BALLOT RESULTS: Draft Final V2 Revised Green Seal Standard for Sanitary Paper Products GS-1

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1 August 16, 2010 BALLOT RESULTS: Draft Final V2 Revised Green Seal Standard for Sanitary Paper Products GS-1 Green Seal is in the final stages of developing the Green Seal Standard for Sanitary Paper Products, GS-1 (a revision of the current GS-1 and GS-9). Registered stakeholders were invited to review the Draft Final V2 Revised Standard and re-submit a ballot. The second round of balloting resulted in a 38% affirmative vote. Included are the comments and responses for your review. There were several comments from stakeholders that warranted substantive modifications to the standard. These changes are included following a response, if applicable. After you review this information, as well as the Draft Final Version 3 Revised Standard, you are being provided the opportunity to amend your original ballot or to submit a ballot if you have not already done so. Any amended ballot must be th received by 8 PM Eastern on August 30, If you do not submit an amended ballot, your original ballot will be recorded as final.

2 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 2 Response to Comments: Below are the comments on the Draft Final V2 Revised Standard from all ballots (affirmative, negative, or abstain), with identifying comments removed, and Green Seal s response/efforts for resolution in red. Draft final version 3 revised standard language is given in italics in red. GENERAL COMMENTS: Great job and it is a huge improvement! I am sorry that I had not provided much input during the process. I think it is great and I support it 100%. I do however feel that the concept of sourcing fiber content is valid for future consideration. This may be more pertinent for writing/copy paper however in many overseas paper manufacturing plants using post consumer materials travel a long long way to reach the manufacturing plant. May be worth exploring in future versions or standards. Your comments are acknowledged. 2.0 DEFINITIONS 2.7 Chemical Agents. Chemical Agent is too general, i.e. not specific enough to the pulp and paper industry. Proposed change: Deinking and paper-making chemicals. Chemicals added in the deinking/papermaking process including, but not limited to, surfactants, defoamers, dispersants, foaming agents, and collectors. It is noted that the term Chemical Agent could be considered to cover too broad of a category. A review of available information shows that Papermaking Additive as defined in Handbook of Pulp & Paper Terminology, 2 nd Edition, Smook, 2001 best represents this category of chemicals. Therefore the standard will be changed as follows: Papermaking Additives. Materials intentionally added to paper or to the papermaking furnish to modify or improve certain paper properties or to facilitate the papermaking process. This definition encompasses all materials that enter the system except fiber and water, including, but not limited to: surfactants, detergents, defoamers, dispersants, foaming agents, collectors, wet strength resins, and biocides.

3 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS Component i) Additive is the common term of our industry and residual is the appropriate terminology instead of contaminant (2nd sentence). ii) Naturally occurring elements are not tested for. No one will know the residual level. iii) Chlorinated organics which may be present as a result of chlorination of the water are already addressed in another section. Proposed change: Additive. A deliberate addition to the product, added for its continued presence in the final product to provide a specific characteristic, appearance, or quality. Naturally occurring and chlorinated organics, which may be present as a result of chlorination of the water supply, are not considered additives being intentionally added if the concentrations are below the applicable maximum residual levels in the National Primary Drinking Water Standards found in 40 Code of Federal Regulations (CFR) Part 141. or Additive. A deliberate addition to the product, added for its continued presence in the final product to provide a specific characteristic, appearance, or quality. It is understood that additive is the term used to describe non-fibrous chemicals and minerals used in the papermaking industry. Green Seal will use the term Papermaking Additives to describe additions to the process beyond fiber and water and the term component will be removed from the standard. However, contaminant will be added to the standard as a separate definition, since any contaminants present above the ingredient level of 0.01% are prohibited. The term contaminant will remain in the standard as it is more representative of something that is unintentionally added, compared to residual, which implies something left over. The clarification for naturally occurring elements and chlorinated organics has been removed with the removal of the component definition. Papermaking Additives. Materials intentionally added to paper or to the papermaking furnish to modify or improve certain paper properties or to facilitate the papermaking process. This definition encompasses all materials that enter the system except fiber and water, including, but not limited to: surfactants, detergents, defoamers, dispersants, foaming agents, collectors, wet strength resins, colorants, and biocides.

4 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 4 Contaminant. A substance that was not intentionally added, but is known to be present above 0.01% (100 parts per million) by weight in papermaking additives as purchased. This change will also be reflected in the additional prohibited substances, as follows: Additional Prohibited Substances. The papermaking process shall not contain the following substances as papermaking additives or contaminants: Chlorophenolic Biocides Fragrances Heavy metals, including but not limited to lead, chromium, or selenium both in the elemental form or compounds Ozone-depleting compounds In the same definition of chemical agents, what is the definition of a collector? A collector is a specific reference to a surfactant used in flotation deinking, as defined in the Handbook of Pulp & Paper Terminology (2 nd Edition, Smook, 2001): Chemical agent (surfactant) used in flotation deinking to agglomerate small particles onto larger particles and change the surface of the particles from hydrophilic to hydrophobic, Handbook of Pulp & Paper Terminology, 2 nd Edition, Smook, Recovered Material The recovered fiber definition should not exclude fibers containing any percentage of virgin materials recovered outside the facility, as packaging materials and broke in a converting facility could not be recovered and would become waste. Your comment is noted. The definition for what is not included in recovered material refers only to recovered fibers or mill broke from outside the facility. Converting (finishing) broke and packaging materials from outside the facility are covered in the first two bullets of the definition. However, for clarification the definition and terminology will be modified to better represent industry terms. Recovered Material. Either material recovered from or otherwise diverted from the solid waste stream, that is generated after the completion of the paper manufacturing process; or fiber and broke recovery that contains 100%

5 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 5 recovered material and is integral to the manufacturing process from which it was generated. Recovered material may include: Finishing waste generated after completion of the papermaking process (i.e., during converting), such as envelope cuttings; bindery trimmings; printing waste; cuttings and other converting waste (finishing broke); butt rolls and mill wrappers; obsolete inventories; and rejected unused stock. Post-consumer materials such as paper, paperboard, and fibrous materials from retail stores, office buildings, homes, etc., after they have completed their intended end-use. Fibers recovered from whitewater or wastewater, or mill broke (wet or dry) generated from the manufacturing process used only to make the certified product (i.e., mill broke containing 100% recovered material). Fibrous materials such as agricultural residues from non-timber species or fibrous by-products from the timber industry. Recovered material does not include: Fibers recovered from whitewater or wastewater, or mill broke (wet or dry) generated from the manufacturing process used to make non-certified products containing virgin material (i.e., mill broke containing any virgin material), regardless of whether such materials are used by the same or another company. Finishing Broke. Discarded paper resulting from any finishing (converting) operation, including, but not limited to winding, slitting, cutting, sorting, counting, cartoning, palletizing, and wrapping. Mill Broke. Paper discarded from any point in the manufacturing process, which is subsequently re-pulped and reprocessed. Wet broke is typically generated from the wire or presses, while dry broke emanates from the dryers, reel, and winder. We disagree with the concept that For non-timber species, recovered material is considered agriculture waste. This provides an unleveled playing field for other such materials such as sawdust. Sawdust is a waste product from the lumber (sawmill) business and is excluded from being considered a recovered material for determining recycled content. Why is fiber waste from agriculture OK but fiber waste from a lumber business isn t OK. That is contradictory in our opinion. In either case the waste can either be collected for use in another process (i.e. paper making) or it can be burned or land filled. Same scenario, same alternative disposals, but different classification allowances for determining recycled content. We consider that to be unacceptable. In our minds, recycled fiber is fiber that has been used to make a product once, collected or separated from the solid waste stream, and reused to make another product. Have I misunderstood this section? Are agriculture wastes included or excluded as a recycled fiber source? It is unclear. If they are excluded, then make a second bullet under section that discusses what is not included and simply say that agriculture waste from non-tree species is

6 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 6 not included. Green Seal acknowledges your comment. However, per the comments in the last response to comments, sawdust or other materials are not prohibited. The intent of the standard is to be inclusive of alternative paper-making technologies that use waste materials. The reference to waste materials will be moved within the definition and fibrous by-products from the timber industry will be added for clarification. Recovered Material. Either material recovered from or otherwise diverted from the solid waste stream, that is generated after the completion of the paper manufacturing process; or fiber and broke recovery that contains 100% recovered material and is integral to the manufacturing process from which it was generated. Recovered material may include: Finishing waste generated after completion of the papermaking process (i.e., during converting), such as envelope cuttings; bindery trimmings; printing waste; cuttings and other converting waste (finishing broke); butt rolls and mill wrappers; obsolete inventories; and rejected unused stock. Post-consumer materials such as paper, paperboard, and fibrous materials from retail stores, office buildings, homes, etc., after they have completed their intended end-use. Fibers recovered from whitewater or wastewater, or mill broke (wet or dry) generated from the manufacturing process used only to make the certified product (i.e., mill broke containing 100% recovered material). Fibrous materials such as agricultural residues from non-timber species or forest residues. Recovered material does not include: Fibers recovered from whitewater or wastewater, or mill broke (wet or dry) generated from the manufacturing process used to make non-certified products containing virgin material (i.e., mill broke containing any virgin material), regardless of whether such materials are used by the same or another company. Forest Residue. Fibrous by-products of harvesting, manufacturing, extractive or woodcutting processes such as, but not limited to, chips, stumps, branches and sawdust, which would otherwise be incinerated or disposed of in situ or in a landfill Solid Waste We are not sure why you exclude sanitary waste (e.g., restrooms, etc.) from the term solid

7 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 7 waste. Paper towel waste from restrooms is solid waste and could potentially be used for recycling and/or composting. Sanitary waste from restrooms was separated out from solid waste since this section covers the paper manufacturing process. Please note that materials that are recycled or composted are also excluded from the definition of a solid waste since they will be beneficially reused. Therefore, the definition will not be modified Source Reduction The definition of source reduction is still too vague and should not be considered case by case. The definition / requirements should be clarified in the standard. My primary reasons are that the source reduction loophole gives manufacturers an opportunity to have 15% less PCW content and still be certified. I feel this invites unwanted subjectivity and violates the spirit of the standard. It is noted that the criterion for source reduction is not specifically defined in the standard. However, it was Green Seal s opinion that the concept of source reduction should be more fully incorporated into a standard that focuses on sustainability. Given that the criterion is still subjective, it will be removed from the standard and replaced with a placeholder for future consideration Take-Back Program 4.3 Source Reduction. Reserved. Does a Take-back Program have to be a company program? We would think not. You could simply drop the word Company. The Take-back Program option was added to the standard to allow for an alternative packaging end-of-life management option for packaging that is not easily recyclable in the current marketplace. The goal of a take back program is that a company takes the initiative to develop the program as a responsible producer, however the program may rely on external parties for execution. The definition will be modified for clarity. Take-Back Program. A program sponsored by the original product manufacturer that has been demonstrated to receive at least 50% of sold containers for recycling, composting, or reuse.

8 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS PRODUCT-SPECIFIC PERFORMANCE REQUIREMENTS In the spirit of time to return comments on the ballot, we have not reviewed all the products and specs in Section 3, but there have been numerous inputs previously to cover the wide range of products available on the market. It is still our position that putting all these individual products, and their specifications, in the standard will only result in the standard needing to be updated as products in the marketplace change. Your comments are acknowledged. It is Green Seal s opinion that Section 3, Product-Specific Performance Requirements, strengthens the standard, even if it brings with it additional maintenance of the standard. In addition, section 3.2 allows for submittal of alternative product performance data for additional products or categories not currently in the standard. Therefore, this section will remain in the standard. 3.3 Product Specifications One of current products does not meet the minimum product per package of 112 sqft/pack, based on private label customer driving majority of volume in that put-up. Changing the specification will increase the cost of product. Green Seal acknowledges your comment. The institutional folded towel category was re-evaluated compared to additional marketplace data and the minimum product per package was adjusted accordingly. Product Single Ply Specification Multi Ply Specification Minimum product per roll/package Conversion Basis Minimum product per roll/package Conversion Basis INSTITUTIONAL PRODUCTS Bathroom Tissue 84 ft 2 /roll ⅞ x 3 ⅞ 42 ft 2 /roll ⅞ x 3 ⅞ Facial Tissue Flat Box ft 2 /box x 8 Facial Tissue Cube/ Dispenser Boxes ft 2 /box 85 8 x 8 Paper Towels Hard wound or Center Pull 133 ft 2 /roll inch wide roll 67 ft 2 /roll inch wide roll

9 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 9 Paper Towels Folded 84 ft 2 /package x 9 42 ft 2 /package 75 9 x 9 Paper Towels Kitchen Rolls Paper Towels General Purpose Wipes Paper Napkins Folded (used with or without a dispenser) RETAIL PRODUCTS 110 ft 2 /roll x ft 2 /box x ft 2 /package x ft 2 /roll x 9 62 ft 2 /box x ft 2 /package x 17 Bathroom Tissue 62 ft 2 /roll ⅞ x 3 ⅞ 31 ft 2 /roll ⅞ x 3 ⅞ Facial Tissue Flat Box ft 2 /box x 8 Facial Tissue Cube/ Dispenser Boxes Paper Towels Folded 35 ft 2 /roll x 9.25 Paper Towels Kitchen Rolls ft 2 /box 85 8 x ft 2 /roll x 9 Paper Napkins Beverage 62 ft 2 /package x 9.5 Paper Napkins Luncheon 91 ft 2 /package x 12 Paper Napkins Dinner/Guest Towel MISCELLANEOUS PRODUCTS Toilet Seat Covers 88 ft 2 /package x per package 17.5 ft 2 /roll x ft 2 /roll x 9 31 ft 2 /package x ft 2 /package x ft 2 /package x Placemats, tray liners, and Other Table Coverings (a) For example, bathroom tissue: number of per roll = square feet per roll divided by sheet size (in 2 ) multiplied by 144 (in 2 /ft 2 )). - - = no requirement 4.1 Recovered Material Requirements. Again we would argue that there is an unfair and unleveled playing field when considering agriculture waste fiber as a source of recovered and then recycled fiber. We use large quantities of sawdust which we can t call recycled fiber so why should waste hemp or flax be able to claim recycled content when we can t? I can verify that before the paper industry started using the sawdust, it was burned in wigwam burners just to get rid of it. Have I misunderstood this section? Are agriculture wastes included or excluded as a recycled source? If they are excluded, then the paragraph addressing agriculture waste in this section should be deleted entirely. It is agreed that waste materials should be considered similarly in the standard. Therefore, the definition was further clarified (see the comments under the definition for

10 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 10 recovered material) and a definition was added for forest residue. It should be noted that forest residues are not prohibited, but the current wood products marketplace has found other beneficial uses for these waste materials. However, if a company were to manufacturer a product containing such materials, it would be considered for certification. Forest Residue. Fibrous by-products of harvesting, manufacturing, extractive or woodcutting processes such as, but not limited to, chips, stumps, branches and sawdust, which would otherwise be incinerated or disposed of in situ or in a landfill. 4.2 Post-Consumer Material Requirements. The post-consumer calculations should not allow a default yield. This allows manufacturers to assume a yield on post consumer fibers which likely gives more credit for PC content than actual. Your comment is acknowledged. It is known that the way some facilities operate does not always allow for accurate yield determinations for the different inputs to the papermaking furnish. The default yield information is in the current GS-1 and GS-9 standards, and the 75% yield factor is considered to be representative of sanitary paper product manufacturing. Therefore, the default yield will remain in the standard. Due to the already short supply of post-consumer wastepaper, and the need to transport it further and further to get the quantity we need to support our businesses, we are still opposed to the increases in post-consumer content requirements as they will increase the negative environmental impacts due to transportation costs, non-renewable fuel use, and CO2 emissions. We do not see any environmental advantages to these increases and in fact see negative impacts from additional transportation needs and the increased chemical usage that is required for some of the very low grades of post-consumer wastepaper in order to manufacture products meeting the customer requirements and demands. Green Seal acknowledges these comments. Please note that Green Seal lowered the post-consumer requirements significantly from the Proposed Revised Standard to the Draft Final Revised Standard, based on similar concerns. The main reasons for increasing the post-consumer levels are that since the last edition progress has been made in the industry to provide products at these higher levels. As a result, the changes reflect progress and also continue to encourage more progress in the industry. Therefore, the levels established in the Draft Final Revised Standard will remain the same.

11 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 11 A question regarding the alternative reduction paragraph We have products, when used with our controlled dispensers, that generate a 20 to 30 percentage reduction in use at the customer site thus 20 to 30 percent reduction in waste at their site. This is based on consumer research conducted during actual use trials. Does that qualify for the 15% reduction credit in the standard? It is noted that this scenario, if well documented, is something that could be considered in the source reduction category. However, given that this section of the standard is considered to be subjective, it is being replaced with a placeholder for future consideration. Any data or supporting reports that can be provided by industry would be useful to review to aid in development of this criterion in the future Water Disinfection. Unknown whether this will be a problem in two of three facilities. i) The term input target should be removed. a. 4 ppm of residual is tolerated in drinking water which implicitly means that input chlorine concentration is higher than 4 ppm. b. The input target concentration should not be limited as long as the residual level at the head box is below the applicable maximum residual disinfectant levels (MRDLs) in the National Primary Drinking Water Regulations found in 40 CFR, Part 141. However, the dosage shall not exceed the amount reasonably required to accomplish the intended technical effect. c. In 1999, NCASI showed that even at very high dosages of sodium hypochlorite, it is unlikely that dioxins and furans will be generated in water at our operating ph levels (7.5 and higher). ii) The biocides must not only be registered with the EPA. For Canadian mills, the biocides must be registered with the PMRA (Pest Management Regulatory Agency). iii) We believe the end of the first sentence "to prevent bio-fouling" is not necessary. Proposed Change: "Water Disinfection. Chlorine derivatives and biocides may be used to disinfect the incoming fresh water supply and recycled process water. Product testing is not required, as long as the concentration of the chlorine derivatives and biocides used for disinfection is below the applicable maximum residual disinfectant levels (MRDLs)

12 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 12 in the National Primary Drinking Water Regulations found in 40 CFR, Part 141 at the head box. However, the dosage shall not exceed the amount reasonably required to accomplish the intended technical effect. Biocides must be registered with the EPA or PMRA." It is noted that the wording is unclear in the water disinfection criteria. It is understood that the input of the disinfectant would be higher than the allowable residual. It is also understood that water may be added to the papermaking process at more locations than just the head box, so the location description will be broadened. The comments regarding biocide registration and the text of the first sentence are also acknowledged and will be modified accordingly. Therefore, the criterion will be reworded as follows: Water Disinfection. Chlorine derivatives and biocides may be used to disinfect the incoming fresh water supply and recycled process water. Product testing is not required, as long as the concentration of the chlorine derivatives and biocides used for disinfection is below the applicable maximum residual disinfectant levels (MRDLs) in the National Primary Drinking Water Regulations found in 40 CFR, Part 141 at any location where water is added to the papermaking process. Biocides must be registered with the EPA or the Pest Management Regulatory Agency (PMRA) Carcinogens, Mutagens, and Reproductive Toxins This section should be clarified to avoid misinterpretation. Proposed change: Carcinogens, Mutagens, and Reproductive Toxins. The product shall not contain any carcinogens, mutagens or reproductive toxins being intentionally added. Additionally, the product shall not contain any ingredients or additives known to produce or release carcinogens, mutagens, or reproductive toxins. An exception shall be made for titanium dioxide and carbon black used in colorants. An exception shall also be made for carcinogens, mutagens or reproductive toxins coming from recovered materials. However, their concentration should be at a level that is not toxic to human health. All responders agreed that we can not comply with this one as written. Some chemicals may contain trace amounts which are not intentionally added by the manufacturers. Suggest that finished products meet Prop 65 thresholds.

13 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 13 Green Seal acknowledges these comments. The terminology in the standard is being modified to better represent the papermaking industry, since papermaking additives are not always intended to remain with the product. In addition, it will be clarified that known contaminants are prohibited if they exceed 100 ppm in the papermaking additives as purchased from the raw material suppliers. If a contaminant exceeds this level, manufacturers will be required to find a substitute with a lower contaminant level, or a contaminant-free version. These changes affect this section of the standard as follows: Carcinogens, Mutagens, and Reproductive Toxins. The papermaking process shall not contain any papermaking additives or contaminants that are carcinogens, mutagens or reproductive toxins or that are known to produce or release carcinogens, mutagens, or reproductive toxins. An exception shall be made for titanium dioxide and carbon black used in colorants. Contaminant. A substance that was not intentionally added, but is known to be present above 0.01% (100 parts per million) by weight in papermaking additives as purchased. Papermaking Additives. Materials intentionally added to paper or to the papermaking furnish to modify or improve certain paper properties or to facilitate the papermaking process. This definition encompasses all materials that enter the system except fiber and water, including, but not limited to: surfactants, detergents, defoamers, dispersants, foaming agents, collectors, wet strength resins, and biocides. Papermaking Process. The process of using fiber, water and additives to make paper, including, but not limited to re-pulping, cleaning, screening, deinking, washing, bleaching, and papermaking. The only exception for carcinogen content should be due to wastepaper inputs as with other ingredients. The exception for colorants should be removed. Your comment is acknowledged. However, since this standard covers a broad range of products, several categories, such as napkins and placemats contain printing. The exception allows for the use of white and black pigments that are only considered carcinogens as fine particulates, which is not the form of the printed material. Therefore, the text will not be changed Optical Brighteners.

14 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 14 Although we can comply with the standard for optical brighteners if necessary there are certain conditions that might affect us by using optical brighteners at the proposed levels. I have checked with Operations to see if there is a level that they feel might work better that was still low enough to allow us to maintain as a reasonable standard for Green Seal and still keep a market acceptable level of brightness in our paper. There is no specified level of brightness in the proposal. Although we do not use optical brighteners on a daily basis, on occasion there are times when the incoming furnish causes the brightness levels to drop. In this instance and only in this instance is optical brightener used to increase the brightness to an acceptable, uniform level to reduce variability in our end product. I noticed that although there is a higher level of brightness from certain grades of recovered paper that would be acceptable, the availability is limited based on current market conditions, and pricing is at time prohibitive for our market. There is no current brightness level in the standard so therefore each company s standard for brightness will vary which will allow for a variance in terms of the amount of optical brightener used. For this reason, we ask that the standard identify optical brighteners in the following way, if possible: Optical brighteners shall be used as an ingredient (or leveling agent for product uniformity) if and only if the criteria above cannot be met so that; a) Optical brighteners can be used at a rate not to exceed.04% a year to increase brightness on paper if the incoming recovered paper causes brightness levels to drop. i) An intentional addition should be allowed to control the drastic brightness changes of the incoming raw material, i.e. to stabilize the optical properties of paper products. ii) A lowered allowed concentration could be part of a revision in Proposed change: Optical Brighteners. Optical Brighteners may be used as additives with a limit concentration of 100 ppm of active ingredient added in the process. An exception shall be made for optical brighteners coming from recovered materials. We do manufacture products in some of our mills that require optical brighteners based on customer requirements. These are mainly food contact acceptable optical brighteners used according to the FDA limits. Some of that optical brightener can and does get into the white water and could contaminate other products not intended to have optical brighteners. We have no reason to believe that the resulting concentration would be any higher than the carryover from office paper and would be below the 100 ppm in the standard, but it came from our intentional addition to other products rather than just from the wastepaper. If you want the optical brightener specification in the standard, we believe the standard should simply say that optical brighteners should not be added to a Green Seal certified product and that contamination from other processes and/or raw materials should not exceed the 100ppm level.

15 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 15 These comments are noted. Typically optical brighteners are prohibited in Green Seal standards such as cleaning products and soaps. However, it is recognized that the perception still remains in the marketplace that most Sanitary Paper Products should be white. It is understood that necessary changes to bleaching processes to remove precursors to dioxin and furan formation have resulted in a less uniform product, and one that may not appear white, which requires the use of optical brighteners. The main environmental issues with optical brighteners are associated with biodegradability and ecotoxicity. Since optical brighteners used in papermaking are designed to remain with the product, they are more likely to end up in solid waste than wastewater. Therefore, after additional research, it was determined that an acceptable use level of 200 parts per million will ensure that wastewater discharges are well below this level, and will be protective of the environment. The standard was modified as follows: Optical Brighteners. Optical brighteners may be used as a papermaking additive at a dosage not to exceed 200 parts per million (0.02%) by weight as added to the papermaking process. This level does not include any optical brighteners that may be present in the furnish through the use of recovered materials Colorants That section should be clarified to avoid misinterpretation. The terminology of the second paragraph should be inspired from the CONEG legislation. Proposed change: Colorants. The product shall not contain any intentionally added colorant as additives or ingredients. An exception shall be made to colorants coming from recovered materials. Further, paper towels and general-purpose wipes, paper napkins, and placemats and other table coverings may be printed with colorants provided that these colorants contain a combined total concentration of lead, mercury, cadmium, and hexavalent chromium lower than 100 parts per million, by weight (0.01%)." Your comment is noted. The way that Green Seal standards are written is that a term is used in the criteria, and the term is defined in the definitions section, to avoid any misinterpretation. The section will be modified to include reference to papermaking additives, since this term better represents the industry.

16 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 16 Regarding the second sentence, it is the intent of the section to harmonize with CONEG, by limiting these heavy metals to less than 100 ppm. Therefore the text will not be changed Biodegradability Colorants. The product shall not contain any colorants as papermaking additives; an exception shall be made for products that would not contain colorants but for the addition of recovered materials. Further, paper towels and general-purpose wipes, paper napkins, and placemats and other table coverings may be printed with colorants provided that these colorants contain a sum concentration of less than 100 parts per million, by weight (0.01%), of heavy metals including lead, mercury, cadmium, and hexavalent chromium. Not all chemical agents should require biodegradability testing. It is not common for chemical vendors to have the information available, so manufacturers would have to test every raw material using in their processes to meet this standard. The modeling exception should not be allowed if all agents require confirmation of biodegradability. If it is required, it should be verified through test data. An investigation should be made in the industry to know the portion of qualified chemicals to the biodegradability criteria. The approval of this section should be postponed. Unknown whether this will be a problem. It is noted that there are still outstanding questions regarding this criterion. A review of known databases shows that many chemicals have existing biodegradability data available from other studies, although manufacturers and chemical vendors may not know the data is available. This requirement is also consistent with other Green Seal standards, where modeling using BIOWIN is an acceptable alternative if data does not exist, which can minimize testing. As stated previously, the term chemical agent will be replaced with papermaking additives, as a more representative term used in the industry. Green Seal reviewed marketplace data for papermaking additives and determined that there are several additional categories of chemicals that would not need to meet this criterion, including inorganic compounds and polymers. Polymers are essential additives needed in the papermaking industry, and have been excluded from this criterion in other Green Seal standards.

17 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 17 In addition to the exclusions, it was noted that many of the additives used as surfactants or defoamers may not be readily biodegradable. It was determined that an exception should be provided for these additives to meet inherent biodegradability as long as the additive has low aquatic toxicity, since these additives will end up in the wastewater which will be subject to biological treatment. Those conditions will improve the degradation of these chemicals. The following changes will be made to the standard: Biodegradability. Any papermaking additives used in the papermaking process, except for inorganic compounds, polymers, optical brighteners, and biocides, shall exhibit ready biodegradability in accordance with the Organization for Economic Co-operation and Development (OECD) definition, as follows. Biodegradability shall be measured according to any of the following methods: ISO 7827, 9439, 10707, 10708, 9408, 14593; OECD Methods 301A F; or OECD 310. Specifically, within a 28-day test, the ingredient shall meet one of the following criteria: Removal of Dissolved Organic Carbon (DOC) > 70% Biochemical Oxygen Demand (BOD) >60% % of BOD of Theoretical Oxygen Demand (ThOD) > 60% % Carbon Dioxide (CO 2 ) evolution of theoretical > 60% For papermaking additives that do not exhibit ready biodegradability in these tests the manufacturer may demonstrate biodegradability in sewage treatment plants using the Coupled Units Test found in OECD 303A by demonstrating DOC removal > 90%. An exception shall be made for papermaking additives that do not exhibit ready biodegradability, if the additive has low aquatic toxicity (acute LC mg/l for algae, daphnia, or fish) and exhibits inherent biodegradability per ISO test methods 9887 or 9888 or OECD 302A-C. Testing is not required for any papermaking additives for which sufficient information exists concerning its biodegradability, either in peer-reviewed literature or databases. In the absence of experimental data, quantitative structure-activity relationship (QSAR) data from EPA's BioWin (EPISuite) models may be considered. 5.0 MANUFACTURING REQUIREMENTS 5.2 Manufacturing and Converting Reporting Requirements. Comments:

18 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 18 We are not doing the air emissions monitoring mentioned in the standard. Will increase costs. Your comment is acknowledged. The intent of the Manufacturing and Converting Reporting Requirements section is to gather industry data for the purpose of informing future criteria in the standard. The section has been revised so that manufacturers are only required to report data that they are currently monitoring as part of their permit process. 5.2 Manufacturing and Converting Reporting Requirements. The following information shall be reported for processes including re-pulping, deinking, papermaking, product converting, and waste treatment (on-site or off-site facilities), on an annual basis or when any changes are made to the processes. If a manufacturer only does converting, then the supplier of the parent rolls will be required to provide additional relevant data. The facility shall also provide their total annual production of paper 1 data as tons PACKAGING REQUIREMENTS Air Monitoring. Air monitoring data shall be reported as required by the facility s air permit. The data shall be reported at the frequency and units specified in the permit and the associated permit limits for monitored parameters shall be provided Wastewater Monitoring. Wastewater monitoring data shall be reported as required by the facility s wastewater permit. The data shall be reported at the frequency and units specified in the permit and the associated permit limits for monitored parameters shall be provided Solid Waste. Solid waste shall be reported as the tons of material entering an external solid waste disposal stream as an annual total. Solid waste such as waste packaging materials that cannot be recycled, shall be reported as tons based on the as disposed weight. Solid waste such as wastewater solids shall be reported as dry tons (i.e., wet tons multiplied by the fractional solids content). 6.1 Primary and Secondary Packaging. One area that seems very problematical to us is Paragraph 6.1, in reference to plastic packaging. It is not clear to us that there is currently any way to certify retail products packaged in standard retail plastic packaging (Code 4). As you note, the material is not currently defined as 1 Total production represents the gross production of paper from the machines, and not sales of paper. 2 1 ton = metric tonnes

19 August 16, 2010 RESPONSE TO DRAFT FINAL V2 REVISED STANDARD BALLOT COMMENTS GS-1 19 recyclable, the only way to source reduce would be to adopt too-thin poly that would be readily damaged on the way to the consumer, and we do not believe that recovered material is currently realistically available. It is certainly not possible for companies to get consumers to return over 50% of plastic wrapping (for a take back program). So are you simply making the standard irrelevant for conventional retail products other than paper-wrapped single rolls of bathroom tissue? These comments are acknowledged. It is not the intent of this standard to preclude retail products from certification. The plastic wraps and films typically used in the paper industry would currently not be considered recyclable, but once markets are established for their use, this could change. Therefore, the recyclable option was included in the standard as a placeholder. Green Seal s intent was that plastic films would meet the 25% pre- or post-consumer requirement for manufacturing. Subsequent information from packaging suppliers shows that the level of 25% is not achievable in the marketplace for a clear plastic package. Therefore, a statement has been added that allows for documentation that the maximum available has been used, as follows: 6.1 Primary and Secondary Packaging. Primary and Secondary packaging shall meet the following requirements, based on the packaging material type: Packaging made from paper or paperboard shall be recyclable, and made from 100% recovered material. Packaging made from containerboard (corrugated cardboard) shall be recyclable and made from at least 30% recovered material. Packaging made from plastic shall be recyclable, or source-reduced by 20%, or shall contain 25% recovered material content (pre- or post-consumer). Where a product s packaging is below these levels, the manufacturer must demonstrate that efforts have been made to use the maximum available pre- or post-consumer material in packaging. An exception shall be made for packaging with an effective take-back program.