General procedures

Overview

This section prescribes the operational steps for implementing sustainable acquisition policies, detailing the documentation required when sustainable products are not used, the specific identification of those products in contract documents, and the priority ranking of various environmental programs.

Key Rules

• Written Justification: If a requiring activity determines it is not practicable to procure sustainable products or services, they must provide a written justification for the contract file addressing the specific reasons.
• Identification in Solicitations: Contracting officers must explicitly identify applicable sustainable products and purchasing programs in the solicitation, as well as any products specifically excluded via justification, exception, or exemption.
• Prioritization Hierarchy: Agencies must prioritize products in the following order:
  1. Statutory purchasing programs (e.g., EPA-designated recycled content and USDA biobased).
  2. Multi-attribute products (meeting both statutory and EPA program requirements).
  3. Non-statutory EPA purchasing programs.
• Conflict Resolution: If a conflict arises between an EPA-designated item and a USDA biobased product, and no product meets both standards, the EPA-designated item takes precedence.
• Primary Resource: The Green Procurement Compilation (GPC) at sftool.gov is established as the official resource for determining applicable purchasing programs and guidance.

Practical Implications

• File Documentation: Contracting officers must ensure the contract file contains specific justifications from the requiring activity whenever "green" requirements are bypassed to avoid audit findings.
• Increased Specificity: Solicitations must be more granular, identifying not just that "sustainable products" are required, but specifying the exact purchasing program (e.g., Comprehensive Procurement Guideline) and product type.
• Technical Compliance: Procurement teams should integrate the Green Procurement Compilation (GPC) into their market research workflow to ensure they are applying the correct priority levels to different environmental labels and certifications.