Invitation to Comment: Criteria for Chemical Dispensing Systems
Green Seal’s new Environmental Innovation Beta Advisory Program allows product manufacturers to explore environmental and health impacts, engage in transformative product innovation, and achieve global recognition to the newest sustainability standard. 3M is a member of the initial cohort of beta program participants who are pursuing certification of their products under the Environmental Innovation Standard (GS-20, Edition 2.0). The company submitted three products for the GS-20 Review: Twist ‘n Fill™ , Flow Control (Locking Cabinet), and Flow Control (Portable) chemical management systems with the same primary innovation claim: A significantly reduced environmental impact resulting from greater dilution accuracy. According to the applicant, greater accuracy of the applicant dispensing systems can be reasonably expected to reduce human exposure and environmental impacts (including water quality degradation and risks to aquatic life) associated with the use phase when compared to systems with less accuracy, by providing users with a more reliable concentration of active ingredients in the final product.
Green Seal is seeking your feedback on 3M’s innovation claims for these products. We invite all members of our stakeholder community and the general public to submit comments by email to email@example.com. Feedback will be accepted through June 27, 2019. About Twist ‘n Fill™ and Flow Control Chemical Management Systems When used as intended, 3M’s Twist ‘n Fill™ and Flow Control Chemical Management Systems provide the following functions:
- Safely and accurately dilute chemical concentrates through an automated system to create ready-to-use cleaning products for industrial, institutional, and commercial facilities.
- Dispense multiple chemical solutions from a single device to create ready-to-use cleaning products.
Innovation Claim Details
3M claims that this product differs from other chemical management systems on the market because the measured average dilution accuracies of their systems are 37-96% and 63-98% greater compared with the measured average dilution accuracies of several leading systems on the market. The design of the applicant’s proportioning valve and the metering orifice (with no moving parts), and the introduction of a new metering orifice (with each package of concentrated cleaning product), maintains higher accuracy without the need for maintenance or servicing. 3M claims that greater accuracy of the applicant dispensing systems can be reasonably expected to reduce human exposure and environmental impacts (including water quality degradation and risks to aquatic life) associated with the use phase when compared to systems with less accuracy, by providing users with a more reliable concentration of active ingredients in the final product. Greater accuracy avoids the need to dial in higher concentrations to ensure that the resulting solution will be able to perform its intended function, which is likely to cause increased worker exposure, concentration of cleaning products in wastewater, and costs. The greater accuracy of dilution also reduces the likelihood that a solution using the specified concentration may not have enough active ingredients to perform adequately. Greater consistency in cleaning solutions will provide a commensurate increase in the consistency of cleaning and disinfection. Over time, consistent dilution accuracy results in significant reductions in active disinfection (quaternary compounds) and detergent ingredients. Green Seal has not yet validated any of these claims. Once Green Seal finalizes the requirements after this public comment period, 3M will submit documentation for third-party validation by Green Seal. The Twist ‘n Fill™ and Flow Control Chemical Management Systems will achieve Green Seal Certification for Environmental Innovation if all requirements in the 3M Chemical Management Systems Criteria Document are met.
About Green Seal’s Environmental Innovation Standard
Green Seal’s Environmental Innovation Standard (GS-20) provides a framework for the certification of environmental innovations in a variety of product categories. Applicants follow the steps below to complete the process:
Earning certification under the GS-20 Standard demonstrates that Green Seal, an independent third party, has verified the environmentally innovative aspect(s) of a product. The certification includes verification that the product innovation results in a significant reduction of human health and environmental impacts compared to products of the same functional class.