Biobased Corrections

I just received the February issue of

EBN. Thanks for announcing USDA’s new biobased rule and the role BEES plays [“USDA Announces Biobased Rule,”

Vol. 14, No. 2]. I’d like to correct your statement:

“Each product must be reviewed by an independent entity using BEES … or using the ASTM D7075 standard for the environmental performance of biobased products, which is also based on life-cycle assessment.”

BEES is the only tool that may be used to provide information on the environmental and public-health benefits of the “items,” or product categories that USDA is designating. USDA also intends for BEES to be the only tool that may be used to qualify a specific product for a “USDA Certified Biobased Product” label. The only situation in which either BEES or ASTM D7075 may be used is when an agency is considering purchasing a specific biobased product and optionally makes a special request for more specific information on its environmental and public-health benefits from the manufacturer. This will not happen often.

Barbara Lippiatt, BEES developer

National Institute of Standards and Technology

Gaithersburg, Maryland

I think your site and newsletter are tops. I just have one comment. In her article “USDA Announces Biobased Rule,” Jessica Boehland made a statement about biobased rules relative to recycled-content rules, saying “in cases where the two rules contradict one another, federal agencies are instructed to follow the recycled-content CPG.” I would suggest a different take on this. The law authorizing the biobased program says we are not required to “buy bio” if the product is already on the U.S. Environmental Protection Agency’s CPG list for recycled products. But this doesn’t mean we

must buy recycled instead of biobased products. Biobased products can be purchased instead if they offer us a better value in terms of price, performance, or environmental impact. Thanks very much!

Karen Kivela, Green Procurement Program Manager

Air Force Center forEnvironmental Excellence

Brooks City-Base, Texas