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Green Purchasing Program Guide July 2008

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FEDERAL LAW ENFORCEMENT GREEN PROCUREMENT PROGRAM

TRAINING CENTER (GPP) GUIDE July 2008

FLETC GPP Guide i

TABLE OF CONTENTS

Introduction

1. Policy

1.1 FLETC Environmental Policy

1.2 FLETC Green Purchasing Program (GPP) Policy

1.3 Federal Law

1.4 Federal Acquisition Regulations

1.3 Executive Orders

2. Planning

2.1 Why Green Purchasing is Important

2.2 Green Purchasing Objectives and Targets

2.3 Required Actions

2.3.1 Recovered Materials

2.3.2 Energy and Water Efficient Products

2.3.3 Alternative Fuels and Fuel Efficiency

2.3.4 Bio-Based Products

2.3.5 Non-Ozone Depleting Substances

2.3.6 Priority Chemicals

2.3.7 Environmentally Preferable Products (EPP)

3. Implementation and Operation

3.1 Structure and Responsibility

3.2 Training

3.3 Communication

3.4 Document Control

3.5 Operational Controls

3.5.1 Applying GPP to Commodity Purchases

3.5.2 Executing GPP in Contracts for Construction and Services

3.5.3 Executing GPP in Non-Contracted (In-House) Projects

3.5.4 Product Certification and Qualification Programs

3.5.5 Resolving Conflicts between Purchasing Programs

4. Checking and Corrective Action

FLETC GPP Guide ii

4.1 Monitoring and Measurement

4.1.1 RCRA 6002 Report

4.1.2 Report to the President

4.1.3 FLETC Metrics

4.2 Corrective and Preventive Action

4.2.1 Internal Audits and contract Performance Information

4.2.2 Regulatory Inspections and EPA Compliance Guidance

4.3 Record Keeping

5. Management Review

5.1 Use GPP Monitoring Data to Drive Program Improvement

5.2 Reward Excellence

Appendix A - Glossary ............................................................................................................... A-1

Appendix B - Forms and Checklists ............................................................................................B-1

Attachment 1 – Green Procurement Requirements Reference Sheet ..............................B-2

Attachment 2 – Green Procurement Statement ................................................................B-6

Attachment 3 – Recovered Material Determination Form ..............................................B-8

Attachment 4 – CE Project Manager/COTR Considerations and Guidelines ...............B-11

Attachment 5 – GPC Green Procurement Considerations and Guidelines Log ............B-14

Attachment 6 – Green Procurement Program Annual Review Form ............................B-16

Attachment 7 – Green Procurement Program FAR Clause Selection Sheet .................B-20

FLETC GPP Guide iii

LIST OF ACRONYMS

A-E Architectural-Engineer

APP Affirmative Procurement Program

BEES Building for Environmental and Economic Sustainability

BPL Biobased Products List

CAR Corrective Action Request

CFR Code of Federal Regulations

CIO Chief Information Officer

COTR Contracting Officer’s Technical Representative

CPG Comprehensive Procurement Guidelines

CRBT Center for Resourceful Building Technology

CSI Construction Standards Institute

DoE Department of Energy

EA Enforcement Action

EO Executive Order

EPA Environmental Protection Agency

EM Environmental Management

EMS Environmental Management System

EPP Environmentally Preferable Purchasing

ETL Engineering Technical Letter

FAR Federal Acquisition Regulation

FEE Federal Environmental Executive

FEMP Federal Energy Management Program

FPDS Federal Procurement Data System

GPC Government Procurement Card

GPO Government Printing Office

GPP Green Procurement Program

GSA General Services Administration

JWOD Javits-Wagner-O’Day

NOV Notice of Violation

NRC National Recycling Coalition

OFEE Office of the Federal Environmental Executive

OFPP Office of Federal Procurement Policy

OCR Office of Collateral Responsibility

OPR Office of Primary Responsibility

P2 Pollution Prevention

PR Purchase Request

PWS Performance Work Statement

QAE Quality Assurance Engineer

RCRA Resource Conservation Recovery Act

RMAN Recovered Material Advisory Notice

SOW Statement of Work

USDA United States Department of Agriculture

FLETC GPP Guide iv

RECORD OF CHANGE/CORRECTION

NUMBER/CHANGE DATE POSTED NAME/OFFICE SYMBOL

FLETC Green Procurement Program Guide, July 2008

TRAINING CENTER (GPP) Guide July 2008

FLETC GPP Guide 1

Introduction

The Federal government is one of the largest purchasers in the world. In fiscal year 2002, Federal agencies spent more than $250 billion for goods and services to support the activities of approximately 1.7 million employees in 60 agencies. In addition, Federal agencies spent another

$15 billion on small purchases via purchase cards. Purchasing decisions can significantly influence the environmental performance of Federal facilities. By including environmental considerations in purchasing decisions, government procurement processes can be used to purchase products and services that reduce an organization’s environmental impacts.

Since 1976, requirements for “green purchasing” have been incorporated into Federal regulations and Executive Order requirements, with a goal of integrating environmental considerations into all stages of the Federal purchasing process. However, based on reporting by Federal agencies on their green purchasing activities, it is evident that Federal agencies are encountering challenges in fully implementing these requirements. Potential environmental costs and benefits associated with choosing one product or service over another may not be routinely factored into purchasing decisions. Different organizations within a facility may have differing perceptions of who is responsible for ensuring that the facility is buying green products and services.

Environmental staff may be familiar with green purchasing requirements and benefits, but they may find it difficult to initiate facility or agency-wide purchase of green products without the cooperation and support of upper management and those responsible for the purchase and use of these products. Procurement personnel may be familiar with green purchasing requirements but hampered by a lack of requests for green products and services from the user community.

Procurement personnel and product users also may not know how to locate green products and services to evaluate their performance and compare their environmental attributes. The goal of this Guide is to assist Federal Law Enforcement Training Center (FLETC) personnel at all levels in understanding the economic and environmental benefits of the green purchasing requirements mandated for Federal agencies.

Green Procurement (GP) is defined as the purchase of environmentally preferable products and services in accordance with federally mandated green purchasing preference programs.

Department of Homeland Security (DHS) and FLETC policy requires that purchases of products or services meet or exceed Federal Green Procurement Program (GPP) requirements to the maximum extent possible.

The GPP is an extension of the Affirmative Procurement Program (APP) established by

Executive Order (EO) 12873, Federal Acquisition, Recycling, and Waste Prevention (October

1993). Affirmative Procurement was the name for the “buy-recycled” purchasing program that

Federal agencies were required to implement. The intent of that program was to stimulate recycling by providing a market for products manufactured from recycled materials. In

September 1998, EO 13101, Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition replaced EO 12873 and greatly strengthened the APP.

The Affirmative Procurement program was further strengthened by EO 13423, Strengthening

Federal Environmental, Energy, and Transportation Management (January 2007) which superseded EO 13101 and added the current GPP requirements. The GPP is essentially an umbrella program that addresses seven procurement preference programs. The six mandatory procurement program elements include: (1) Recovered Materials, (2) Energy and Water http://www.archives.gov/federal-register/executive-orders/pdf/12873.pdf http://www.fedcenter.gov/Bookmarks/index.cfm?id=47&pge_id=1606 http://www.fedcenter.gov/programs/eo13423/

FLETC GPP Guide 2

Efficient Products, (3) Alternative Fuels and Fuel Efficiency, (4) Biobased Products, (5) Non-

Ozone Depleting Substances, and (6) Priority Chemicals. In addition, the program addresses the voluntary Environmentally Preferable Products program.

The Federal government has made significant progress in improving environmental and energy performance through its series of Executive Orders, Memoranda of Understanding, and other guidance. EO 13423 builds on that body of work and success by integrating and updating prior practices and requirements into a cohesive, strategic approach to further ensure enhanced performance and compliance with statutory and other legal requirements. Instructions For

Implementing EO 13423, “Strengthening Federal Environmental, Energy, and Transportation

Management”, March 29, 2007 provides implementation guidance for this new EO.

FLETC’s Environmental Management System (EMS) encompasses Green Procurement. Thus, Green Procurement becomes an environmental aspect and this GPP Guide encompasses the management action plan to address this aspect. Under the EMS construct, this GPP Guide consists of the following elements: policy, planning, implementation and operation, checking

(reporting) and corrective action, and management review.

http://www.fedcenter.gov/Documents/index.cfm?id=6825 http://www.fedcenter.gov/Documents/index.cfm?id=6825 http://www.fedcenter.gov/Documents/index.cfm?id=6825

FLETC GPP Guide 3

1. Policy

1.1 FLETC Environmental Policy

The mission of the FLETC is to train those who protect our homeland. In accomplishing this mission, FLETC must protect our natural resources, prevent pollution and reduce waste by integrating environmental stewardship into our day-to-day operations. By managing our facilities and programs in a manner that protects the environment we enhance mission performance, the safety of our employees and public health.

In support of this policy, FLETC leadership has directed the implementation of an EMS based on the International Organization for Standardization (ISO) 14001 framework and pledge:

To comply fully with the letter and spirit of all Federal, State and local environmental laws and regulations.

We will ensure that all appropriate staff members remain current on applicable laws and regulations

To consider environmental factors when making planning, purchasing, construction, and operating decisions.

We will adopt cost-effective practices that eliminate, minimize or mitigate environmental impacts and we will use environmentally preferable materials if those materials meet technical specifications.

To work continuously to improve the effectiveness of our environmental management programs

We will establish appropriate environmental objectives and performance indicators to guide these efforts and measure our progress.

To provide appropriate training and educate employees to be environmentally responsible on the job.

We will use a variety of training and communication tools to educate our employees about our environmental management system and how to apply its principles and policies to our everyday work.

To monitor our environmental performance regularly through rigorous evaluations.

We will conduct annual environmental reviews with senior management.

To work cooperatively with surrounding communities to anticipate, plan, and address common concerns regarding environmental stewardship.

FLETC GPP Guide 4

We will work to establish relationships with local community leaders and organizations to find ways to share our common environmental message.

To seek to prevent pollution before it is produced, reduce the amount of waste at our facilities, re-use and recycle whenever possible, and support pollution prevention by our partner organizations and suppliers.

We will participate in pollution prevention programs and develop related reports that can be shared within our facility and with others.

To communicate and reinforce this policy throughout our organization.

We will develop communication strategies that are designed to ensure employees and others who use our facilities have an appropriate understanding of this environmental management policy.

To reduce our current usage rates for electricity and water and strive to find alternative renewable sources of energy.

We will commit to researching and implementing the use of alternative energy sources such as wind and solar power.

1.2 FLETC Green Purchasing Program (GPP) Policy

FLETC policy requires that environmental impacts be considered in all purchasing decisions and that preference be given to those products and services designated by or recommended in Federal green purchasing preference programs. Products and services that have a lesser or reduced effect on human health and the environment are preferred when compared with competing products.

1.3 Federal Law

The Resource Conservation Recovery Act (RCRA) established the recycled content purchasing program.

The Farm Security and Rural Investment Act of 2002 (“Farm Bill”) created the biobased product program.

1.4 Federal Acquisition Regulations (FAR)

FAR 7.105(b)(16) requires acquisition plans to include environmental and energy conservation objectives associated with the acquisition.

FAR 11.302 requires the use of recovered materials, and consideration of environmentally preferable purchasing criteria developed by the EPA.

FAR 23.202 requires the Government to acquire supplies and services that promote energy and water efficiency, advance the use of renewable energy products, and help foster markets for emerging technologies. This policy extends to all acquisitions, including those below the simplified acquisition threshold.

http://www.fedcenter.gov/Bookmarks/index.cfm?id=1294&pge_id=1606 http://www.biobased.oce.usda.gov/fb4p/PoliciesAndLaws.aspx http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/07.htm#P63_11059 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/11.htm#P140_20867 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/23.htm#P26_2078

FLETC GPP Guide 5

FAR 23.403 requires the use of recovered materials considering cost, availability of competition, and performance. The objective is to acquire competitively, in a cost-effective manner, products that meet reasonable performance requirements and that are composed of the highest percentage of recovered materials practicable.”

FAR 23.404 requires each agency to establish an Affirmative Procurement Program (APP).

FAR 23.703 requires agencies to implement cost-effective procurement preference programs promoting energy-efficiency, water conservation, and the acquisition of environmentally preferable products and services.

FAR 23.803 requires agencies to minimize the procurement of materials and substances that contribute to the depletion of stratospheric ozone.

1.5 Executive Orders

EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management, 24

January 2007.

EO 13101, Greening the Government through Waste Prevention, Recycling, and Federal

Acquisition, 14 September 1998, Rescinded by EO 13423.

EO 12873, Federal Acquisition, Recycling, and Waste Prevention, 20 October 1993, Rescinded by EO 13101.

EO 13221, Energy-Efficient Standby Power Devices, 31 July 2001 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/23.htm#P102_10496 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/23.htm#P104_11171 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/23.htm#P228_28415 http://acquisition.gov/comp/far/current/html/Subpart%2023_8.html http://www.fedcenter.gov/programs/eo13423/ http://www.fedcenter.gov/Bookmarks/index.cfm?id=47&pge_id=1606 http://www.archives.gov/federal-register/executive-orders/pdf/12873.pdf http://www.fedcenter.gov/Bookmarks/index.cfm?id=54&pge_id=1606

FLETC GPP Guide 6

2. Planning

2.1 Why Green Purchasing is Important

Green purchasing is an important environmental stewardship activity, required by EO 13423 and in many cases provides products which outperform their conventional counterparts. Green purchasing can provide many benefits to help accomplish our mission more effectively.

Informed purchasing decisions can significantly influence FLETC’s environmental performance since the type of materials FLETC purchases can impact disposal costs, air emissions, and water and energy use. Wise planning can help manage these impacts.

The goal of GPP is to avoid unnecessary costs and negative impacts to the greatest extent possible. Since green purchasing requirements apply to all purchases of products and services, it is very important that FLETC maximizes the benefits of green purchasing by realizing and complying with all requirements.

In the EMS planning phase, activities which significantly affect the environment are identified, goals are set, and plans are created to manage the impacts of these activities. Green purchasing is one such activity--or, in EMS terms, it is an “environmental aspect.” The EMS process provides the framework whereby GPP “impacts” are effectively managed as a part of improving the overall environmental performance of FLETC.

2.2 Green Purchasing Objectives and Targets

Having identified green purchasing as a significant aspect under the FLETC EMS, the next step is to identify objectives (long-term goals) and targets (short-term goals) which reflect the principles established in the policy. EMS guidelines state that targets be specific and measurable within a specific time frame for accomplishment. There must be at least one target for each objective.

FLETC has one GPP objective – to improve green purchasing practices. To accomplish this objective, the following Targets are established for 2008-2009:

(1) To provide green purchasing training to all procurement staff in 2008.

(2) To publish this guide and make it intranet accessible to personnel involved in purchasing by the end of 2008.

(3) To conduct awareness training on purchasing and using green products and services for all requirements personnel, purchase card holders, and approving officials by the end of

2008.

(4) To ensure that the purchases of all computers, monitors and related equipment meet or exceed EPEAT Silver level requirements.

(5) To increase the use of 30% recycled content paper and recycled printer cartridges.

2.3 Required Actions

2.3.1 Recovered Materials

EPA has published regulations to implement the Resource Conservation and Recovery Act

(RCRA) and EO 13423. The “Comprehensive Procurement Guideline,” (CPG), is a list of products that are made with recovered materials, are technologically and economically feasible to produce, and will conserve raw materials and reduce the solid waste stream. The first CPG http://www.epa.gov/cpg/about.htm

FLETC GPP Guide 7 list was issued in 1995, and the list continues to grow as EPA adds new products. EPA also issues guidance for buying recovered material products in their “Recovered Materials Advisory

Notices” (RMANs). The RMANs mandate recovered material content ranges for CPG products based on current information about commercially available products. RMAN levels are updated by EPA as marketplace conditions change.

REQUIRED ACTIONS. FLETC personnel are required to purchase 30% recycled content paper for use with copiers and printers. This requirement is mandated by EO 13423 for all Federal agencies. Use of recycled printer cartridges is also encouraged as well as recycling of used printer cartridges.

Additionally, FLETC personnel must purchase recovered material products that are listed in the

EPA’s CPG. The CPG provides a concise summary of all of the requirements of the CPG and

RMAN. Note that although EPA considers the recovered material content percentages listed in the RMAN to be recommendations, FLETC has adopted these percentages as mandatory requirements. This means that when buying any of the items listed in the CPG, FLETC purchasers must acquire a product that meets the EPA recovered material percentage requirement, unless an exemption applies. Exemptions can be granted on a case-by-case basis if a recovered material product cannot be acquired:

Competitively within a reasonable period of time;

At reasonable prices; or

To reasonable performance standards in the specifications, provided a written determination by technical or requirements personnel of the performance standard's reasonableness is included with the justification. The technical and requirements personnel must base their determination on National Institute of Standards and

Technology guidelines, if available.

FLETC personnel may conduct market research and discover that certain recycled-content CPG items are continually being exempted due to ongoing price, supply, or technical issues. “Blanket exemptions” can be established for specific products that are unable to meet EPA requirements as long as DHS does not prohibit them, and the blanket exemptions are reviewed on an annual basis so as not to become outdated.

These exemptions must be documented in the contract file per FAR 24.405(c). Documentation must be provided to procurement personnel with the purchase request (PR) package.

The products that are covered by the CPG include but are not limited to paper and paper products, non-paper office products, vehicular fleet maintenance products, construction products, landscaping products, traffic control products, park and recreation products, and other miscellaneous products. Recovered material product requirements apply to all CPG item acquisitions made with federal dollars, no matter what purchasing mechanism is used or how they are paid for. Credit card purchases, all types of contracts, and in-house projects that include

CPG items must all comply with EPA requirements. Recovered material products are available from many government and commercial sources.

WHERE TO FIND APPROPRIATE PRODUCTS. Recovered material products are available from many government and commercial sources.

http://www.epa.gov/cpg/products.htm

FLETC GPP Guide 8

GSA Advantage! highlights these products. The GSA Environmental Products and Services

Guide is another way to locate CPG and other recycled products.

Defense Logistics Agency (DLA) Environmental Website offers re-refined oil and other environmentally friendly products.

DoD EMALL identifies environmentally preferable items with a green tree icon.

The Javits-Wagner-O'Day (JWOD) Program provides employment opportunities for over

36,000 Americans who are blind or have other severe disabilities through two nonprofit agencies, the National Industries for the Blind (NIB) and National Institute for the Severely

Handicapped (NISH) (serving people with a range of disabilities). Per FAR 8.002, these agencies are a mandatory source for all supplies and services which are on the Procurement

List. The JWOD program has begun several green initiatives. JWOD products can be purchased directly from the JWOD catalog. Throughout the catalog, products containing recycled content are indicated by the recycling symbol and the logo indicates products that are environmentally friendly. In addition to the catalog, their products can be purchased from authorized commercial distributors, including GSA Advantage! and the DoD

EMALL.

NISH is a source for janitorial services and is actively working to become a leader in green cleaning practices, including recycled-content product use. A report on the NISH web site explains this initiative.

UNICOR is another mandatory source of supply. UNICOR’s product categories include:

Clothing & Textiles, Graphics, Office Furniture, Fleet Management and Vehicular

Components, Electronics, Industrial Products, Recycling Activities, and Services. The

UNICOR web site describes their green product initiatives.

Central Contractor Registration (CCR): A database at http://www.ccr.gov can be used to locate small businesses that provide green products. On the main web page, choose the link to “Dynamic Small Business Search,” then search for “Buy Green NAICS codes.”

2.3.2 Energy and Water Efficient Products

The FLETC energy program responds to the Energy Policy Act of 2005; EO 13221, Energy-

Efficient Standby Power Devices: and EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management.

REQUIRED ACTIONS. FLETC must reduce energy use, purchase energy-efficient products, increase the use of renewable energy, and conserve water. The Federal Energy Management

Program (FEMP), the Energy Star program, and Department of Homeland Security Energy and

Water Conservation programs guide these efforts. FLETC is required to buy products that comply with Federal energy efficiency requirements, and to design and operate buildings to minimize energy and water consumption in accordance with EO 13423.

Energy and water conserving product purchases are mandatory elements of the FLETC GPP. In addition, FLETC personnel are encouraged to support Federal alternative energy goals by https://www.gsaadvantage.gov/ http://www.gsa.gov/Portal/gsa/ep/channelView.do?pageTypeId=8207&channelPage=/ep/channel/gsaOverview.jsp&channelId=-12972 http://www.gsa.gov/Portal/gsa/ep/channelView.do?pageTypeId=8207&channelPage=/ep/channel/gsaOverview.jsp&channelId=-12972 http://www.dlis.dla.mil/green/attributes/ http://www.dlis.dla.mil/emall.asp http://www.jwod.gov/jwod/p_and_s/p_and_s.htm http://www.jwod.gov/jwod/p_and_s/p_and_s.htm http://www.jwod.gov/jwod/about_us/green_projects.html http://www.jwod.com/ http://www.nish.org/NISH/Rooms/DisplayPages/LayoutInitial?Container=com.webridge.entity.Entity%5bOID%5b24BD2A456022C845ABAA178C057BB911%5d%5d http://www.unicor.gov/recycling http://www.ccr.gov/ http://www.fedcenter.gov/Bookmarks/index.cfm?id=54&pge_id=1606

FLETC GPP Guide 9 purchasing green power where it is available and cost-effective, and by including renewable energy technologies in construction projects where appropriate.

In accordance with EO 13423, beginning in FY 2008, all Agencies are required to reduce water consumption by 2 percent annually through the end of FY 2015 or 16 percent by the end of FY

2015.

Additionally, EO 13423 requires that each agency improve energy efficiency through the reduction of energy intensity. The goal is to reduce energy demand by 3 percent annually through the end of fiscal year 2015, or 30 percent by the end of FY 2015, relative to a FY 2003 baseline year.

In order to help achieve the above stated goals, the FLETC CIO will implement the following procurement practices:

1. Acquire electronic products using the Electronic Product Environmental Assessment

Tool (EPEAT) to achieve its energy reduction goals, unless there is no standard for such products.

2. Enable the Energy Star features on all computers and monitors.

Energy conservation requirements affect all purchases of computers, monitors, printers, scanners, fax machines and copiers; building construction, renovation and maintenance projects; and purchases of appliances. Water conservation requirements apply to all building construction and renovation projects.

WHERE TO FIND APPROPRIATE PRODUCTS AND SERVICES. Energy-saving products can be found in federal supply sources including the GSA Environmental Products and Services Guide, GSA Advantage! (look for the Energy Star symbol and the EE symbol) and the DoD EMALL.

Energy saving products are also available from commercial sources. To choose energy efficient products, look for the Energy Star first. If an Energy Star product is not available cost effectively, choose the most efficient product possible from FEMP’s Energy-Efficient Products list. Both programs use the same criteria, with Energy Star rated products attaining the highest level of performance. To identify products that meet the federal low standby power requirements, consult FEMP's online database of electronic products.

Products that support the water conservation Best Management Practices include water-efficient irrigation systems, toilets and urinals, faucets and showerheads, boiler and steam systems, and cooling towers and equipment. Water efficiency recommendations for some of these products are included on the FEMP technologies web site.

2.3.3 Alternative Fuels and Fuel Efficiency

The Energy Policy Act (EPACT), Public Law 102-486, addresses all aspects of energy supply and demand, including energy efficiency, alternative fuels and renewable energy. Title III of

EPACT states that of the total number of vehicles acquired by a federal fleet after 1999, 75% shall be Alternate Fuel Vehicles (AFVs). It also requires Federal agencies to arrange for refueling of AFVs at commercial fueling facilities that offer alternative fuels for sale.

REQUIRED ACTIONS. FLETC facilities must acquire AFVs (with the exception of law enforcement and emergency vehicles), alternative fuels for those vehicles, and fuel-efficient petroleum-powered passenger cars and light trucks.

http://www.fedcenter.gov/programs/eo13423/ http://www.fedcenter.gov/programs/eo13423/ http://www.gsa.gov/Portal/gsa/ep/channelView.do?pageTypeId=8207&channelPage=/ep/channel/gsaOverview.jsp&channelId=-12972 https://www.gsaadvantage.gov/ http://www.dlis.dla.mil/emall.asp http://www.energystar.gov/products http://www1.eere.energy.gov/femp/program/index.html http://www1.eere.energy.gov/femp/program/index.html http://www1.eere.energy.gov/femp/program/index.html http://www1.eere.energy.gov/femp/technologies/technologies.html

FLETC GPP Guide 10

Additionally, EO 13423 requires FLETC to:

1. Reduce the agencies fleet consumption of petroleum products by 2 percent annually through the end of FY 2015.

2. Increase non-petroleum based fuel consumption by 10 percent annually.

3. Use Plug-In Hybrid (PIH) vehicles when PIH vehicles are commercially available at a cost reasonably comparable, on the basis of life-cycle cost, to non-PIH vehicles.

All of the above requirements are based on an FY 2005 baseline.

WHERE TO FIND APPROPRIATE PRODUCTS. These web sites will assist customers in finding

AFVs, alternative fuels, and fuel efficient vehicles:

GSA’s Vehicle Leasing Program offers AFVs as part of their service.

DOE’s Clean Cities Program web site has an Alternative Fueling Station Locator.

The Fuel Economy Guide and other tools for finding fuel-efficient, environmentally preferable vehicles are available on the EPA/Department Of Energy (DOE) Fuel

Economy web site. Users can find and compare cars by gas mileage, greenhouse gas emissions, air pollution ratings, and safety information. The site also provides information regarding gas mileage tips, gas prices, advanced technology, and the importance of fuel economy.

EPA's Green Vehicle Guide is another tool for choosing the cleanest and most fuel-efficient vehicle that meets your needs. This guide provides information about the environmental performance of vehicles based on emissions levels, air pollution, fuel economy values and global warming impacts. This guide does not account for other environmental factors, such as recyclability of the vehicle, or other consumer preferences such as safety, cost, or driving performance. Users of the Green Vehicle Guide can look up ratings for specific vehicles, or view a list of the ratings for all current year vehicles.

2.3.4 BioBased Products

REQUIRED ACTIONS. FLETC personnel must comply with Federal and DHS GPP policy and give preference to the purchase of Bio-Preferred items on USDA’s Biobased products list

(http://www.biobased.oce.usda.gov/fb4p/Designation Items List.aspx).

Biobased items include office products; printing products; transportation fleet maintenance products; construction products; and janitorial and landscaping products.

There will be some overlap between the CPG list for recycled-content purchasing and the USDA list for biobased item purchasing. USDA’s Federal Register notice states that procurements that are subject to the CPG do not have to satisfy the biobased product requirements, if the two sets of requirements are inconsistent. This does not mean, however, that CPG requirements must automatically be followed in place of biobased purchasing. Purchasers should look at the benefits and costs of both types of products, and select the one that provides the best value overall.

http://www.fedcenter.gov/programs/eo13423/ http://www.gsa.gov/Portal/gsa/ep/contentView.do?P=FFFS&contentId=8060&contentType=GSA_OVERVIEW http://www.eere.energy.gov/afdc/fuels/stations_locator.html http://www.fueleconomy.gov/ http://www.fueleconomy.gov/ http://www.epa.gov/greenvehicles/ http://www.biobased.oce.usda.gov/fb4p/DesignationItemList.aspx http://www.biobased.oce.usda.gov/fb4p/DesignationItemList.aspx

FLETC GPP Guide 11

WHERE TO FIND APPROPRIATE PRODUCTS. Until USDA designates biobased items and establishes the voluntary labeling program, you can find biobased products by visiting the following sites:

The DOE Biomass Program develops technology for conversion of biomass (plant-derived material) to fuels, chemicals, materials and power, so as to reduce dependence on foreign oil and foster growth of biorefineries. Today's biomass products include ethanol, biodiesel, biomass power, and industrial process energy.

The United Soybean Board web site offers a Products Guide that lists consumer and industrial products.

The National Corn Growers Association web site has a database of information on availability of corn-based products for industrial and consumer use.

The GSA Environmental Products and Services Guide will include a biobased product category when more products become available.

NISH is a source for janitorial services and is actively working to become a leader in green cleaning practices, including biobased product use. A report on NISH’s web site explains this initiative.

2.3.5 Non-Ozone Depleting Substances

REQUIRED ACTIONS. When feasible, FLETC personnel must purchase SNAP-approved alternatives to Ozone Depleting Substances (ODS) products. The lists of these chemicals are managed by EPA's Significant New Alternatives Policy (SNAP) program.

The SNAP Program covers refrigeration and air conditioning; foam insulation; cleaning solvents;

fire suppressants; aerosol solvents and propellants; sterilants; and adhesives, coatings and inks.

The SNAP web site (http://www.epa.gov/ozone/snap/lists/index.html) identifies alternatives to

ODS products and provides lists of acceptable and unacceptable substitutes. Before installing

ODS substitutes in air conditioning and refrigeration systems, always follow the OEM recommendations. Some substitutes may result in reduction in equipment capacities and changes in operating temperatures.

WHERE TO FIND APPROPRIATE PRODUCTS. Non-ODS products are available through GSA

Advantage! (look for the SNAP symbol); the DoD EMALL; and commercial sources. The EPA

Database of Environmental Information for Products and Services includes information on products that have reduced ozone depleting potential.

2.3.6 Priority Chemicals

REQUIRED ACTIONS. FLETC employees must reduce their usage of these chemicals. FAR

23.703 supports this by requiring agencies to eliminate or reduce the generation of hazardous waste and promote the use of nonhazardous materials. EO 13423 requires agencies to establish goals to reduce the quantity of toxic and hazardous materials acquired. EPA has defined the priority chemical list to include:

cadmium http://www.eere.energy.gov/biomass/ http://www.unitedsoybean.org/newuses/ http://lepton.marz.com/ncga/comm_dev_center/index_PG.asp http://lepton.marz.com/ncga/comm_dev_center/index_PG.asp http://www.gsa.gov/Portal/gsa/ep/channelView.do?pageTypeId=8207&channelPage=/ep/channel/gsaOverview.jsp&channelId=-12972 http://www.nish.org/NISH/Doc/0/CBFCTNGH8V345B4B87IH7KLV25/F-T115-greening%20initiative-BRobinson.pdf http://www.epa.gov/ozone/snap/fact.html http://www.epa.gov/ozone/snap/lists/index.html http://www.epa.gov/ozone/snap/lists/index.html https://www.gsaadvantage.gov/ https://www.gsaadvantage.gov/ http://www.dlis.dla.mil/emall.asp http://yosemite1.epa.gov/oppt/eppstand2.nsf http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/23.htm#P228_28415 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/23.htm#P228_28415

FLETC GPP Guide 12 lead polychlorinated biphenyls (PCBs) mercury naphthalene

Part of the overall GPP effort is to find alternatives for these five priority chemicals or products containing them. The FLETC pollution prevention program focuses on identifying alternatives for these and other hazardous chemicals.

WHERE TO FIND APPROPRIATE PRODUCTS. The United States Air Force PROACT environmental research service can assist governmental employees with product substitution inquiries free-of-charge. Employees can visit their web site to browse and download the technical inquiry results. In addition, the EPA Database of Environmental Information for

Products and Services includes information on products that avoid the five priority chemicals.

And as it becomes available, more information will be posted on the OFEE web site, in the

Priority Chemicals and Waste Prevention sections.

2.3.7 Environmentally Preferable Products (EPP)

REQUIRED ACTIONS. FLETC personnel will endeavor to purchase any products and services that are more environmentally friendly than what we routinely purchase, but are not already covered by one of the mandatory programs described above.

WHERE TO FIND APPROPRIATE PRODUCTS. These web sites will help purchasers find environmentally preferable products:

Database of Environmental Information for Products and Services: EPA offers an extensive, searchable database of product-specific information (e.g., environmental standards and guidelines or contract language) developed by government programs, both domestic and international, as well as third parties.

GSA Advantage!

GSA Environmental Products Overview

OIKOS Green Building Source

Guide to Resource Efficient Building Elements http://www.afcee.brooks.af.mil/pro-act/PRO-ACThome.asp http://www.afcee.brooks.af.mil/pro-act/PRO-ACThome.asp http://yosemite1.epa.gov/oppt/eppstand2.nsf http://yosemite1.epa.gov/oppt/eppstand2.nsf http://ofee.gov/gp/pchemical.asp http://www.ofee.gov/wpr/wpr.asp http://yosemite1.epa.gov/oppt/eppstand2.nsf https://www.gsaadvantage.gov/ http://www.gsa.gov/Portal/gsa/ep/channelView.do?pageTypeId=8207&channelPage=%252Fep%252Fchannel%252FgsaOverview.jsp&channelId=-12972 http://oikos.com/ http://www.crbt.org/

FLETC GPP Guide 13

3. Implementation And Operation

3.1 Structure and Responsibility

The FLETC has established an EMS Support Team consisting primarily of Deputy Assistant

Directors from all areas of FLETC operations. The EMS Support Team along with employees from the Environmental and Safety Division, the Procurement Division, and the Chief Financial

Officer’s Directorate are responsible for implementing this Green Procurement Program. The

EMS Support Team has established the FLETC goal of 100% compliance with mandatory

Federal GPP guidelines in all acquisition transactions.

3.2 Training

GPP training will be disseminated to the FLETC workforce for anyone who buys or specifies purchases. Training will be required for all acquisition, requirements, and contracting personnel because it is one of the metrics to be tracked according to the FLETC GPP Strategy.

Government Procurement Card (GPC) holders will receive GPP training as a part of their annual

GPC training. Specific slides on the GPP have been added to the existing GPC training for this purpose.

In addition, general awareness training will be provided to the general FLETC populace via

Center News articles, Earth Day activities, and other electronic and printed means.

3.3 Communication

Communication is vital to program launch and sustainment. It includes training and awareness for both internal and external (contractors and vendors) customers. A sound communications strategy will help fulfill the RCRA and Farm Bill requirements to have a Promotion Program for green purchasing. GPP requirements will be communicated to offerors in Statements of Work and Performance-Based Work Statements (PWS) attached to solicitations for applicable supplies and services issued by contracting personnel.

3.4 Document Control

GPP documentation procedures will apply to all construction services and supply purchases.

GPP process guidance will be located on the FLETCNet. Current versions of documents will be maintained and obsolete documents will be promptly removed. Project-specific documentation will be maintained in the related contract file.

3.5 Operational Controls

Operational controls are procedures and specifications to ensure that FLETC personnel purchase designated and mission-appropriate green products and services, in support of our stated GPP policy, legal requirements and GPP objectives and targets. The objective is to ensure that product users and the procurement personnel who support them include environmental impacts along with only sole source, price, performance and availability in the criteria on which purchasing decisions are made. Environmental impact evaluation criteria must be included in the solicitation to make a best value award based upon GPP principals. To this end, several control documents have been developed and are included in Appendix B. These forms are provided for the users’ convenience. Other documentation, such as memos or emails, may be used to document compliance with the green purchasing program. The control documents provided include the following:

FLETC GPP Guide 14

The Green Procurement Requirements Reference Sheet (Attachment 1) includes web page links for GPP-compliant product lists, third-party Environmentally Preferred Products (EPP) standards, and selected sources of supply. The form also lists the EPA CPG recycled-content products. It can be used in conjunction with the other forms to identify the full range of GPP requirements that apply to a procurement action.

The GPP Statement (Attachment 2) is a form that has been developed to document that the

GPP was considered for purchasing actions that do not require GPP-compliant items. These items include U.S. EPA-designated CPG items, USDA-designated biobased items, Energy Star® listed items, and FEMP Low Standby Power items.

The Recovered Material Determination Form (RMDF) (Attachment 3) is for procurement actions that include EPA-designated recycled content items. It documents the CPG items that are required, states whether or not they meet EPA requirements, and provides the rationale for exemptions. Note that although EPA CPG items and USDA biobased items are both subject to the same exemption criteria (see Section 3.3.1), a written determination to justify an exemption request is only required for the EPA CPG items.

CE Project Manager/ Contracting Officer’s Technical Representative (COTR)

Considerations and Guidelines (Attachment 4) is a verification checklist to be used by Project

Managers and (COTR) to document ongoing GPP compliance during project quality assurance inspections.

The GPC Purchasing Considerations and Guidelines Log (Attachment 5) is intended to be used to document credit card holders’ purchases over the micro-purchase threshold ($3,000) of items that are designated for green purchasing under one of the mandatory Federal programs.

The log also identifies whether or not the product that was purchased met GPP requirements, and documents the reason for choosing a non-compliant product. Note that there is no requirement for written documentation pertaining to micropurchases; however, this log can be used to monitor GPC purchases of these items, and can be maintained in the purchasing files for auditing purposes.

The Green Procurement Program Annual Review Form (Attachment 6) is used to evaluate the progress of the GPP.

The FAR Clause Selection Sheet (Attachment 7) is used to document the applicable FAR clause(s) used in the contract.

3.5.1 Applying GPP to Commodity Purchases

Purchase Orders. GPP requirements apply to all commodity purchases, including those made by purchase order.

The end user of the product, in adhering to the GPP requirements, will determine whether or not GPP applies to the purchase. The Green Procurement Requirements Reference Sheet

(Attachment 1) aids in this process.

The user provides Contracting with the GPP Statement (Attachment 2) or a similar memo or e-mail statement if no GPP items are being acquired. The user completes the RMDF

(Attachment 3) if recycled-content CPG items on the EPA list are to be purchased. Other documentation (a memo or e-mail) are provided to Procurement if USDA-designated biobased items, FEMP or Energy Star energy-efficient items, or FEMP Low Standby Power

FLETC GPP Guide 15 items are being purchased. Contracting will not establish the requirements documents for purchase orders without adequate GPP documentation.

“Blanket exemptions” are established for specific products that are unable to meet EPA requirements as long as DHS does not prohibit them, and the blanket exemptions are reviewed on an annual basis so as not to become outdated.

Government Purchase Cards. GPP requirements do apply to GPC purchases even though most purchases are below the micropurchase limit ($3,000). Cardholders, however, must comply with the requirements of EPA’s CPG unless an only sole source, timeliness, performance, or price exemption applies. These exemptions must be documented for those purchases above the micro-purchase threshold ($3,000).

The end user of the product will work with the credit card holder to determine whether or not

GPP applies to the purchase, and identify products that meet GPP requirements. The Green

Procurement Requirements Reference Sheet (Attachment 1) aids in this process.

Note that although the GPP requirements apply equally to micropurchases and larger purchases, written determinations to justify a CPG exemption request are not required for micropurchases.

The GPC Purchasing Considerations and Guidelines Log (Attachment 5) is a form that is used to document how GPP was considered by the purchaser. It documents whether or not the

GPC purchase met applicable green purchasing requirements, and the rationale for choosing a non-compliant product.

3.5.2 Executing GPP in Contracts for Construction and Services

It takes teamwork and attention to detail to ensure that GPP is successfully included in contracts for construction, supplies and services. First, all contracted projects are evaluated by the requiring organization to determine if any of the GPP program elements apply. The Green

Procurement Requirements Reference Sheet (Attachment 1) assists with this evaluation.

If the project or service contract has no GPP requirements, the requiring organization will document this using the GPP Statement (Attachment 2) or equivalent documentation. This shows that GPP has been considered and no further action is needed. The documentation shall be submitted with the Purchase Request package and will be included in the contract file.

If the project or service contract includes requirements for one or more of the recycled-content products on the CPG list, the Recovered Material Determination Form (RMDF)

(Attachment 3) is completed and included in the applicable contract specification. This form documents the CPG items that are required, states whether or not they meet EPA requirements, and provides the justification for any exemptions that are being invoked. The completed forms then become part of the official contract file as a submittal.

Additional documentation (a memo or e-mail) is provided to Contracting if USDA-designated biobased items, FEMP or Energy Star energy-efficient items, or FEMP Low Standby Power items are required. Contracting shall receive adequate GPP documentation from requirements personnel for all contract actions.

FLETC GPP Guide 16

Construction projects are typically executed by a design agent. The GPP Statement

(Attachment 2), RMDF (Attachment 3), or equivalent forms supplied by the design agent will be used to identify GPP requirements that apply to the project. GPP specifications and other

Sustainable Development goals are included in the project’s Construction Criteria Document or Requirements and Management Plan, along with the rest of the program’s technical requirements.

The requiring organization will then write the Statement of Work or PWS that will define the contractor’s performance requirements.

If an A/E design contractor is to be used to develop construction project specifications, ensure that the selection criteria included in FAR 36.602-1 have been considered. Design agents are responsible for including these criteria when choosing A/E firms to design construction projects.

The project manager shall include GPP specifications in the A/E firm’s Statement of Work for construction projects. Per FAR 36.601-3: “For facility design contracts, the statement of work shall require that the architect-engineer specify, in the construction design specifications, use of the maximum practicable amount of recovered materials consistent with the performance requirements, availability, price reasonableness, and cost-effectiveness.

Where appropriate, the statement of work also shall require the architect-engineer to consider energy conservation, pollution prevention, and waste reduction to the maximum extent practicable in developing the construction design specifications.”

When buying green, either write detailed Statements of Work (SOW) or use Performance-

Based Work Statements (PWS). Green contract language for more than 600 products and services is included in EPA’s EPP Database and can be added to the SOW or the PWS.

Design agents are responsible for including appropriate GPP requirements in construction specifications. Design agents must review the specifications with this in mind and identify any discrepancies to the project manager. Guide specifications are available from the

Construction Criteria Base on the WBDG web site; these guide specifications have been updated to include EPA recycled-content requirements, but may not yet contain all required…