint, the FDA recently concluded an assessment of scientific research on the effects of BPA and concluded that the evidence at this time does not suggest that very low levels of human exposure to BPA through the diet are unsafe.

6.3.1 Products Making Antimicrobial Claims Antimicrobial pesticide products shall have label instructions that the product should only be used on fabric soils or laundry conditions that have been identified to be at risk for disease transmission or where required by regulation. Equivalent language may be approved by the certification program Comment: Based on the 2011 Green Seal position statement on antimicrobial cleaning products it is clear that the organization believes that its standards do not conflict with or violate the EPA’s current approach to regulating antimicrobial products under FIFRA. However, on detailed review of publicly available information, is not clear that the governmental authorities are in agreement. Will they allow Green Seal listing, logos, or claims on a registered antimicrobial product? It appears irresponsible to encourage suppliers to purchase Green Seal approval without a clear path to sharing this certification with customers. If the regulatory authorities do not agree with Green Seal, manufacturers will either have wasted their certification investment, or worse yet, in addition to a wasted investment they will incur both fines and a reputational smear. Comment: Reference 6.3.1. The intent for this specification is understood. However, as written it causes confusion around implementation. If a manufacturer provides a GS-48 certified sanitizer or disinfectant, they can position it for healthcare settings, but it is not feasible to restrict sales to other market segments where the need must be understood on a case by case basis. Most importantly, the language seems to remove or discount the voice of the purchaser from determining when and if antimicrobial efficacy is required

6.7 *Ingredient Line The product label shall list the product ingredients using the naming convention of the

International Nomenclature of Cosmetic Ingredients (INCI) in order of predominance. Where an INCI name does not exist for an ingredient, alternative nomenclature may be used . Ingredients in concentrations of less than 1% may be listed in any order after those in concentrations of more than 1%. The general term ‘fragrance’ may be used for fragrance components; however, a list of fragrance components shall be made available to end-users in an easily accessible means, such as the company website, IFRA website, or technical data sheet. A chemical function or chemical class descriptor may be used to protect trade secret information. Comment: For consumer products, we recommend the use of the Consumer Product Ingredient Communication Initiative format for listing ingredients. This voluntary industry program has very good participation (>90% of products covered participate). Information about the program can be found here: http://www.cleaninginstitute.org/assets/1/Page/Ingredient%20Communication%20Model%20fnl%20rev%200311.pdf.

6.7.1 *Consumer and User Communication The product ingredient line shall be made available to end-users in an easily accessible means in addition to the product label, such as the company website or technical data sheet. Comment: This criterion would require ingredient communication be available on both the product label and at another source. As product size shrinks, so does the availability of space for important product information, such as proper use and disposal. We recommend that the Consumer Product Ingredient Communication Initiative program be followed. If a company chooses to provide ingredient information on a website or through a toll-free number, the website address or telephone number must be on the product label. Information about the program can be found here: http://www.cleaninginstitute.org/assets/1/Page/Ingredient%20Communication%20Model%20fnl%20rev%200311.pdf.

6.10 *Statement of Basis for Certification Whenever the product claims to be certified to this standard, it shall be based on a third-party certification program with an on-site auditing program, and shall state, unless otherwise approved in writing by Green Seal: This product meets the Green Seal™ Standard for Laundry Care Products, GS-48 through use of ingredients that are not toxic or harmful to humans and the environment, efficient use of packaging material, and documented product performance [for products that use wash water can include “at low wash temperatures”].

Comment: Green Seal allows the phrase, “…use of ingredients that are not toxic or harmful to humans and the environment.” This phrase needs to be put into context or may be at odds with the FTC “Green Guides”. The standard’s definition of toxic (500 mg/kg to 2,000 mg/kg) may not be in line with consumers’ interpretation of being not toxic. In addition, how can the product carry this statement along with the signal words as described in Annex C where moderately toxic or toxic are allowed?

ANNEX A – Normative Definitions of Terms (note that the defined terms are italicized throughout the standard) Aerosol Packaging. A primary package that requires a pressurized propellant to dispense product through a nozzle. Allergen. Allergenic substances listed by the European Commission Directive 76/768/EEC, 27 July 1976 on the Approximation of the Laws of the Member States relating to Cosmetic Products (also known as the Cosmetic Directive) in Annex III and those listed by the U.S. Food and Drug Administration (FDA) (including food allergens Food Allergen Labeling and Consumer Protection Act of 2004 (Public Law 108-282, Title II). Antimicrobial Agent. A substance intended to disinfect, sanitize, reduce, or mitigate growth or development of microorganisms and protect inanimate objects, industrial processes or systems, surfaces, water, or other chemical substances from contamination, fouling, or deterioration caused by bacteria, viruses, fungi, protozoa, algae, or slime. Antimicrobial Pesticide Product. An EPA-registered antimicrobial pesticide product or a minimum risk pesticide product intended for and capable of disinfecting, sanitizing, reducing, or mitigating growth or development of microorganisms and protecting inanimate objects, industrial processes or systems, surfaces, water, or other chemical substances from contamination, fouling, or deterioration caused by bacteria, viruses, fungi, protozoa, algae, or slime. Anti-Static Product. A product that is intended to eliminate, prevent, or inhibit the accumulation of static electricity. Asthma. Asthma is a chronic inflammatory disorder of the airways that impairs breathing. Asthma affects children and adults, may be intermittent or persistent, and is further classified as mild, moderate, or severe. The chronic inflammation associated with variable airflow obstruction commonly causes difficulty breathing, coughing, wheezing, shortness of breath, and/or chest pain. Symptoms may resolve completely between active episodes. Symptoms may occur during exposure, immediately after exposure, or up to 24 hours later in a “late phase,” frequently interrupting sleep.

Asthmagen. A substance designated as an asthma-causing agent by the Association of Occupational and Environmental Clinics (AOEC), which after review by AOEC have met the AOEC sensitization criteria. Benchmark Product. A product used to compare to for performance testing; usually a reference product or a national market leading product. Biobased. The content of a product that is from biological products or renewable materials, forestry, or agricultural materials (including plant, animal, and marine materials). Bleaching Product. A product that is intended to clean and remove stains from textiles and fabric by either oxidatively or reductively modifying the dirt/stain such that it becomes more water soluble and easier to remove or by decolorizing the stain such that it is no longer visible. Carcinogen. A substance listed as a known, probable, reasonably anticipated, or possible human carcinogen by any of the following agencies or programs: International Agency for Research on Cancer (Groups 1, 2A, and 2B); National Toxicology Program (Groups 1 and 2); EPA Integrated Risk Information System (weight-of-evidence classifications A, B1, B2, C, carcinogenic, known/likely human carcinogen, likely to be carcinogenic to humans, and suggestive evidence of carcinogenicity or carcinogen potential); Occupational Safety Health Administration (as carcinogens under 29 Code of Federal Regulations (CFR) 1910.1003(a)(1)); or under the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) (hazard categories 1 (H350, may cause cancer) and 2 (H351, suspected of causing cancer)). Certified-Organic Components. A component certified as organic (by meeting the USDA organic standards) by a USDA-accredited certifying agent or programs determined to be equivalent by or have recognition agreements with the USDA NOP. Child Labor. Work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. To avoid child labor the International Labour Organization provides the following instruments: Minimum Age Convention (e.g., a minimum age not less than 15 and 18 for hazardous work) and the Worst Forms of Child Labour Convention. Child-Resistant Packaging. Child-resistant packaging, as defined by the Poison Prevention Packaging Act, is packaging that is designed or constructed to be significantly difficult for children under five years of age to open or obtain a toxic or harmful amount of the substance contained therein within a reasonable time, and not difficult for normal adults to use properly, but does not mean packaging which all such children cannot open or obtain a toxic or harmful amount within a reasonable time. Code of Federal Regulations, Title 16, Part 1700 and Title 40, Part 157. Chronic Aquatic Toxicity. Long-lasting adverse effects to aquatic organisms. Substances

that are classified as long-term hazards to the aquatic environment are in hazard categories 1 through 4 (H410 through H413) under the GHS. Closed Dilution-Control System. Systems that control the dilution of a product so that the undiluted product cannot be practically accessed by users. Cold Water. For the purposes of this standard this refers to water wash temperatures of 80°F +/- 5°F; 27ºC +/- 3°C for household use and of 105°F +/- 5°F; 41°C +/- 3°C for institutional use. Colony Forming Unit (CFU). A measure of bacteria concentration assuming that each bacterium is capable of forming a colony. Color Component. A product component, such as a dye or pigment, whose only function is to change the product’s color. Component. A deliberate addition to the product added at any level or a contaminant that was not deliberately added but is known to be present above 0.01% (100 parts per million), by weight, in the product. Naturally occurring elements and chlorinated organics, which may be present as a result of chlorination of the water supply, are not considered components if the concentrations are below the applicable maximum contaminant levels in the National Primary Drinking Water Standards found in 40 CFR Part 141. Concentrate. A product that must be diluted by water prior to its intended use (e.g., a laundry detergent product that must be diluted before putting into a washing machine). Disinfecting. Destroying or irreversibly inactivating infectious microorganisms but not necessarily their spores on inanimate objects or surfaces. Enzyme. A protein that acts as a catalyst in biochemical reactions. Each enzyme is specific to a particular reaction or group of similar reactions. EPA-Registered Antimicrobial Pesticide Product. An antimicrobial pesticide product registered with the EPA under FIFRA (7 U.S.C. 136) or registered with Health Canada’s Pesticide Management Regulatory Agency (PMRA). Fabric Protectant. A product intended to be applied to textile or fabric substrates to protect the surface from soiling or to reduce absorption of liquid into the fabric’s fibers. This does not include flame retardant or waterproofing products. Fabric Refresher. A product intended to neutralize or eliminate odors on non-laundered textiles or fabric. This does not include anti-static products, spot removers, or antimicrobial pesticide products. Fabric Softener-Single Use Dryer Product. A product intended for single use in the dryer to impart softness to, or control static cling of, a load of washable fabrics. For the purpose

of this definition, “single use” means a product that is intended for one-time use during a single drying cycle and is removed after completion of the drying cycle. This does not include products applied to washable fabrics prior to placing the washable fabrics in the clothes dryer. Fragrance. An additive, often (but not limited to) a multi-component additive, used in a product with the purpose of imparting or neutralizing a scent in the product. Genetically Modified Microorganism (GMM). A microorganism in which the genetic material has been altered in a way that does not occur naturally by mating and/or natural recombination. The methods or techniques by which GMM are produced are listed by the European Commission Directive 2009/41/EC on the Contained Use of Genetically Modified Microorganisms. Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS established hazard classes and means for classifying substances; classification based on these hazard classes has been listed by the European Chemicals Agency and the ex-European Chemicals Bureau, or is disclosed on a SDS. Good Manufacturing Practices. Incorporation of quality practices and procedures, such as those included in the FDA Inspection Operations Manual, to minimize the risk of adulterated or misbranded products. Halogenated Organic Solvents. An organic solvent containing halogens, including, but not limited to, fluorine, chlorine, bromine, astatine, and iodine. Hazardous Air Pollutant. A substance listed by the EPA in the Clean Air Act Section 112(b) (1) as a hazardous air pollutant. Household Use. Use of products that are typically sold to consumers (usually through retail outlets such as stores or online sites) for their own personal use rather than for professional/institutional use. This typically includes, but is not limited to, cleaning and treating their personal property. Institutional Use. Use of products that are typically sold to cleaning professionals for cleaning in commercial or institutional facilities. This typically includes, but is not limited to, cleaning for government agencies, factories, sanitariums, prisons, restaurants, hotels, stores, automobile service and parts centers, health clubs, theaters, transportation companies, hospitals, schools, libraries, auditoriums, office complexes, and similar properties where any resident’s personal property is typically cleaned/treated by professionals (e.g., in-house or contract service providers rather than when the residents are responsible for cleaning tasks). This is typically referred to as commercial or professional use. Intentional Introduction. The act of deliberately utilizing a material in the formation of a primary package or packaging component where its continued presence is desired in the

final primary package or packaging component to provide a specific characteristic, appearance, or quality. Laundry. Textile and fabric materials that require removal of soils or stains or require freshening or treatment (e.g., anti-static, anti-wrinkle, protectant, starch) for use. For the purposes of this standard, this does not include furniture or carpet. Laundry Detergent Product. A product intended for use in laundry washing machines or for hand-laundering to enhance the cleansing action of water for textile and fabric substrates. These products are usually based on surfactants and builders and may be combined with additional functions like bleaching or softening. Laundry Prewash. A product that is intended for application to a textile or fabric prior to laundering in a wet-cleaning process, and that supplements and contributes to the effectiveness of laundry detergent products and/or provides specialized performance. Laundry Starch/Sizing/Fabric Finish Product. A product that is intended for application to a textile or fabric, either during or after laundering, to impart and prolong a crisp, fresh look and may also act to help ease ironing of the fabric. Microorganism. An organism that cannot be seen by the naked eye (microscopic organisms) including, but not limited to, bacteria, fungi, archaea, and protists. Also included in this category are viruses or virus-like particles, although they are generally regarded as non-living. Minimum Risk Pesticide. A special class of antimicrobial pesticide products that are not subject to federal registration requirements through the EPA because they meet specific requirements under section 25(b) of FIFRA, including, but not limited to, that the components, both active and inert, are demonstrably safe for the intended use. Moderately Toxic. A product having an acute mammalian toxicity oral lethal dose LD50 greater than or equal to 2,000 mg/kg or less than or equal to 5,000 mg/kg is considered moderately toxic for the purposes of this standard. Mutagen. A substance designated as known to induce, be regarded as if they induce, or which cause concern for humans owing to the possibility that they may induce heritable mutations in the germ cells of humans and thus meet the criteria for germ cell mutagenicity hazard categories 1 and 2 (H340 and 341) under the GHS. Natural Component. A component that comes from materials found in nature including mineral, forestry, agricultural, or biological materials such as, but not limited to, animal products produced by the animal but not part of the animal; do not contain petroleum or petroleum-derived compounds; do not contain transgenic hybrid organisms (inserted deoxyribonucleic acid that originated in a different species); have been processed without irradiation; and are not chemically altered.

Naturally-Derived Component. A component that is partially chemically altered without petroleum components and have been minimally processed such that they not be altered to such an extent that they are substantially less biodegradable or more toxic (examples of potentially acceptable processes are included in Appendix 2). Neurotoxin/Systemic Toxin. A substance designated as producing a specific target organ toxicity arising from either single exposure or repeated exposure and meets the criteria for hazard categories 1 or 2 (H370, H371, H372, H373) under the GHS or R48 danger of serious damage to health by prolonged exposure. Optical Brightener. An additive designed to enhance the appearance of colors and whiteness in materials by absorbing ultraviolet radiation and emitting blue radiation. These compounds are also known as fluorescent whitening agents. Organic Compound. Any member of a large class of chemical compounds whose molecules contain carbon, with the exception of carbides, carbonates, cyanides, diamond and graphite. Ozone-Depleting Compound. A compound with an ozone-depletion potential greater than 0.01 (Chloroflourocarbon - CFC 11=1) according to the EPA list of Class I and Class II Ozone-Depleting Substances, or any substances or mixtures falling into category 1 (H420), hazardous to the ozone layer, under the GHS. Pathogenic Microorganism. For the purposes of this standard this includes microorganisms that cause disease, including, but not limited to: coliforms, Escherichia coli, Salmonella, Staphylococcus aureus, Pseudomonas aeruginosa, and some yeasts and molds. Post-Consumer Material. Material that would otherwise be destined for solid waste disposal, having completed its intended end-use and product life cycle. Post-consumer material does not include materials and by-products generated from, and commonly reused within, an original manufacturing and fabrication process. Powders/Solids/Non-Aqueous Liquids. Products that cannot be formulated with additional water due to the form of the product, including, but not limited to: powdered detergents, solid bar soaps, detergents in tablet form, detergents as extruded or cast solids, non-aqueous liquid products in a dissolvable shell. Primary Cleaning Function. For the purposes of this standard, a cleaning product’s primary function is to remove soil. Primary Package. Package material that physically contains and contacts the product, not including the cap or lid. For products that meet the annex requirements for Products as Powders/Solids/Non-Aqueous Liquids, the primary package is the material that holds the individually packaged product units or the entire product contents, but does not include the protective packaging or wrap.

Product As Used. For products that are used with wash water it is the dilution of the product at a rate of 25 liters of wash water per kg of laundry washed . For products that are not used with wash water it is the most concentrated form of the product that the manufacturer recommends for a product’s intended use. Recyclable. The package can be collected in a substantial majority of communities, separated or recovered from the solid waste stream and used again, or reused in the manufacture or assembly of another package or product through an established recycling program. Reference Product. A standardized product formula that was developed through a consensus-based process. Refillable Package. A primary package that is routinely returned to and refilled by the product manufacturer at least five times with the original product held by the primary package, and demonstrated in practice. For the purpose of this standard, the product manufacturer or the product manufacturer's agent may refill a primary package. Renewable Material. A material that is rapidly generated in nature including, but not limited to, agricultural products and biomass like cellulosic materials. Reproductive Toxin. A substance listed as a reproductive toxin (including developmental, female, and male toxins) by the State of California under the Safe Drinking Water and Toxic Enforcement Act of 1986 (California Code of Regulations, Title 22, Division 2, Subdivision 1, Chapter 3, Sections 1200, et. Seq., also known as Proposition 65); or a substance designated as Category 1 (H360), known or presumed reproductive toxicant, or Category 2 (H361), suspected human reproductive toxicant, or having adverse effects on or via lactation (H362), under the GHS. Respiratory Sensitizer. A substance designated as Category 1 for respiratory sensitization (H334), leading to hypersensitivity of the airways following inhalation under the GHS. Sanitizing. Reducing, but not necessarily eliminating, microorganisms from the inanimate environment to levels considered safe as determined by public health codes or regulations. Secondary Cleaning Function. For the purposes of this standard, the secondary function of a cleaning product may be to enhance the primary cleaning function through bubble or foam formation or to provide some other added functional enhancement. Secondary Packaging. Packaging used to contain primary package/s and typically used for merchandizing. This does not include case or shipping packaging or the primary package, cap, or lid. Serious Eye Damage. The production of tissue damage in the eye, or serious physical decay of vision, following application of a test substance to the anterior surface of the eye, which

is not fully reversible within 21 days of application. This includes substances identified under Category 1 for Serious Eye Damage/Eye Irritation (H318) under the GHS. Skin Corrosion. The production of irreversible damage to the skin, namely visible necrosis through the epidermis and into the dermis, following the application of a test substance for up to 4 hours. Corrosive reactions are typified by ulcers, bleeding, bloody scabs, and, by the end of observation at 14 days, by discoloration due to blanching of the skin, complete areas of alopecia, and scars. This includes substances designated as Category 1A, 1B or 1C for Skin Corrosion/Irritation (H314) under the GHS. Skin Sensitizer. A substance that will lead to an allergic response following skin contact. Identified under Category 1 for skin sensitization (H317) under the GHS. Spot Remover. A product intended to clean localized areas or remove localized spots or stains on textiles or fabric. These products may or may not require subsequent laundering to achieve stain removal. This standard does not include carpet spot removers. Softening Product. A product used to make fabric softer and prevent static. This may be one of several functions of a product (e.g., laundry detergent product) or its sole function. Sour Product. A product used to change the pH of laundry wash from alkaline conditions down to more safe and neutral conditions. Source-Reduced Package. A primary package that has at least 20% less material (by weight) compared to containers commonly used for that product type. For bag-in-the-box type primary packages, the box is included in the weight if the box is used during product use or in product merchandising. Spray Packaging. A primary package that dispenses the product through a nozzle and the product is in small droplets (i.e., a spray). It does not require a pressurized propellant to dispense the product. Stain Removing Product. A product that is intended to remove stains from textiles and fabric. This includes, but is not limited to, products making stain removing claims, laundry detergent products, spot removers, bleaching products, and combination products. Surfactant. A compound that reduces interfacial tension between two liquids or a liquid and a solid. This includes detergents, wetting agents, and emulsifiers. Synthetic Component. A component created artificially rather than naturally or from natural components. For the purposes of this standard, naturally-derived components are not considered synthetic components. Take-Back Program. A program sponsored by the original product manufacturer that has been demonstrated to receive at least 50% of sold primary packages for recycling or reuse.

Third-Party Certification Program. A program without any financial interest or stake in the sales of the product or service being certified, or other conflict of interest. There must be a standard to base the certification upon and the standard must be appropriate and meaningful for its intended purpose. The standard must be publically available and developed with stakeholder input. Certification to the standard must be completed by an independent party (e.g., not the manufacturer of the product being certified), include site inspections, and have a monitoring program to verify ongoing compliance. Toxic. A product having an acute mammalian toxicity oral lethal dose LD50 greater than or equal to 500 mg/kg or less than or equal to 2,000 mg/kg is considered toxic for the purposes of this standard. Toxic Release Inventory Persistent, Bioaccumulative, and Toxic Chemicals. The chemicals listed by the EPA on the Toxic Release Inventory as Persistent, Bioaccumulative and Toxic Chemicals. Undiluted Product. The most concentrated form of the product produced by the manufacturer for transport outside its facility. Very Cold Water. For the purposes of this standard this refers to water wash temperatures of 60°F +/- 5°F; 16°C +/- 3°C or lower. World Health Organization (WHO) Risk Group 1. Microorganisms that are unlikely to cause human or animal disease under the basis for classification defined by the WHO in the Laboratory Biosafety Manual. In the case that a particular strain has conflicting risk group designations on various international lists, the most hazardous (highest level) designation will be utilized. The biosafety designation lists that will be consulted include: • Australia/New Zealand • Belgium • Switzerland • United Kingdom • Germany • United States Department of Health and Human Services, National Institutes of Health • European Commission • Singapore • Japan Comment: We support the use of the Association of Occupational and Environmental Clinics (AOEC) asthmagen list to define asthmagens for GS-48 and strongly support prohibiting asthmagens from inclusion in laundry care products. We would further encourage that the definition of asthmagens not be limited to the ones that meet the sensitization criteria, but that all asthmagens designated with an “A” on the AOEC List be prohibited from cleaners, especially those designated with a "G" or "generally accepted."

We also support the use of the GHS criteria to define respiratory sensitizers in addition to the AOEC asthmagen list. Comment: Reproductive Toxin Reference is made to the list of chemicals known to cause reproductive toxicity by the State of California, but ignores the process under the California law that allows a determination of “no significant risk” to be made through risk assessment. At a minimum, Green Seal should allow reproductive toxins to be present in products when their use does not trigger labeling under the process of the California regulations. Comment: The definitions of moderately toxic and toxic are not aligned with the Globally Harmonized System of Classification and Labeling of Chemical (GHS) as is the majority of the proposed standard. Moderately toxic (acute oral LD50 <2,000 >5,000 mg/kg) is equivalent to an acute category 5 under GHS and would require labeling of ‘may be harmful.’ This category is considered optional and many countries that have adopted GHS have not adopted this category. Therefore, labeling would not be required. Toxic (acute oral LD50 <500 >2,000 mg/kg) is equivalent to an acute category 4 under GHS and would require labeling of ‘harmful.’ This definition is not completely aligned with category 4 – the lower limit is 300 mg/kg. Under GHS, any ‘toxic’ labeling does not occur until the acute LD50 is less than 300 mg/kg. If the rest of the proposed standard is aligned with GHS criteria and definitions, I would recommend that moderately toxic and toxic also align with GHS.

ANNEX B – Normative Closed Dilution-Control System. Institutional use products in closed dilution-control systems that meet all of the following requirements may be evaluated for acute mammalian toxicity (3.3) and skin and eye corrosion (3.4) herein with the product as used (rather than with the undiluted product). A. Practically Inaccessible. The primary package shall not allow for access/exposure of the product during routine handling of the primary package, such as while transferring from shipping cartons, after opening a cap or lid, or when connecting to the dispensing system. B. Spill Resistant. The primary package shall require coupling to a specially designed device in order to dispense product. C. Drop Test. The primary package, with the lid on, shall be durable as demonstrated by passing the following drop test: drop the product from a height of 48 inches with 4 drops: flat-on-bottom, flat-on-top, flat-on-side, and corner; with passing results including that the primary packages must not leak, contents must be retained, and no damage to the outer primary package likely to adversely affect safety must be sustained.

D. Backflow Prevention. The product shall have backflow prevention included in the closed dilution-control system that meets the American Society of Sanitary Engineering's (ASSE) 1055B standard. E. Safety Data Sheet. The product label and SDS shall include the applicable text “meets Green Seal’s requirements for acute toxicity and/or skin and eye corrosion at the as-used dilution”. F. Certifier’s Web Site. The Web site of the certification program listing certified products shall identify which products were evaluated as-used, and which health criteria were evaluated as-used. Comment: We support Green Seal’s decision to include the closed-loop dispensing exemption for laundry products. As outlined in the document ‘Background Information of the Proposed Green Seal Standard for Laundry Care Products’, products sold in closed-loop dispensing systems eliminate waste, reduce costs and deliver additional safety measures by preventing worker exposure to the concentrated product.

ANNEX D – Normative Products Containing Enzymes. Products that contain enzymes shall meet all of the following: A. Enzyme Form. Enzymes in the product shall be in liquid form or an encapsulated solid (or other dust-free solid) with a minimum diameter of 0.15 mm. Smaller diameters may be permitted for solid products if they are demonstrated to result in airborne enzyme concentrations equivalent to or less than encapsulated solids with a 0.15mm diameter. B. Enzyme Source. The source from which enzymes were derived shall be identified to a species level and disclosed to the certification program. C. Enzyme Source Microorganisms. For enzymes derived from microorganisms, documentation shall be provided that the source microorganism is absent from the finished product. Test methodology and results shall be documented in sufficient detail and provided to the certification program. If the product does not conform to this provision, then all microorganisms shall meet the requirements in section Annex E herein. D. Sensitization and Asthma. Enzymes are exempted from the requirements for Asthmagens (3.8) and Respiratory Sensitization (3.9) herein. E. Spray Packaging. Enzyme products in spray packaging, or designed for use in spray packaging shall demonstrate airborne enzyme exposure for users below 1 ng/m3 when sampling is conducted according to the protocol described in the international Association

for Soaps, Detergents and Maintenance Products (AISE) document “Exposure measurements of enzymes of risk assessment of spray products.” F. Enzyme Labeling. Products containing enzymes shall declare clearly on the label and SDS, that the “product contains enzymes,” in addition to the listing in the ingredient line. G. Industrial Hygiene. Documentation shall be provided to the certification organization that demonstrates that the manufacturer has implemented an industrial hygiene plan intended to minimize concentrations of and exposure to airborne enzymes (e.g., engineering controls, work practices, and personal protective equipment) and monitor the air concentrations of the enzyme/s and worker illness/sensitization due to the enzyme/s. An example of best practices that may be applicable for this plan is available at AISE. Comment: We strongly disagree with the exemption of enzymes from the asthmagen and respiratory sensitizers prohibition. There is generally no known threshold for asthmagens and a full prohibition is most protective of users as well as occupants. In the study that Green Seal has used to justify the inclusion of enzymes it is clearly stated: “Therefore a lower benchmark where risk of sensitisation is clearly absent cannot be given with sufficient accuracy.” (HERA. 2007. Human and Environmental Risk Assessment for Subtilisin (Protease). http://www.heraproject.com/files/22-F-07_PROTEASE_HERA_Final%20Edition%20%28unsecured%20-%20PDFA-1b%29.pdf) In addition, according to the Green Seal Mission Statement at the beginning of the GS-48 standard, Green Seal “sets leadership standards that aim to reduce, to the extent technologically and economically feasible, the environmental, health, and social impacts throughout the life-cycle of products, services, and companies.” The life-cycle of cleaning products includes the manufacturing process. There are many studies, including recent studies, which show that workers employed in the manufacture of enzyme detergents are at risk of becoming sensitized and of developing work-related asthma. This has been seen despite the use of encapsulated enzyme preparations. A few of these studies are referenced below. In proposing an exemption to the asthmagen prohibition for enzymes, Green Seal had asserted that end users of enzyme products are not at risk of developing asthma. However, a recently published article provides evidence that this is not the case. Adisesh, et. al. report cases of occupational asthma (respiratory sensitization) and work-aggravated asthma in in workers using enzyme cleaners in a healthcare setting. This occurred even in workplaces with non-detectable or low air sampling results. Wipe samples on surfaces and hands did show positive results. The authors also assert that there is evidence that “enzyme is able to become airborne with minimal or no agitation of the detergent liquid” and that other chemicals in the product, like surfactants, can have a role in the ability of the product to become airborne. The effects of the components of the cleaning products on the ability for the enzyme to become airborne should be better understood prior to allowing their use in Green Seal-certified products. Because there are no known thresholds for asthmagens and because skin exposure has not been

fully explored for its role in respiratory sensitization, we strongly urge Green Seal to not expand the Enzyme Annex to other Green Seal standards including GS-48. We feel strongly that the environmental advantages of the use of enzymes, such as decreased use of heated water, are not enough to justify the human health effects, such as work-related asthma, which can disabling and long-lasting. In a recent announcement about new and revised third-party certification standards for cleaning products the California Department of Public Health Occupational Health Branch excluded GS-52 and GS-53 certified cleaning products that contain enzymes from our recommendation and we would need to do the same for GS-48 should the enzyme exemption be approved. (http://www.cdph.ca.gov/programs/ohsep/Documents/GS-ELStandards.pdf) If all Green Seal cleaning product standards are changed to exempt this class of asthmagen we would need to reconsider recommendation of using Green Seal certification to purchase cleaning products. References: van Rooy FG, Houba R, Palmen N, Zengeni MM, Sander I, Spithoven J, Rooyackers JM, Heederik DJ. 2009. A cross-sectional study among detergent workers exposed to liquid detergent enzymes. Nov;66(11):759-65. Brant A, Zekveld C, Welch J, Jones M, Taylor AN, Cullinan P. 2006. The prognosis of occupational asthma due to detergent enzymes: clinical, immunological and employment outcomes. Clin Exp Allergy, Apr;36(4):483-8. Brant A, Hole A, Cannon J, Helm J, Swales C, Welch J, Newman Taylor A, Cullinan P. 2004. Occupational asthma caused by cellulose and lipase in the detergent industry. Occup Environ Med;61:793-795. Vanhanen M, Tuomi T, Tiikkainen U, Tupasela O, Voutilainen R, Nordman H. 2000. Risk of enzyme allergy in the detergent industry. Occup Environ Med; 57:121-125. Cullinan P, Harris JM, Newman Taylor AJ, Hole AM, Jones M, Barnes F, Jolliffe G. 2000. An outbreak of asthma in a modern detergent factory. Lancet; Dec 2;356(9245):1899-900. Hole AM, Draper A, Jolliffe G, Cullinan P, Jones M, Newman Taylor AJ. 2000. Occupational asthma caused by bacillary amylase used in the detergent industry. Occup Environ Med;57:840-842. Adisesh A, Murphy E, Barber CM, Ayres JG. 2011. Occupational asthma and rhinitis due to detergent enzymes in healthcare. Occupational Medicine; 61:364-369. Comment: E. Spray Packaging. ACI recommends this criterion be amended to 15 ng/m3. This safe exposure level is based on a number of publications (see below). In addition, the sampling

should be conducted pursuant to the protocol described in Battelle (2000). This protocol can be found here: http://www.aciscience.org/docs/Characterization%20of%20Aerosols%20Generated%20from%20A%20Consumer%20Spray%20Product-Phase%20II_reduced.pdf. Weeks, J.A., Harper, R.A., Simon, R.A., Burdick, J.D. 2011. Assessment of sensitization risk of a laundry pre-spotter containing protease. Cutaneous and ocular Toxicology. 30(4):272-279. Basketter, D., Berg, N., Kruszewski, F.H., Sarlo, K., Concoby, B. 2012. The toxicology and immunology of detergent enzymes. Journal of Immunotoxicology. Available (early) online through ISSN 1547-691X print/ISSN 1547-6901 online. DOI: 10.3109/157691X.2012.659358. Sarlo, K., Dirchner, D.B., Troyano, E., Smith, L.A., Carr, G.J., Rodrigues, C. 2010. Assessing the risk of type 1 allergy to enzymes present in laundry and cleaning products: evidence from the clinical data. Toxicology 271(3):87-93. ACI Risk Assessment Guidance for Enzyme-Containing Products: http://www.aciscience.org/docs/SDA_Enzyme_Risk_Guidance_October_2005.pdf Developing Consumer Products Containing Enzymes: Ensuring Consumer Safety: http://www.aise.eu/downloads/20060626%20Enzymes%20booklet%20FINAL.pdf F. Enzyme Labeling. There is no reason for enzyme to be declared in the product twice on a label. ACI recommends this criterion be deleted. G. Industrial Hygiene. ACI’s publication, “Work Practices for the Handling of Enzymes in the Detergent Industry should also be referenced. That publication can be found here: http://www.aciscience.org/docs/Work_Practices_for_Handling_Enzymes.pdf.