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Chapter 1: Green Cleaning Basics



What is Green Cleaning?

Green cleaning is a holistic approach to janitorial services that takes into account:
  1. the health, safety, and environmental risks of products and processes associated with cleaning;

  2. the mission and use of the facility to be cleaned and the behavior of facility occupants; and

  3. the cleaning, maintenance, and sanitation needs of the facility.
In other words, it is an approach to cleaning that involves the use of alternative products, applying those products in different ways, and evaluating and/or changing behaviors associated with how buildings are used to reduce risks while maintaining a satisfactory level of cleanliness and disinfection.
Example 1:

Traditional glass cleaner-made of alcohol and ammonia, which are solvents-is typically applied by using a trigger spray, which creates a fine mist. Vapors created by this product and process have the following effects:

  • Vapors can enter the breathing zone of cleaning personnel, causing respiratory irritation and triggering asthmatic attacks and other breathing disorders (especially when used repeatedly and over time).

  • Because they can remain in the restroom, vapors can affect building occupants using the restroom.

  • Vapors are circulated throughout the building by the ventilation system and can affect building occupants.

  • When the vapors are exhausted to the outdoors, they can contribute to atmospheric smog and air pollution.

Green cleaning alternatives can include:

  • Replacing the traditional glass cleaner with one that has no solvents-a detergent, or soap-based cleaner that produces fewer vapors.

  • Applying the product in a stream rather than a mist to reduce the vapors.

  • Applying the spray to a wiping cloth, rather than directly onto the glass, to reduce the vapors.

Example 2:

If occupants eat in their individual offices, they are likely to produce crumbs, which could attract pests. This might require more frequent pesticide or rodenticide applications than if all eating were centralized in a lunchroom or conference room. In addition, if employees clean up coffee or beverage spills at the time of a spill, rather than wait for the cleaning crew to do it (especially when it involves carpets or other fabrics), janitors can use fewer, and less-toxic, cleaning products than if spills dry or seep into carpet. Hence, green cleaning requires some involvement by building occupants.

Does Green Cleaning Work?

Green cleaning is a concept; it is a collection of new tools and practices that can be applied to traditional approaches. Green cleaning approaches vary from building to building. Green cleaning works if the products and processes used are targeted to the specific risks associated with each building, and if building managers, janitorial personnel, and building occupants all participate in the development of a green cleaning plan.

Why is Green Cleaning Important?

Green cleaning is all about reducing risk. Risk is the measure of the probability and severity of harm to human health or the environment. It is based on the type and toxicity of a hazard (that is, its potential effect on plants, animals, humans, and ecosystems) and the type and degree of exposure to that hazard (based on intensity, frequency, and duration). Risk is characterized by evaluating hazard and exposure together, along with the pathways by which people or the environment are likely to become exposed (e.g., through eyes, skin, lungs, or mouth and through contact with contaminated air, water, or soil).

No matter what changes are made to traditional products and processes, cleaning buildings-like all other activities in life-will never be without risk. All risk, however, can be evaluated on a continuum that ranges from very high to very low. Current cleaning practices might pose very high risks or avoidable risks, and changing certain practices and products might reduce unnecessarily hazardous practices with alternatives that are equally effective. Keep in mind, however, that although hazards and exposures generally can be evaluated for humans or the environment, the specific risk to an individual person or individual waterway, for example, will be unique based on individual circumstances, such as pre-existing health conditions, and vulnerabilities (i.e., asthma, heart disease) (for example, children and the elderly are more vulnerable). There are also trade-offs to be considered-for example, using a less-toxic product that requires more scrubbing to be effective-might reduce the risk of inhalation or skin contact, but that might also increase the risk of arm or hand injuries brought on by additional scrubbing.

Overall, however, the practice of green cleaning has many benefits. Green cleaning can:

  • Reduce health effects to building occupants and janitorial staff, such as skin, eye, and respiratory irritation or burns; allergies; multiple-chemical sensitivity; headaches; nausea or other gastrointestinal ailments; poisoning; cancer; reproductive hazards; and damage to liver, kidneys, and other internal organs.

  • Increase safety by reducing the likelihood and frequency of fires, explosions, spills, and splashes.

  • Reduce environmental impacts, including regional and global environmental issues such as air pollution, water pollution, raw materials resource use, bioaccumulation of chemicals in plants and animals, ozone depletion, and global climate change. Green cleaning also reduces the amount and toxicity of products and chemicals requiring disposal.

  • Reduce costs to building management, tenants, and/or the janitorial company associated with sick leave, health care, productivity loss, and litigation.

  • Increase occupant and worker satisfaction, including improved morale, productivity and efficiency, quality of life, and sense of well-being. This can result from decreased health effects and decreased annoyances such as malodor.

What Are the Federal Mandates for Green Cleaning?

Green cleaning is a new concept to many people in the cleaning industry, but one that is evolving into a professional standard. In fact, several federal mandates already exist that require federal agencies to consider environmentally preferable products and services in their acquisitions and procurements.

Executive Order 13101

Executive Order 13101 on Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition requires federal procurement officers to consider environmental factors in their purchasing and contracting decisions and directed the U.S. Environmental Protection Agency (EPA) to develop guidance to address environmentally preferable purchasing.

EPA established the Environmentally Preferable Purchasing (EPP) program in response to the Executive Order and developed guiding principles for applying environmentally preferable purchasing in the federal government setting. EPP clauses are being included in many federal contracts. The application of these principles in specific acquisitions varies depending on a number of factors, such as: the type and complexity of the product or service being purchased; whether or not the product or service is commercially available; the type of procurement method used (e.g., negotiated contract, sealed bid); the time frame for the requirement; and the dollar amount of the requirement.

For more information, see www.epa.gov/opptintr/epp.

Federal Acquisition Regulation

Section 23.703 of the Federal Acquisition Regulation (FAR) requires Executive agencies to consider environmental factors when purchasing products and services. Agencies must:

  • Maximize the use of environmentally preferable products and services.

  • Maximize the use of energy-efficient products.

  • Eliminate or reduce the generation of hazardous waste.

  • Promote the use of nonhazardous and recovered materials.

  • Realize life-cycle cost savings.

  • Promote cost effective waste reduction.

  • Consider the use of biobased products.

  • For more information, see www.arnet.gov/far.

Comprehensive Procurement Guideline

Section 6002 of the Resources Conservation and Recovery Act (RCRA), along with Executive Order 13101, requires EPA to designate recycled-content products and to recommend to federal agencies practices for buying these products. Once a product is designated, procuring agencies are required to purchase it with the highest recovered material content practicable. In response to these directives, EPA developed the Comprehensive Procurement Guideline (CPG) program to research and designate products and provide guidance. Federal agencies are now required to purchase janitorial supplies, such as facial tissue, bathroom tissue, paper towels, industrial rags and wipes, and plastic trash bags, with recycled content.

For more information on this program, visit www.epa.gov/cpg.

What Green Cleaning Standards Already Exist?

Several reputable standard-setting organizations have already developed voluntary standards and guidance for agencies, companies, and other organizations that want to adopt green cleaning practices.

The American Society for Testing and Materials (ASTM), an independent consensus based standard-setting organization, has issued guidance on procedures for developing a green cleaning program. The "Standard Guide for Stewardship for the Cleaning of Commercial and Institutional Buildings" (ASTM E-1971) was issued in 1998 to help owners and operators of commercial and institutional buildings adopt green cleaning and housekeeping practices. The standard provides recommendations for developing a stewardship plan; provides guidance on evaluating cleaning processes and selecting, using, storing, and disposing of products; and discusses equipment, training, and communications activities for a green cleaning program. According to ASTM, following the principles set forth in this guide can lead to greater tenant/occupant satisfaction, reduced operational costs, and greater productivity of occupants and cleaning personnel.

A copy of the ASTM standard is attached to this manual, with permission.

Green Seal is an independent, nonprofit organization dedicated to protecting the environment by promoting the manufacture and sale of environmentally responsible consumer products. It has developed a consensus-based standard for industrial and institutional cleaners. Green Seal standards set forth a list of product requirements that are based on an assessment of the environmental impacts of product manufacture, use, and disposal and reflect information and advice obtained from industry, trade associations, users, government officials, environmental and other public interest organizations, and others with relevant expertise.

Visit www.greenseal.org for a description of Green Seal and its certification process. Also, see the attached copy of the Green Seal Industrial and Institutional Cleaners standard.

Can Green Cleaning Help Reduce Regulatory Burdens?

Green cleaning can potentially help agencies, municipalities, or companies reduce the regulatory burdens associated with the use, storage, or disposal of chemicals used in traditional cleaning. Organizations should be familiar with the regulations governing the use of janitorial chemicals, but this manual provides an overview to demonstrate how switching to green cleaning can potentially reduce regulatory procedural and financial burdens.

Most agencies, municipalities, or companies that use dangerous chemicals in the workplace are regulated by the U.S. Occupational Safety and Health Administration (OSHA). OSHA regulations require employers to protect the health and safety of their employees through training, use of certain procedures (including personal protection), development of emergency plans, and more.

For information on OSHA regulations, visit www.osha.gov.

In addition, the U.S. Environmental Protection Agency (EPA) has passed several regulations affecting the janitorial industry:

  • If companies discharge dangerous chemicals directly or indirectly into the waters of the United States, they might be regulated under the Clean Water Act. The Clean Water Act specifies chemicals and chemical limits that can and cannot be discharged into the public sewer system, as this wastewater is eventually discharged into surface waters such as rivers or streams. Concerns for janitorial companies include chemicals or mixtures poured into the sink or toilets, such as floor finish containing zinc or toilet bowl cleaner containing hydrochloric acid.  For more information about the Clean Water Act, visit www4.law.cornell.edu/uscode/33/ch26.html.

  • The Clean Air Act regulates air emissions from area, stationary, and mobile sources. Under this law, EPA establishes national ambient air quality standards to protect public health and the environment. The Clean Air Act also seeks to prevent accidental releases of certain hazardous chemicals and minimize the consequences of such releases. Janitorial companies should consider whether the volatile organic compound (VOC) emissions from certain chemical products such as aerosol cleaners, or methylene chloride from graffiti removers exceed Clean Air Act limits. For more information about the Clean Air Act, visit www.epa.gov/oar/oaqps/.

  • If organizations create wastes that are hazardous (for example, rags that are soaked in solvents, unused cleaning chemicals that become waste, or residue from spills), they are regulated under the Resource Conservation and Recovery Act (RCRA). RCRA imposes certain rules upon the generator of hazardous waste (usually the building in which the wastes are created and/or the cleaning company itself), including recordkeeping, storage, disposal requirements, and emergency procedures.  For more information about RCRA, call toll-free 800 424-9346 or TDD 800 553-7672.

  • The Emergency Planning and Community Right-to-Know Act (EPCRA) requires organizations to report on the presence of certain hazardous chemicals on-site in quantities above a certain threshold, and also report annually on the location and hazards of these chemicals. In addition, facilities must report on certain waste management activities and the release of toxic chemicals. The data on toxic chemicals are compiled in a publicly available database known as the Toxics Release Inventory (TRI), which contains information on chemical emissions from almost 23,000 facilities in the United States. Under EPCRA, facilities also must develop chemical emergency plans. EPCRA is designed to provide local communities with information to protect public health, safety, and the environment. Some green cleaning programs restrict the use of chemicals that are reported through the TRI. Much of the EPCRA program is actually implemented through a local emergency planning agency such as a city or county.  For more information about EPCRA, visit http://www.epa.gov/emergencies/index.htm.

  • The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) governs releases or threatened releases of hazardous substances that may endanger public health or the environment. It requires operators of facilities to report releases to the environment due to chemical spills or other accidents and criminal penalties can apply for failure to report.  For more information on CERCLA, visit www.epa.gov/superfund/index.htm.

  • The Toxic Substances Control Act (TSCA) allows EPA to track the 75,000 industrial chemicals currently produced or imported into the United States. EPA repeatedly screens these chemicals for environmental or human-health hazards. EPA can ban the manufacture and import of chemicals that pose an unreasonable risk; prohibit or limit the amount of production or distribution of a substance in commerce; prohibit or limit the production or distribution of a substance for a particular use; limit the volume or concentration of the chemical produced; prohibit or regulate the manner or method of commercial use; require notification of the risk of injury to distributors and consumers; specify disposal methods; and require replacement or repurchase of products already distributed.  For more information about TSCA, call 202 554-1404 or TDD 202 554-0551, e-mail tsca-hotline@epamail.epa.gov, visit www4.law.cornell.edu/uscode/15/ch53.html.

  • The Safe Drinking Water Act protects the quality of drinking water in the United States by imposing safe standards of purity and requiring all owners and operators of public water systems to comply with health-related and nuisance-related standards, which in turn affect those entities, such as cleaning companies, that discharge chemicals into the public water system.  For more information about the Safe Drinking Water Act, visit www.epa.gov/safewater/sdwa/sdwa.html.

  • The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) imposes requirements on the distribution, sale, and use of pesticides, including disinfectants and antimicrobial products. For example, FIFRA requires users to register with EPA when purchasing pesticides and prohibits users from altering the product labels or using the product in way that is inconsistent with the label. For example, disinfectants containing quaternary ammonium chloride are regulated under FIFRA.  For more information on FIFRA, visit www.epa.gov/pesticides/.

  • Depending upon your exact location, you also might be regulated by state or regional laws, such as the following examples:

    • California South Coast Air Quality Management District (AQMD) standards. The AQMD is the air pollution control agency for the four-county region including Los Angeles and Orange counties and parts of Riverside and San Bernardino counties. Purchasers and janitorial managers in these counties must following stricter regulations set by the AQMD to reduce emissions and prevent pollution. For more information on AQMD, visit www.aqmd.gov.

    • State of California Safe Drinking Water and Toxic Enforcement Act, otherwise known as Proposition 65, requires California's governor to publish a list of chemicals that are known to the State of California to cause cancer, birth defects, or other reproductive harm. This list must be updated at least once a year. More than 550 chemicals have been listed as of April 1, 1996. Proposition 65 imposes certain controls that apply to chemicals that appear on this list. These controls, designed to protect California's drinking water sources from contamination by these chemicals, allow California consumers to make informed choices about the products they purchase, and enable residents or workers to take actions to protect themselves from exposures to these harmful chemicals. For more information, visit http://prop65news.com/pubs/brochure/madesimple.html#safe.

    • Chesapeake Bay Program Toxics of Concern. Based on ambient concentrations of chemical contaminants and aquatic toxicity data, this list identifies toxic pollutants that represent immediate or potential threats to the Chesapeake Bay system. Clear evidence is lacking that the contaminants on the Chesapeake Bay list of Chemicals of Potential Concern actually cause or have reasonable potential to cause adverse effects in the environment, but the Chesapeake Bay Program believes these chemicals warrant enough concern to be carefully monitored and tracked. For example, a number of the chemicals listed as being a potential concern are either banned or restricted pesticides that have residues still remaining in the ecosystem at elevated levels but below thresholds of concern; others chemicals are of increasing concern due to use patterns or potential for toxicity to Bay resources. For more information, visit www.chesapeakebay.net/toxics2.htm.

Some of these regulations primarily affect upper management in an agency, municipality, or company, while others directly impact janitorial management and staff. 

Changing cleaning practices and using less toxic products can reduce safety and health risks to workers and occupants and can reduce certain regulatory requirements, which can save organizations money. The next two chapters provide information on how to green cleaning practices and green cleaning products.