mr BRADLEY MILLER

Contacted Senator Gary Peters' office for information on China tariff exemption process. Urged an end to tariffs. Conference call with Mexico Desk of ITA on 8/20/19 for information on new certifications required by that country for imported products with electrical components.

Advocated for GSA adherence to American National Standards in all purchasing systems. BIFMA, ANSI, and NIST representatives discussed the eCommerce pilot (Commercial Platforms Initiative) and procurement vehicles with micro-purchase thresholds using government credit cards on a 9/11/19 conference call. BIFMA argued that ANSI standards should never be waived, in any scenario. Safety and performance of products used by the federal workforce should be the highest priority and the technology should be powerful enough to assure that as opposed to not being able to factor it in as a basic requirement. Participated in a Coalition for Government Procurement meeting with the Government Accountability Office (GAO) on July 15. GAO is preparing a report for Congress on Federal Prison Industries (FPI) and had asked for input from the Coalition's Furniture Committee in preparing the report. BIFMA supports the report and determination of all negative affects of FPI on the economy or private sector jobs as well as getting a true picture of the program's impact on recidivism. It has never been factually established that the program reduces the return of paroled individuals to prison solely because they worked in the prison industries program. Those selected to work in FPI are the least likely to return to prison anyway. It is a flawed data sample and the GAO should compare those numbers with recidivism rates for those who worked in libraries, kitchens, or elsewhere. It isn't even "work" that results in less recidivism. A very interesting study would look at those who would normally be chosen for a work program in a facility without a work program to track their recidivism rates. Our hunch is that it would still be less than for others in the same facility, while doing no work whatsoever, making the recidivism claims of FPI and others baseless. A more important evaluation of the program would be how many paroled participants get jobs upon release due to their training. Contacted US Senator Debbie Stabenow's office for information on Buy American Act and Presidential Executive Order that would make changes to domestic materials content levels of products purchased by the US Government.

Presented July 18 briefing and August 14 webinar to General Services Administration's IWAC staff on the ANSI/BIFMA e3 Furniture Sustainability Standard and the LEVEL Certification Program.

Urged US Rep. Fred Upton to support HR 2647, The Safer Occupancy Furniture Flammability Act. The bill would make California's Technical Bulletin 117-2013 a national flammability standard.

Signed letter to Federal Energy Regulatory Commission urging greater electricity competition in the marketplace.

Presentation with EPA representative, Best Buy, Staples, and ecomedes to Sustainable Purchasing Leadership Council Summit on "eCatalog Integration: Simplifying Access to Sustainable Products".

Letter to US Rep. Fred Upton urging support for HR 2647, The Safer Occupancy Furniture Flammability Act. The bill would make California's Technical Bulletin 117-2013 a national flammability standard.

Introductory meetings with two new CPSC members (Commissioners Feldman and Baiocco) on 3/18/19. Communicated BIFMA work on California flame retardant regulatory changes and advocated for a national rule based on that state's smolder test, Technical Bulletin 117-2013.

Signed on to Americans For Free Trade letters to members of the new Congress (1/9/19) and the President (1/27/19) opposing tariffs with China. Participated in National Association of Manufacturers USTR roundtable on US-EU regulations (3/14/19). Contacted U.S. Senators Debbie Stabenow and Gary Peters (3/21/19) about their positions on NAFTA/USMCA approval.

Signed on to Americans For Free Trade letter to the President opposing tariffs with China and urged U.S. Senators Debbie Stabenow and Gary Peters to endorse a Senate letter to USTR calling for List 3 exclusions in the China 301 Tariffs action.

Provided US Senator Gary Peters' office with furniture industry contacts for background information on PFAS issue. Communicated with EPA and GSA contacts about the furniture industry sustainability standard and Joint Committee meeting of December 12, 2018.

Presentation to GSA on ANSI/BIFMA Standards for business and institutional furniture.

Conference call with EPA staff on BIFMA & EPP program activities. Discussed the LEVEL certified products database and how to accurately incorporate it into a product registry webinar. Follow up communication to EPA Deputy Director Tom Tillman about the decision to retract the agency's recommendations in the Lumber/Wood product category. Asked for an explanation of the reasoning for doing so on June 27, 2018. Still no response provided.

Conference call with GSA staff to discuss how to strengthen adherence to ANSI/BIFMA Standards for GSA Furniture Schedules; review new ANSI/BIFMA updates; and discuss ways to educate the GSA staff on furniture standards.

Trade issues (NAFTA, steel and aluminum tariffs) continue to be a concern to the furniture industry. Encouraged US Representative Bill Huizenga, US Senator Debbie Stabenow, and US Senator Gary Peters to revert to diplomacy instead of threats and trade wars to advance trade policy goals. Participated in the local US Department of Commerce Commercial Services office sponsored World Trade Week to discuss current trade problems including the renegotiation of NAFTA. Met with US Representative Bill Huizenga to understand his legislation (H.R. 4248) to amend the Securities Exchange Act of 1934 to repeal certain disclosure requirements related to conflict minerals. Provided industry input.

Informed US Senator Debbie Stabenow of the unintended consequences of rushing to new "Buy American" rules in federal procurement that could disrupt supply chains with long standing trading partners. Urged Rep. Bill Huizenga to oppose prison reform legislation in the House of Representatives that would give Federal Prison Industries new advantages in the government marketplace. Worked with the Coalition for Government Procurement to address problems that could occur with e-Commerce platform purchasing that would bypass established federal procurement goals as well as disadvantage many businesses currently selling to the government.

Steel and Aluminum Tariffs were a concern to the furniture industry. BIFMA sent a letter to the White House, US Department of Commerce, and Members of Congress expressing those concerns. I met with US Senator Gary Peters' Regional Representative in West Michigan to discuss our concerns. BIFMA connected with the local US Department of Commerce Director of Commercial Services in Grand Rapids, MI to renew the office's relationship with personnel there in light of the growing tension in international trade circles.

Worked with the Sustainable Purchasing Leadership Council to promote sustainable purchasing and recognition of credible standards like the furniture industry's ANSI/BIFMA e3 Furniture Sustainability Standard and LEVEL Certification Program. There are many stakeholders in the SPLC including representatives from federal agencies. EPA participated in one meeting and I wrote to Nancy Beck, Deputy Assistant Administrator of the Office of Chemical Safety and Pollution Prevention, encouraging the agency to publish the EPA's updated Guidelines for Ecolabels and Standards with the accompanying Assessment Manual online.

Worked with the Sustainable Purchasing Leadership Council to promote sustainable purchasing and recognition of credible standards like the furniture industry's ANSI/BIFMA e3 Furniture Sustainability Standard and LEVEL Certification Program. There are many stakeholders in the SPLC including representatives from federal agencies. EPA participated in one meeting and I wrote to Nancy Beck, Deputy Assistant Administrator of the Office of Chemical Safety and Pollution Prevention, encouraging the agency to publish the EPA's updated Guidelines for Ecolabels and Standards with the accompanying Assessment Manual online.

Steel and Aluminum Tariffs were a concern to the furniture industry. BIFMA sent a letter to the White House, US Department of Commerce, and Members of Congress expressing those concerns. I met with US Senator Gary Peters' Regional Representative in West Michigan to discuss our concerns. BIFMA connected with the local US Department of Commerce Director of Commercial Services in Grand Rapids, MI to renew the office's relationship with personnel there in light of the growing tension in international trade circles.

Continued work on an update to the ANSI/BIFMA e3 Furniture Sustainability Standard with many stakeholders including representatives from EPA and GSA.

Participated in the General Services Administration's Quality Partnership Council meeting in Philadelphia. The QPC is a multi-stakeholder group of federal agency representatives, suppliers and consultants from the private sector, and GSA officials that meets to learn from each other and solve any problems with the procurement process. Also provided a GSA representative with information on BIFMA's furniture sustainability database and suggestions on how government search capabilities could be improved for faster and easier location of products.

Continued work on an update to the ANSI/BIFMA e3 Furniture Sustainability Standard with many stakeholders including representatives from EPA and GSA.

BIFMA signed on to a Federal Wood Industries Coalition letter asking the EPA to recognize an equivalent method of testing for compliance with the new Federal Formaldehyde Rule. BIFMA supports the rule and its smooth implementation. BIFMA also signed on to a National Association of Manufacturers letter to the CPSC regarding a proposed rule that would establish a mandatory standard for table saws sold in the U.S. requiring manufacturers to incorporate a patented technology. The rulemaking process was initiated in 2006 when the Commission granted a petition by the holder of the patents to establish a mandatory standard. If the rule is finalized, the CPSC would create an unprecedented government-imposed monopoly for the patent holders.

BIFMA endorsed OSHA's Safe and Sound Week on Social Media.

Continued work on an update to the ANSI/BIFMA e3 Furniture Sustainability Standard with many stakeholders including representatives from EPA and GSA. EPA stakeholders encourage development of a calculator to determine benefits of the program. Commented in support of an EPA proposal giving manufacturers more time to comply with the new Formaldehyde Rule. BIFMA supports the rule, and reasonable time frames for implementation. Communicated support to EPA staff of their Recommendations of Specifications, Standards, and Ecolabels for Federal Purchasing. Encouraged other pilot assessment program participants to work with each other to learn where individual programs could be strengthened. Participated in NIST Standards Education Workshop on Sustainability. Relayed the BIFMA experience and rewards of developing a standard and certification program for furniture.

Communicated with US Department of Commerce International Trade Administration staff for guidance on the Technical Barriers to Trade process at the World Trade Organization and what the industries options are for addressing an issue of concern.

Continued work on an update to the ANSI/BIFMA e3 Furniture Sustainability Standard with many stakeholders including representatives from EPA and GSA. A straw ballot was conducted and input from the GSA representative on the committee received. Offered GSA our assistance in training federal government personnel on the standard. Worked with Environmental Protection Agency staff on a proposed VOC spec for federal procurement of furniture. Contacted EPA about the "Accessing Standards" link on their Recommendations of Specifications, Standards, and Ecolabels for Federal Purchasing website page to make sure government agencies could easily access free copies of BIFMA's standard. Contacted GSA about a new green icon on the GSAAdvantage! site that Schedule contractors can use to identify product environmental attributes. An EPA Recommended icon is available for products that conform and/or are certified to one of the specifications, standards and ecolabels recommended by EPA. BIFMA offered to help GSA educate vendors on the icon and how to update their product information.

Continued working with GSA as part of a Schedule 71 Structure/Scope Working Group on an update to the current Schedule 71 solicitation, specifically the product subgroups under the contract organized by SIN, the technical requirements, and the requirements for packaged office offerings.

Requests to OSHA's Directorate of Enforcement Programs (DEP) for an official interpretation letter on Safety Data Sheets and the Article Exemption. Sought assistance of US Senator Gary Peters' Office to expedite a response. Met with staff to explain our position. Attended Small Business Meeting in Grand Rapids MI hosted by US Rep. Bill Huizenga.

Continued work on an update to the ANSI/BIFMA e3 Furniture Sustainability Standard with many stakeholders including representatives from EPA and GSA. Continued working with the Environmental Protection Agency on a Pilot of Draft Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement. Serving on the Furniture Panel and Guidance Committee for the Pilot. Worked with EPA and GSA on sustainable procurement issues and tools directly and through the Sustainable Purchasing Leadership Council. The SPLC seeks to improve the purchasing process through education and guides to assist buyers.

Requests to OSHA's Directorate of Enforcement Programs (DEP) for an official interpretation letter on Safety Data Sheets and the Article Exemption. Sought assistance of US Senator Gary Peters' Office to expedite a response. Met with staff to explain our position. Attended Small Business Meeting in Grand Rapids MI hosted by US Rep. Bill Huizenga.

Continued work on an update to the ANSI/BIFMA e3 Furniture Sustainability Standard with many stakeholders including representatives from EPA and GSA. Continued working with the Environmental Protection Agency on a Pilot of Draft Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement. Serving on the Furniture Panel and Guidance Committee for the Pilot. Worked with EPA and GSA on sustainable procurement issues and tools directly and through the Sustainable Purchasing Leadership Council. The SPLC seeks to improve the purchasing process through education and guides to assist buyers.

Began working with GSA to update the current Schedule 71 solicitation, specifically the product subgroups under the contract organized by SIN, the technical requirements, and the requirements for packaged office offerings. Joined Schedule 71 Structure/Scope Working Group.

Continued work on an update to the ANSI/BIFMA e3 Furniture Sustainability Standard with many stakeholders including representatives from EPA and GSA. Continued working with the Environmental Protection Agency on a Pilot of Draft Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement. Serving on the Furniture Panel and Guidance Committee for the Pilot. Worked with EPA and GSA on sustainable procurement issues and tools directly and through the Sustainable Purchasing Leadership Council. The SPLC seeks to improve the purchasing process through education and guides to assist buyers. Spoke with OHSA staff interested in current research around sustainability standards and what OSHAs role is/should be.

Sent OSHA's Directorate of Enforcement Programs (DEP) another request for an official interpretation on Safety Data Sheets and the Article Exemption. Agency staff says they have an Interpretation Letter for BIFMA that is under review.

Set up introductory meeting in the BIFMA conference room for area furniture manufacturer members to meet Michigan's newly elected U.S. Senator Gary Peters.

Continued working with the Environmental Protection Agency and representatives of several other agencies in a Pilot of EPAs proposed Draft Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement. Serving on the Furniture Panel and Guidance Committee for the Pilot. Continued work on the sixth update to the ANSI/BIFMA e3 Furniture Sustainability Standard with many stakeholders including representatives from EPA and GSA. Worked with agency representatives on NSF International committees for Commercial Furnishings Fabric (NSF 336) and Greener Chemicals and Processes (NSF 355). Communicated with EPA staff about the possibility of designing a calculator similar to the one they worked with the electronics industry on for EPEAT. Worked with EPA and GSA on sustainable procurement issues and tools directly and through the Sustainable Purchasing Leadership Council. The SPLC seeks to improve the purchasing process through education and guides to assist buyers. Tools explored with agencies this quarter include the Acquisition Gateway, the Sustainable Facilities Tool, and proposed icons for the GSA Advantage website. Followed up a Healthy Furniture Workshop on Stain-Repellants and Antimicrobials hosted by the Green Science Policy Institute by discussing the EPA's DfE/Safer Choice Program with that agency. Investigated the role of components, suppliers, and the definition of "articles" with OSHA to determine responsibilities for disclosure to manufacturers.

Asked OSHA's Directorate of Enforcement Programs (DEP) for an official interpretation on Safety Data Sheets and the Article Exemption. Communicated with the U.S. House Appropriations Committees Surveys and Investigations Division on a study for the Committee on the Federal Prison Industries, Inc. (FPI). Authority was provided to FPI in Fiscal Year 2012 to manufacture goods for the commercial market that are manufactured outside of the U.S.. Authority was also given to FPI to partner with commercial business to sell prison-made goods. I provided perspective on both of these authorities and the impact on the private sector.

Continued urging the U.S. Senate to reform Country of Origin Labeling (COOL) requirements that the World Trade Organization has found to be a violation of fair trade laws and address the threat of retaliation by Canada and Mexico. Furniture was on the list of targets for retaliation. The Senate acted, the President signed the budget bill that included the reform, and the crisis was averted.

Urged the Senate to reform Country of Origin Labeling (COOL) requirements that the World Trade Organization has found to be a violation of fair trade laws and address the threat of retaliation by Canada and Mexico. BIFMA supported H.R. 2393 to repeal the offending COOL requirements for beef, pork and chicken and urges the Senate to take a similar action. Furniture is on the list of targets for retaliation. Met with representative of U.S. Senator Gary Peters to ask for his support.

Provided information to an EPA contractor working on renewal of an NSPS for Metal Furniture Coating. Worked with the Environmental Protection Agency and representatives of several other agencies in a Pilot of EPAs proposed Draft Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement. Serving on the Furniture Panel and Guidance Committee for the Pilot.

Arranged conference calls with OSHA about the applicability of the the article exemption and when exposure must be determined or risk assessments performed for furniture products to determine if, under normal use conditions, there is exposure to a hazardous material.

Urged Congress to reform Country of Origin Labeling (COOL) requirements that the World Trade Organization has found to be a violation of fair trade laws and address the threat of retaliation by Canada and Mexico. BIFMA supported H.R. 2393 to repeal the offending COOL requirements for beef, pork and chicken and urged the Senate to take similar action.

EPA's Draft Guidelines for Environmental Performance Standards and Ecolabels - Participated in meeting with GSA official and webinar with EPA official. Urged implementation of the Guidelines and BIFMA's intent to put the ANSI/BIFMA e3 Furniture Sustainability Standard and the level Certification Program through the national pilot being planned by EPA.

Worked with the General Services Administration on how to best ask for environmental and sustainability criteria in specifications for furniture.

Communicated with EPA on Guidelines for Environmental/Sustainability Standards and Ecolabels, urged government-wide adoption. Worked with EPA officials on various committees and work groups of the Sustainable Purchasing Leadership Council.

Visited with CPSC commissioners and Members of Congress in support of California's new smolder standard for upholstered furniture to eliminate the need for hazardous flame retardant chemicals.

On April 25, 2014, BIFMA submitted comments of concern to GSA on their Request for Information (RFI) for a Potential Government-wide Furniture Strategic Sourcing Initiative (FSSI). Furniture manufacturers regularly provide a variety of complex and innovative configurations designed to enhance workplace performance. The office furniture industry fears that in the race to drive low cost procurement, the important, necessary consideration of overall best value to the government will be jeopardized. Comments were submitted via Email to: FSSI.Furniture@GSA.GOV. On June 16, 2014, I and several BIFMA members, provided Brennan Conaway and Dana Arnold of GSA with input on the agency's efforts to improve the environmental profile of GSA expenditures. An economic input/output life cycle assessment (IO-LCA) process would be an effective way to identify macro level impacts of primary production and manufacturing sectors. BIFMA urged careful consideration to the influence of data applicability, quality, and uncertainty when formulating conclusions.

Signed letter from the American Home Furnishings Alliance to EPA Assistant Administrator James Jones on April 24, 2014 asking for a 30 day extension of the comment period on the proposed Formaldehyde Emission Standards for Composite Wood Products. Met EPA Assistant Administrator James Jones at the Safer Consumer Products Summit in California in May 2014 and asked about status of a pilot program of EPA's proposed Guidelines for for Product Environmental Performance Standards and Ecolabels. BIFMA submitted comments on the proposed guidelines in April 2014.

Participated in meeting with California Air Resources Board (CARB) and EPA representatives on the treatment of laminated products under the Formaldehyde Emissions Standards for Composite Wood Products. BIFMA supported legislation signed by the President in 2010 creating a national formaldehyde rule mirroring the "CARB Rule" so that requirements would be uniform throughout the nation. BIFMA has worked through the Federal Wood Industries Coalition to voice any concerns on implementation of the rule and seeks the least disruptive path for fabricators to comply with the new program.

Supported the Environmental Protection Agency's Draft Guidelines for Product Environmental Performance Standards & Ecolabels for Voluntary Use in Federal Procurement in four meetings with EPA staff present and in comment drafting discussions with four other organizations. Was interviewed by GSA staff as part of market research they were doing to guage industy interest/opinions on LEEDv4. We are supportive of the USGBC's new rating system for buildings and building products. Contacted the US Army Corps of Engineers on behalf of an association test laboratory about new requirements the agency was instituting. Sought clarification and common sense.

Furniture Sustainability Standard - Promoted the ANSI/BIFMA e3 Furniture Sustainability Standard with a panel presentation and conversations at NeoCon East in Baltimore to federal agency representatives. Visited the GSA office in Baltimore to update them on the standard and invite them to designate a GSA stakeholder in our standard's development process. Environmental Protection Agency's Draft Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement - Urged EPA to release this long-awaited guidance that should help clarify which of the some 400 environmental standards and certifications or labels are the most impactful and worthy of federal government usage.

Hazardous Fire Retardants (FRs) in Products - Visited the CPSC and Congressional Offices to support elimination of these chemicals in all products. The risk to human health of exposing everyone to FRs is appearing to be a bigger risk than the fires that these chemicals were designed to fight.

Supported EPA Formaldehyde regulations for particle board products that would be identical to the California rule. Participated in an SBA Roundtable on July 18 and a CARB workshop on August 1 where EPA staff was present.

Contacted the General Services Administration to ascertain the status of efforts to recognize products certified to sustainability standards. Urged EPA representatives to issue guidance on sustainable purchasing that is needed by federal procurement personnel in order to know which standards and ecolabels are the best to use when making purchases. Helped launch the Sustainable Purchasing Leadership Council as a Strategic Partner during a July Webinar and August Summit in Washington DC. The SPLC is a diverse group of stakeholders working together to sort out the "green purchasing" picture for the private sector as well as government. Talked with representatives from EPA and GSA.

Held a Chemicals of Concern Summit at the end of April with experts from many areas including representatives from the EPA's Design for the Environment program. The purpose of the Summit was to secure the most state of the art and agreed upon approaches to addressing "chemicals of concern" within the industry.

BIFMA is watching a case of possible trade retaliation against the U.S. for requiring product "country of origin" labels. It involves the USDA but BIFMA has only reached out so far to Sen. Debbie Stabenow, chairperson of the Agriculture Committee to determine what can be done.

Attended ACCO Climate Leadership Conference in Washington, DC and participated in a meeting with the coordinator of GSA's Sustainable Supply Chain Community of Practice (CoP) and others about the group's status and goals. BIFMA has signed up as a "Champion" of the CoP and will be facilitating the collection and sharing of furniture industry best practices in the supply chain and sustainability initiatives such as the ANSI/BIFMA e3 Furniture Sustainability Standard and level Certification Program. Met with a new staff person in US Rep. Bill Huizenga's office to discuss Federal Prison Industries and legislative opportunities in the new Congress for reform of the program.

Met with new staff person from Rep. Bill Huizenga's office. Discussed BIFMA's position on elimination of flame retardants in products.

Contacted the GSA and EPA representatives on the Section 13 Inter-Agency Product Standards and Ecolabels Sub-Working Group report for for status of release of the group's report. Talked with the coordinator of GSA's Sustainable Supply Chain Community of Practice about opportunities for involvement of additional stakeholders and the timeframe for upcoming meetings.

Discussed BIFMA's position on elimination of flame retardants in products with staff of the Office of Senator Kirsten E. Gillibrand.

Contacted the General Services Administration for status of release of the Section 13 Inter-Agency Product Standards and Ecolabels Sub-Working Group report containing recommended guidelines for government agencies. Joined the GSA's Sustainable Supply Chain Community of Practice as a "Champion" and communicated with program director on expectations, opportunities for involvement of additional stakeholders, and timeframe for upcoming meetings.

Urged release of the Section 13 Inter-agency Product Standards and Ecolabels Sub-Working Group report containing a set of recommended guidelines for government agencies. Supported H.R. 3634, the "Federal Prison Industries Competition in Contracting Act of 2011" and similar legislation being drafted in the U.S. Senate.

Participated in a telephone survey conducted by an EPA contractor of the agency's Environmentally Preferred Purchasing policies. Urged release of the Section 13 Inter-agency Product Standards and Ecolabels Sub-Working Group report containing a set of recommended guidelines for government agencies. Discussed BIFMA's position on elimination of flame retardants in products with EPA Design for the Environment (DfE) staff at a Green Chemistry Conference. Encouraged EPA's Deputy Assistant Administrator, Office of Enforcement and Compliance Assurance, to bolster voluntary programs like DfE and Green Suppliers Network (GSN). Suggested that EPA work closely with White House Council on Environmental Quality to make sure these programs along with Energy Star and all others (USDA biopreferred, etc.) are not duplicative or out of proportion with other environmental impacts.

Participated in Jan. 20, 2012 session on the federal government's development of recommended guidelines to help federal acquisition staff decide on environmental standards and eco-labels for use in the federal procurement process. The Section 13 Inter-agency Product Standards and Eco-labels Sub-Working Group (includes EPA representatives) received input on how a draft set of recommended guidelines and possible implementation strategies should be released. BIFMA supported publication of the plan in the Federal Register. Participated in Feb. 3, 2012 briefing by Nancy Gillis, Director of GSAs Federal Supply Chain Emissions Program Management Office (PMO) regarding future contractor greenhouse gas (GHG) requirements including data systems for capturing vendor GHG emissions, the business case for GHG reporting, and future communication plans for government and industry. BIFMA offered to assist the agency in coming up with workable requirements. Participated in EPA Design for the Environment Phthalates Alternatives Committee (Feb. 15 & March 26) exploring alternatives that may be used as substitutes. BIFMA, and several of the association's members, are stakeholders on this committee. Participated in a March 27, 2012 listening session, hosted by the U.S. EPA's Office of Chemical Safety and Pollution Prevention, on Sustainability and the U.S. EPA, a report prepared by The National Research Council. BIFMA supports EPA collaboration with other agencies and the private sector to establish criteria for which standards and eco-labels should be recognized by the Federal Government. Attended a March 30, 2012 White House Council on Environmental Quality and Office of Public Engagement roundtable conversation entitled, Executing a Sustainable Supply Chain Community of Practice. BIFMA is one of several stakeholders from the federal, private, association and academic sectors assisting the federal government in defining what constitutes a sustainable supplier and sustainable supply chain. The ANSI/BIFMA e3 Furniture Sustainability Standard is one such tool for the assessment of products, facilities, and corporate policies.

Participated in several presentations by GSA representatives on the Section 13 Interagency Product Standards and Ecolabels Subgroup where BIFMA provided survey input and seeks recognition of the ANSI/BIFMA e3 Furniture Sustainability Standard and level Certification Program by government when furniture and furnishings are considered for purchase by agencies. Attended GSA Industry Day in Baltimore for furniture sector and provided GSA staff with suggestions for incorporation of level into the procurement process. Requested removal of "green icons" added to the GSA Advantage website in March of 2011 that provided an unfair competitive advantage for some vendors; the icons were added without the benefit of the Section 13 criteria under development and BIFMA supports use of that criteria for any icons used on the system or in other places such as GSA's Sustainable Furnishings (SF) Tool; The SF Tool developers were contacted with the same request. Informed US Rep. Justin Amash of our activities on these and other matters.

Worked with EPA stakeholders in continued development/maintenance of ANSI/BIFMA e3 Furniture Sustainability Standard. Worked with EPA participants on the Green Products Roundtable to develop a system for understanding and ranking standards and ecolabels. Provided input to Section 13 Interagency Product Standards and Ecolabels Subgroup co-chaired by EPA (Assessment Survey of the ANSI/BIFMA e3 Furniture Sustainability Standard and level Certification Program). Attended White House GreenGov Symposium. Participated in EPA's Design for the Environment (DfE) Committee studying alternatives to phthalates (several BIFMA members participating). Solicited comments on new Product Category Rules for seating from over 1,000 parties including EPA representatives. Met with Representative Justin Amash to brief him on our activities in these and other issues.

1) Urged the General Services Administration to remove an eco-label from the "GSA Advantage" website that was added in March of 2011 and to utilize criteria for recognition of standards and eco-labels being developed by an interagency work group; 2) completed a survey for the GSA-Section 13 Working Group; and 3) discussed ways for GSA to determine a company's efforts to address Green House Gas contributions from products or operations.

Provided additional background to GSA on the ANSI-BIFMA e3 Furniture Sustainability Standard and level Certification Program in response to their interest in using it to meet the goals of EO 13514, the Federal Leadership in Environmental, Energy, and Economic Performance Executive Order. Commented to GSA on the modernization of green symbols posted on the GSA Advantage website. Encouraged the inclusion of level and ANSI standards for products wherever possible. Presented to the Quality Partnership Council and spoke to GSA Administrator Martha Johnson at GSA Expo in May.

Signed on to a statement for the record by the Government Withholding Relief Coalition that was submitted to the House Small Business Committee on May 25, 2011 urging repeal of Section 511 in the Tax Increase Prevention and Reconciliation Act of 2005.

Worked with various EPA staff to help bring greater clarity to the green product marketplace through development of sustainability standards for furniture and other products as well as collaborative efforts with groups such as the Green Products Roundtable. Shared our progress with the offices of Senators Carl Levin and Debbie Stabenow in March 2011.

Discussed fire retardants (FRs) in products with a representative of the CPSC. BIFMA has supported the EPA's Design for the Environment effort to find alternatives to chemicals of concern used as FRs. Also attended a Federal Interagency Committee on Indoor Air Quality meeting with a presentation by Dr. Arlene Blum of the Green Science Policy Institute entitled "On The Toxicity Of Flame Retardants in the Building Environment: What to do About It".

Coordinated meeting with EPA on implementation of legislation to make California's formaldehyde rule (the "CARB Rule") for composite wood products nationwide. Industry representatives met with agency staff for update. Worked with various EPA staff to help clarify what "green products" are; establish ASTM standards; and establish programs for the development of Product Category Rules in the United States.

Signed a Government Withholding Relief Coalition letter to Members of Congress urging a two-year delay of the 3% tax witholding law enacted as part of the Tax Increase Prevention and Reconciliation Act of 2005.

Urged EPA, GSA, NIST, DOE and White House Council on Environmental Quality staff to utilize the BIFMA e3 Furniture Sustainability Standard as a tool to assist U.S. government agencies in meeting the goals of Executive Order 13514, the "Federal Leadership in Environmental, Energy, and Economic Performance" EO.

Sought meeting with EPA on implementation of legislation to make California's formaldehyde rule (the "CARB Rule") for composite wood products nationwide. Offered industry represenatives as stakeholders in the rulemaking process. Recommended that EPA's Sustainable Product Initiative managed by the National Center for Manufacturing Sciences consider serving as a comparative analysis center that would review sustainability standards, green product certifications, and eco-logos.

Urged GSA, EPA, OFEE and Dept. of Commerce's Sustainable Manufacturing Initiative staff to utilize BIFMA's Furniture Sustainability Standard as a tool to assist U.S. government agencies in meeting the goals of Executive Order 13514, the "Federal Leadership in Environmental, Energy, and Economic Performance" EO.

Helped craft and co-signed a letter with other members of the Green Products Roundtable (GPR) to the Federal Trade Commission on the update to their Green Guides. Encouraging clarity of "green" claims and "sustainability" as necessary to reduce "greenwash" in the marketplace.

Urged EPA and GSA to utilize BIFMA's Furniture Sustainability Standard as a tool to assist U.S. government agencies in meeting the goals of Executive Order 13514, the "Federal Leadership in Environmental, Energy, and Economic Performance" EO.

Helped EPA update compiled data on the wood furniture industry based on information from the National Emissions Inventory (NEI) database for 2005.

Signed the Government Withholding Relief Coalition letters to Rep. Robert Andrews, Rep. Mike Conaway, other Members of the Defense Acquisition Reform Panel, and all Members of Congress expressing opposition to 3% withholding.

Spoke with EPA, OFEE, and GSA about Executive Order 13514, "Federal Leadership in Environmental, Energy, and Economic Performance" and how BIFMA's Sustainability Standard could help. Submitted comments to GSA's Emile Monette on role of vendors in the new Executive Order. Worked with OFEE to update BIFMA's information on the FedCenter website.

Supported S. 1660, legislation to make California's formaldehyde rule (the "CARB Rule") for composite wood products nationwide. Opposed implementation of USDA Biomass Program which threatens the US wood fiber supply for makers of composite panels and other products until existing industries are exempt. Briefed US Army Installation Management Command and 30 agencies in an OFEE SAMM meeting on BIFMA's Furniture Sustainability Standard.

Briefed GSA officials on status the level Certification Program for sustainable furniture, promoting it as a tool for government purchasing officials to evaluate products that have achieved progressively higher levels of environmental and sustainability achievements as certified by independent third party organizations.

Briefed EPA and the Office of Federal Environmental Executive on status the level Certification Program for sustainable furniture. Met with staff of Rep. Doris Matsui and spoke with Rep. Fred Upton about legislation to make California's formaldehyde rule (the "CARB Rule") for composite wood products nationwide. A bill to do that was introduced in the US Senate later that month (S. 1660) and BIFMA signed a letter of support to US Senators.

Addressed the Coalition for Government Procurement's Green Committee on the BIFMA e3 Furniture Sustainability Standard and level certification program for product conformance with the standard. Spoke to the Public Building Service representatives in attendance about the standard and possibility of presenting to PBS staff. Presented a briefing on the e3 standard to the GSA's Quality Partnership Council at their Expo in San Antonio.

Continued work with various EPA personnel in meetings on the proliferation of confusing eco-labels; on an ANSI Workshop steering committee; and briefed EPA's Sustainable Products Network on a new certification program for product conformance with the BIFMA standard. Met with Paul Troost of Senator Levin's Office and briefed him on the sustainability standard.

Two meetings with the General Services Administration on the BIFMA e3 Furniture Sustainability Standard and level certification program for product conformance with the standard.

Worked with various EPA personnel in meetings exploring green marketing claims and the proliferation of confusing eco-labels; on an ANSI Workshop steering committee; in a conference call on the BIFMA e3 Furniture Sustainability Standard for an agency case study; and on an ANSI sustainability standard for textiles stakeholder group. Briefed EPA on a new certification program for product conformance with the BIFMA standard. Also briefed U.S. Sen. Debbie Stabenow on our efforts and interest in Sen. Feinstein's draft legislation to create a national eco-logo program that would bring clarity for consumers.

Worked with various EPA personnel on ASTM sustainability comittees, anANSI sustainability standard for textiles, the agency's Green Supplier Network, a case study of the BIFMA e3 Furniture Sustainability Standard, and the proliferation of confusing eco-labels and marks.

Communication with the General Services Administration about requirements for federal contractors and subcontractors scheduled to begin using the E-Verify system in 2009 where employers verify their employees' eligibility to legally work in the United States. Tried to determine office furniture manufacturer responsibility, if any, under the law.

Federal Prison Industries (FPI) Reform - Contact with Rep. Pete Hoekstra's office in July. Congratulated GSA's Quality Partnership Council (QPC) coordinator Jennifer Auble on her new position after seven years of working with the QPC.

Continued work on development of an ANSI sustainability standard for business and institutional furniture. Maintained contact with EPA stakeholders to: address comments on the standard; determine how feasible it would be to use Green Supplier Network to support suppliers with a path forward toward the sustainability standard; discuss the ASTM effort to come up with a generic EPP standard for building products; and continue work with an EPA intern on a case study of how this standard was developed.

Federal Prison Industries (FPI) Reform

Continued work on development of an ANSI sustainability standard for business and institutional furniture. Several people from the Environmental Protection Agency are participating along with a representative of the General Services Administration's National Furniture Center as stakeholders. In this quarter, the furniture standard went to a final ballot by the stakeholder Joint Committee and was released for public comment. I also serve as a Joint Committee member for a sustainable textiles standard under development with NSF International. EPA is participating with that group also and we met in May.

Continued work on development of an ANSI Sustainability Assessment Standard (SAS) for business and institutional furniture. Several people from the Environmental Protection Agency are participating along with a representative of the General Services Administration's National Furniture Center as stakeholders. In this quarter, we commented on the Office of Management and Budget policy letter outling agency responsibilities for acquiring environmentally friendly products and suggested the SAS as a tool.

Senator Debbie Stabenow invited BIFMA members to a business roundtable with the U.S. Department of Commerce Undersecretary for International Trade, Mr. Christopher A. Padilla, on February 20, 2008. We notified all area members of the opportunity.

Federal Prison Industries Reform

* Worked with the High Performance Building Council's Sustainability Committee to provide a report for NIST on the status of sustainability related standards. Participated in a November 6, 2007 forum on the Future of Sustainable Products convened by Alison Kinn Bennett, Co-Chair EPA Green Building Workgroup of US EPA's Office of Pollution Prevention and Toxics - Pollution Prevention Division Worked with the High Performance Building Council's Sustainability Committee to provide a report for NIST on the status of sustainability related standards. Participated in a November 6, 2007 forum on the Future of Sustainable Products convened by Alison Kinn Bennett, Co-Chair EPA Green Building Workgroup of US EPA's Office of Pollution Prevention and Toxics - Pollution Prevention Division

Made association members aware of the need for employer comments on improvements to the 1993 Family and Medical Leave Act (FMLA). Didn't contact agency directly, only informed companies of the opportunity.

1) Became a national partner of the U.S. Fire Administration's Smoking & Home Fires Campaign. 2) Signed on to a letter the NAM Coalition on CPSC sent to the House Subcommittee on Financial Services encouraging approval of sufficient funding for the Consumer Product Safety Commission.

Submitted comments on a petition to DOT to regulate flexible polyurethane foam (FPF) and certain products made with FPF as a Class 9 hazardous material.