By Ilana R. Morady and Craig B. Simonsen

The U.S. Environmental Protection Agency’s Office of Inspector General has just released a report on an evaluation of the EPA’s “Design for the Environment” (DfE) Program. At A Glance, No. 14-P-0349 (September 9, 2014). The Inspector General found flaws in the current DfE logo, including that it improperly implied an EPA endorsement.

Since its establishment over fifteen years ago the EPA’s Design for the Environment Program has evaluated and approved more than 2,500 products to carry the DfE logo. In 2014 the EPA updated the “Safer Chemical Ingredients List” adding over 50 chemical ingredients and bringing the number of safer chemical ingredients to about 650. The DfE Program has also developed a new database system that the Agency suggests will enable it to better manage chemical, partner, and product information in a cloud-based system.

Issues the Inspector General found are that the current DfE logo does not adequately communicate to the consumer that the product is a safer product. The Inspector General also found a risk that an EPA endorsement of DfE products may be implied by the current logo, but any such EPA endorsement is not allowed. The EPA also “lacks sufficient controls over the use of its DfE logo” by former program participants.

The Inspector General also found that the EPA asserts that DfE products are cost effective, “but this has not been determined or reviewed.” In addition, “there are weaknesses in both former and proposed performance measures used by the DfE program” and EPA cannot accurately determine the program’s impact on pollution prevention.

To solve the issues with the DfE Program, the Inspector General recommended that EPA improve the DfE logo, periodically review program participants’ compliance with partnership agreements, address noncompliance with those agreements, remove statements on the EPA’s website that imply that DfE products are cost effective, and develop a performance measurement system.

The EPA has already published a notice seeking comments on four new possible re-designs for the DfE logo.

In the announcement, Jim Jones, the Assistant Administrator for Office of Chemical Safety and Pollution Prevention, says that the Agency “wants to hear from the American people on which designs will help people identify household cleaning and other products that are safer for families and the environment.” Jones specifically asks the public: “What is most appealing to you? What best conveys the concept of safer products for your family’s health? What are your thoughts on the words, graphic, colors and shapes?”

No doubt that industry — and public — input will be important in the re-design of the DfE logo.

Comments on the proposed DfE labels will be accepted until October 31, 2014.