Following is the model EPP policy written for the Alameda County Source Reduction and Recycling Board by the contract team of Delyn Kies and Susan Kinsella, with input from the Board's staff, contractor Beth Eckl, and experts in a number of areas, including energy, landscaping, green building, and toxics.

The policy incorporates as wide a range of information as possible because local jurisdictions might use this in any of a number of ways, including as a local ordinance, implementation guidelines, specifications, or internal policy. Also, the needs of professional purchasers are usually quite different from those of clerical help who buy office products, but this policy is intended to be of assistance to each. Users therefore should adapt this model to their specific intended use. For example, website URLs should be removed if the model is to be framed as legislation.

October 11, 2002

MODEL

ENVIRONMENTALLY PREFERABLE PRODUCT PURCHASING POLICY

ALAMEDA COUNTY WASTE MANAGEMENT AUTHORITY
AND SOURCE REDUCTION AND RECYCLING BOARD

1.0 STATEMENT OF POLICY

It is the policy of [jurisdiction] to:

• institute practices that reduce waste by increasing product efficiency and effectiveness,
  
  
• purchase products that minimize environmental impacts, toxics, pollution, and hazards to worker and community safety to the greatest extent practicable,
  
  
• purchase products that include recycled content, are durable and long-lasting, conserve energy and water, use agricultural fibers and residues, reduce greenhouse gas emissions, use unbleached or chlorine free manufacturing processes, are lead-free and mercury-free, and use wood from sustainably harvested forests, and
  
  
• require vendors, contractors and grantees to implement this policy for all products and services provided to [jurisdiction].

2.0 PURPOSE

This Policy is adopted in order to:

• conserve natural resources,
  
  
• minimize environmental impacts such as pollution and use of water and energy,
  
  
• eliminate or reduce toxics that create hazards to workers and our community,
  
  
• support strong recycling markets,
  
  
• reduce materials that are landfilled,
  
  
• increase the use and availability of environmentally preferable products that protect the environment,
  
  
• identify environmentally preferable products and distribution systems,
  
  
• reward manufacturers and vendors that reduce environmental impacts in their production and distribution systems,
  
  
• create a model for successfully purchasing environmentally preferable products that encourages other purchasers in our community to adopt similar goals.

3.0 SPECIFICATIONS

3.1 Source Reduction

3.1.1[Jurisdiction] shall institute practices that reduce waste and result in the purchase of fewer products whenever practicable and cost-effective, but without reducing safety or workplace quality, including but not limited to:

• electronic communication instead of printed,
  
  
• double-sided photocopying and printing,
  
  
• washable and reusable dishes and utensils,
  
  
• rechargeable batteries,
  
  
• streamlining and computerizing forms,
  
  
• "on-demand" printing of documents and reports as they are needed,
  
  
• leasing long-life products when service agreements support maintenance and repair rather than new purchases, such as carpets,
  
  
• sharing equipment and occasional use items such as chippers,
  
  
• choosing durable products rather than disposable,
  
  
• reducing product weight or thickness when effectiveness is not jeopardized in products such as, but not limited to, paper and plastic liner bags,
  
  
• buying in bulk, when storage and operations exist to support it,
  
  
• reusing products such as, but not limited to, file folders, storage boxes, office supplies, and furnishings.
  

3.1.2 [[Jurisdiction] shall purchase remanufactured products such as laser toner cartridges, tires, furniture, equipment and automotive parts whenever practicable, but without reducing safety, quality or effectiveness.

3.1.3 [Jurisdiction] shall require all equipment bought after the adoption of this policy to be compatible with source reduction goals and practices when practicable, including but not limited to:

• copiers and printers capable of duplexing,
  
  
• battery-operated equipment capable of being recharged or using rechargeable batteries,
  
  
• dishwashing equipment, when washable and reusable dishes and utensils are practicable,
  
  
• bulk storage and operation.

3.1.4 All buyers shall evaluate short-term and long-term costs in comparing product alternatives, when feasible. This includes consideration of total costs expected during the time a product is owned, including, but not limited to, acquisition, extended warranties, operation, supplies, maintenance, disposal costs and expected lifetime compared to other alternatives. Examples of products for which such cost comparisons can indicate significant differences between short- and long-term costs include, but are not limited to, janitorial towels and tissues, parking stops, park benches and tables, office equipment, software and vehicles.

3.1.5 Products that are durable, long lasting, reusable or refillable are preferred whenever feasible.

 

3.2 Recycled Content Products

3.2.1 Printing paper, office paper, and paper products shall contain the highest postconsumer content practicable, but no less than the minimum recycled content standards established by the United States Environmental Protection Agency (U.S. EPA) Guidelines (see Definitions).

3.2.2 Janitorial paper products shall contain the highest postconsumer content practicable, but no less than the minimum recycled content standards established by the U.S. EPA Guidelines.

3.2.3 Other products for which the U.S. EPA has established minimum recycled content standard guidelines, such as those for construction, landscaping, parks and recreation, transportation, vehicles, miscellaneous, and non-paper office products, shall contain the highest postconsumer content practicable, or, when postconsumer material is impracticable for a specific type of product, contain substantial amounts of recovered material, but no less than the minimums established by the U.S. EPA Guidelines.

3.2.4 Copiers and printers bought shall be compatible with the use of recycled content products. When necessary, suppliers shall train equipment maintenance personnel in the appropriate use of recycled products with their equipment.

3.2.5 In accordance with California Public Contract Code, Sec. 10409, [jurisdiction] shall purchase recycled lubricating and industrial oil for use in its vehicles and other equipment, as long as it is certified by the American Petroleum Institute (API) as appropriate for use in such equipment (see http://api-ep.api.org/quality/index.cfm for information about APIÕs Engine Oil Licensing and Certification System).

3.2.6 When specifying asphalt concrete, aggregate base or portland cement concrete for road construction projects, [jurisdiction] shall use recycled, reusable or reground materials when practicable, including, but not limited to, in-place recycling of asphalt concrete, aggregate base and portland cement concrete; rubberized asphalt concrete; recycled aggregate base; or recycled asphalt concrete.

3.2.7 [Jurisdiction] shall specify and purchase recycled-content transportation products, including signs, cones, parking stops, delineators, and barricades, including recycled products approved by the California Department of Transportation (Caltrans).

 

3.3 Forest Conservation

3.3.1 To the greatest extent practicable, [jurisdiction] shall not procure wood products such as lumber and paper that originate from forests harvested in an environmentally unsustainable manner. When possible, [jurisdiction] shall give preference to wood products that are certified to be sustainably harvested by a comprehensive, performance-based certification system. The certification system shall include independent third-party audits, with standards equivalent to, or stricter than, those of the Forest Stewardship Council certification (see Definitions).

3.4 Toxics and Pollution

3.4.1 When replacing vehicles, diesel shall be phased out and replaced with less polluting alternatives such as compressed natural gas, biobased fuels, hybrids, and electric batteries.

3.4.2. To the extent practicable, no cleaning or disinfecting products (i.e. for janitorial or automotive use) shall contain ingredients that are carcinogens, mutagens, or teratogens. These include chemicals listed by the U.S. EPA or the National Institute for Occupational Safety and Health on the Toxics Release Inventory and those listed under Proposition 65 by the California Office of Environmental Health Hazard Assessment. If products must be used that contain these toxic materials, ensure that only the minimum amounts are used and the product is disposed of properly (see Definitions).

3.4.3 The use of chlorofluorocarbon-containing refrigerants, solvents and other products shall be phased out and new purchases shall not contain them.

3.4.4 All surfactants and detergents shall be readily biodegradable and, where practicable, shall not contain phosphates.

3.4.5 All interior paint shall contain the lowest concentrations practicable of volatile organic compounds (VOCs), but as a minimum shall not exceed 50 grams VOC per liter (50g/l) for flat paint and 150 grams per liter (150g/l) for non-flat paints, as determined in accordance with U.S. EPA Test Method 24, CFR Title 40, Part 60, Appendix A. For exterior paints, preference shall be given to paints containing at least 50 percent recycled content (post-industrial and postconsumer) and/or VOC concentrations less than 150g/l (U.S. EPA Test Method 24).

3.4.6 [Jurisdiction] shall reduce or eliminate its use of products that contribute to the formation of dioxins and furans. This includes, but is not limited to:

• Purchasing paper, paper products, and janitorial paper products that are unbleached or that are processed without chlorine or chlorine derivatives, whenever possible. Processed chlorine free (PCF) paper is preferred. Elemental chlorine free (ECF) processes should include enhanced processes such as extended and oxygen delignification whenever possible. Vendors and successful bidders shall supply certification of the paperÕs chlorine free processing status from either a recognized certifying organization or the pulp and paper manufacturer.
  
  
• Prohibiting purchase of products that use polyvinyl chloride (PVC) such as, but not limited to, binders, flooring, and medical supplies whenever practicable.
  

3.4.7 [Jurisdiction] shall purchase products and equipment with no lead or mercury whenever possible, including automotive vehicles. For products that contain lead or mercury, [Jurisdiction] shall give preference to those products with lower quantities of these metals and to vendors with established lead and mercury recovery programs.

 

3.5 Energy and Water Savings

3.5.1 Where applicable, energy-efficient equipment shall be purchased with the most up-to-date energy efficiency functions. When necessary, suppliers or manufacturers shall train equipment operators and maintenance personnel in the proper enabling and use of energy efficient and sleep mode functions on their equipment.

3.5.2 When practicable, [Jurisdiction] shall replace inefficient lighting with energy efficient equipment. Incandescent, mercury vapor and T12 fluorescent lamps should be replaced with compact fluorescent lamps, high-intensity discharge (HID) fixtures and low-mercury T8 or T5 fluorescent lamps. The magnetic ballasts used in older fluorescent lighting should be replaced with electronic ballasts. New lighting should be designed to use no more than 85% of the power allowed by Title 24 Energy Code. Purchasers shall require vendors to recycle discarded lighting fixtures and lamps appropriately.

3.5.3 All appliances purchased by [Jurisdiction] and for which the U. S. EPA Energy Star certification is available shall meet Energy Star certification. Typically, this would include exhaust fans, water heaters, computers, exit signs, water coolers and appliances such as refrigerators, dishwashers and microwave ovens.

3.5.4 When Energy Star labels are not available, choose energy efficient products that are in the upper 25% of energy efficiency as designated by the Federal Energy Management Program.

3.5.5 Wherever [Jurisdiction] replaces roofs, Energy Star-qualifying roof materials shall be used.

3.5.6 [Jurisdiction] shall purchase high efficiency space heating systems that use natural gas rather than electricity, and have an annual fuel utilization efficiency (AFUE) of 0.86 or greater, whenever practicable

3.5.7 [Jurisdiction] shall purchase high efficiency space cooling equipment with an energy efficiency rating (EER) of 11.5 or greater, whenever practicable.

3.5.8 [Jurisdiction] shall purchase water-saving products whenever practicable.

3.6 Green Building - Construction and Renovations

3.6.1 All building and renovations undertaken by [jurisdiction] shall follow Green Building practices for design, construction, and operation, as specified in the Alameda County Waste Management Authority Civic Green Building Model Ordinance (available along with other Building and Construction information from the Alameda County Waste Management Authority).

3.6.2 All newly constructed [jurisdiction]-sponsored buildings shall incorporate sufficient green building methods and techniques to qualify for the equivalent of a LEEDTM Rating System certification (see Definitions).

3.6.3 Renovation of [jurisdiction]-sponsored buildings shall achieve as many pre-requisites and credits as feasible as described in the LEEDTM Rating System for Existing Buildings Pilot Phase and any subsequent version adopted (see Definitions).

3.6.4 [Jurisdiction] shall work with residents, businesses, and other members of the community, including architects, builders and contractors, to encourage private development within the City to use green building methods and practices and to achieve standards set by LEEDTM for commercial buildings, the Alameda County Waste Management Authority Green Building Model Resolution, and the Alameda County Waste Management Authority Residential Green Building Guidelines and Green Points Rating System (available along with other Building and Construction information from the Alameda County Waste Management Authority).

3.7 Waste Minimization

3.7.1 [Jurisdiction] requires vendors to eliminate packaging or use the minimum amount necessary for product protection, to the greatest extent practicable.

3.7.2 Packaging that is reusable, recyclable or compostable is preferred, when suitable uses and programs exist.

3.7.3 Vendors shall be encouraged to take back and reuse pallets and packaging materials.

3.7.4 Suppliers of electronic equipment, including but not limited to computers, monitors, printers, and copiers, shall be required to take back equipment for reuse or environmentally safe recycling when [jurisdiction] discards or replaces such equipment, whenever possible.

3.8 Landscaping

3.8.1 Workers and contractors providing landscaping services for [jurisdiction] shall employ sustainable landscape management practices whenever possible, including:

• The use of integrated pest management, including minimal pesticide use is encouraged.
  
  
• Grasscycling (leaving the clippings on the lawn) is required for at least 50% of all mowings.
  
  
• Pruning shall be done on an as needed basis. Thinning is the preferred method of pruning. Minimal heading or shearing is encouraged.
  
  
• Fertilizing should be done on an as needed basis, as indicated by a soil analysis. Slow release and/or organic fertilizers are preferred.
  
  
• Irrigation scheduling based on weather (evapo-transpiration rates) is required whenever possible. Drip irrigation is preferred whenever practical.
  
  
• Turf areas where drip irrigation is not appropriate should be limited to walking and play surfaces. All other landscaping (such as for views) should be accomplished with low-water plantings.
  
  
• Recycling of plant debris by composting and/or maintaining a minimum 2-inch layer of mulch under all trees, shrubs and groundcovers and a minimum 3-inch layer in all open areas is strongly encouraged. Allowing leaf drop to become part of the mulch layer in tree, shrub and groundcover areas is preferred.

3.8.2 Plants should be selected to minimize waste by choosing species that are appropriate to the microclimate, species that can grow to their natural size in the space allotted them and perennials rather than annuals for color. Native and drought-tolerant plants that require no or minimal watering once established are preferred.

3.8.3 To the greatest extent practicable, [jurisdiction] shall not procure mulch products that originate from forest products. When possible, [jurisdiction] shall give preference to mulch products that are produced on-site or from regionally generated plant debris.

3.8.4 To the greatest extent practicable, [jurisdiction] shall procure compost that is produced from feedstock that includes at least 50%, by volume, regionally generated plant debris and/or food waste and less than 0.5% by volume, physical contaminants. The compost shall be processed in accordance with California Code of Regulations, Title 14, Chapter 3, Article 7, Sections 17868.2-3 to promote pathogen reduction and weed seed kill and minimize heavy metal concentrations.

3.8.5 Hardscapes and landscape structures constructed of recycled content materials are encouraged. Concrete substitutes are encouraged for walkways, such as rosin emulsion paving.

 

3.9 Agricultural Bio-Based Products

3.9.1 Vehicle fuels made from non-wood, plant-based contents such as vegetable oils are encouraged whenever practicable.

3.9.2 Paper, paper products and construction products made from non-wood, plant-based contents such as agricultural crops and residues are encouraged whenever practicable.

 

4.0 DEFINITIONS

4.1 "Agricultural Bio-Based Products" means commercial or industrial products (other than food or feed) that utilize agricultural crops or residues but does not include products made from forestry materials.

4.2 "Buyer" means anyone authorized to purchase on behalf of this jurisdiction or its subdivisions.

4.3 "Chlorine free" means products processed without chlorine or chlorine derivatives.

4.4 "Contractor" means any person, group of persons, business, consultant, designing architect, association, partnership, corporation, supplier, vendor or other entity that has a contract with [jurisdiction] or serves in a subcontracting capacity with an entity having a contract with [jurisdiction] for the provision of goods or services.

4.5 "Dioxins and furans" are a group of chemical compounds that are classified as persistent, bioaccumulative, and toxic by the Environmental Protection Agency.

4.6 "Elemental Chlorine Free" (ECF) bleaching processes replace elemental chlorine gas with a chlorine derivative as the bleaching agent. There is a wide range of different bleaching sequences covered under this term. While all ECF processes significantly reduce the amount of dioxins created in the bleaching process, those that include enhanced processes such as extended and oxygen delignification achieve the greatest reduction.

4.7 "Energy Star" means the U.S. EPAÕs energy efficiency product labeling program described at http://www.energystar.gov.

4.8 "Energy Efficient Product" means a product that is in the upper 25% of energy efficiency for all similar products, or that is at least 10% more efficient than the minimum level that meets Federal standards.

4.9 The "Forest Stewardship Council" is a global organization that certifies responsible, on-the-ground forest management according to rigorous standards developed by a broad variety of stakeholder groups (http://fscus.org/html/).

4.10 "LEEDTM Rating System" means the self-assessing system developed by the U.S. Green Building Council designed for rating new and existing commercial, institutional, and high-rise residential buildings. Credits are earned for satisfying defined criteria and standards. Different levels of green building certification are awarded based on the total credits earned. The LEEDTM Green Building Rating System is described at http://www.usgbc.org.

4.11 "Postconsumer Material" means a finished material which would normally be disposed of as a solid waste, having reached its intended end-use and completed its life cycle as a consumer item, and does not include manufacturing or converting wastes.

4.12 "Practical" and "Practicable" mean whenever possible and compatible with state and federal law, without reducing safety, quality, or effectiveness.

4.13 "Preconsumer Material" means material or by-products generated after manufacture of a product is completed but before the product reaches the end-use consumer. Preconsumer material does not include mill and manufacturing trim, scrap, or broke which is generated at a manufacturing site and commonly reused on-site in the same or another manufacturing process.

4.14 "Processed Chlorine Free (PCF)" refers to a recycled product in which the recycled content is produced using no chlorine or chlorine derivatives. Any virgin content in the product must also be produced in a chlorine free system.

4.15 "Proposition 65" means a list of chemicals that are known to the State of California to cause cancer, birth defects or other reproductive harm. The list is maintained by the California Office of Environmental Health Hazard Assessment (http://www.oehha.ca.gov/prop65.html).

4.16 "Recovered Material" means fragments of products or finished products of a manufacturing process, which has converted a resource into a commodity of real economic value, and includes preconsumer and postconsumer material but does not include excess resources of the manufacturing process.

4.17 "Recycled Content" means the percentage of recovered material, including preconsumer and postconsumer materials, in a product.

4.18 "Recycled Content Standard" means the minimum level of recovered material and/or postconsumer material necessary for products to qualify as "recycled products."

4.19 "Recycled Product" means a product that meets [jurisdictionÕs] recycled content policy objectives for postconsumer and recovered material.

4.20 "Remanufactured Product" means any product diverted from the supply of discarded materials by refurbishing and marketing said product without substantial change to its original form.

4.21 "Reused Product" means any product designed to be used many times for the same or other purposes without additional processing except for specific requirements such as cleaning, painting or minor repairs.

4.22 "Source Reduction" refers to products that result in a net reduction in the generation of waste compared to their previous or alternate version and includes durable, reusable and remanufactured products; products with no, or reduced, toxic constituents; and products marketed with no, or reduced, packaging.

4.23 "Title 24" means the State of CaliforniaÕs energy efficiency standards for residential and nonresidential buildings (Title 24, Part 6) maintained by the California Energy Commission and described at http://www.energy.ca.gov/title24.

4.24 The "Toxics Release Inventory" (TRI) is a publicly available U. S. EPA database that contains information on toxic chemical releases and other waste management activities reported annually by certain covered industry groups as well as federal facilities. It includes chemicals that are classified as carcinogens under the requirements of the Occupation Safety and Health Administration (OSHA) Lists can be obtained from http://www.epa.gov/tri/chemical/index.htm.

4.25 "U.S. EPA Guidelines" means the Comprehensive Procurement Guidelines established by the U.S. Environmental Protection Agency for federal agency purchases as of May 2002 and described at http://www.epa.gov/epaoswer/non-hw/procure/products.htm, or as updated.

4.26 "Water-Saving Products" are those that are in the upper 25% of water conservation for all similar products, or at least 10% more water-conserving than the minimum level that meets the Federal standards.

 

5.0 PRIORITIES

5.1 The health and safety of workers and citizens is of utmost importance and takes precedence over all other policies

5.2 [Jurisdiction] has made significant investments in developing a successful recycling system and recognizes that recycled content products are essential to the continuing viability of that recycling system and for the foundation of an environmentally sound production system. Therefore, to the greatest extent practicable, recycled content shall be included in products that also meet other specifications, such as chlorine free or bio-based.

5.3 Nothing contained in this policy shall be construed as requiring a department or contractor to procure products that do not perform adequately for their intended use, exclude adequate competition, or are not available at a reasonable price in a reasonable period of time.

5.4 Nothing contained in this policy shall be construed as requiring the [jurisdiction], department or contractor to take any action that conflicts with state or federal requirements.

6.0 IMPLEMENTATION

6.1 The [Director of Purchasing, Director of Finance, other responsible director] shall implement this policy through development of an advisory committee or Green Purchasing Team consisting of members representing purchasers, printing and copying, Information Services, Public Works and construction, and all departments which purchase or specify products or award contracts for services that provide products to [jurisdiction]. The teamÕs responsibilities shall include, but are not limited to:

• evaluating opportunities for substituting environmentally preferable products,
  
  
• designing and implementing programs and processes for increasing the purchase of environmentally preferable products,
  
  
• educating managers and staff about [jurisdictionÕs] Environmentally Preferable Purchasing Policy,
  
  
• ensuring that purchasing documents, specifications, and contracting procedures do not contradict each other and do not deter or inhibit the purchase of environmentally preferable products,
  
  
• providing information to facilitate the evaluation and purchase of environmentally preferable products, including identifying appropriate products and sources and providing technical assistance, and
  
  
• evaluating obstacles to purchasing such products in order to create solutions.

6.2 In compliance with State law, vendors shall be required to specify the minimum or actual percentage of recovered and postconsumer material in their products, even when such percentages are zero.

6.3 Vendors and successful bidders shall verify environmentally preferable purchasing claims by certifying, under penalty of perjury, that the environmental attributes claimed are accurate. Such certification shall be accomplished by supplying signed verification from either a recognized certifying organization or the manufacturer, or by identifying claim verification on the product, such as the Energy Star symbol. This requirement for certification applies to products for which the vendor or successful bidder claims such attributes as apply to the product, including, but not limited to, recycled content, chlorine free, non-toxic, reduced toxicity, sustainable forestry, and energy-saving features.

6.4 Buyers making the selection shall provide a written explanation for product choices that do not meet the environmentally preferable purchasing criteria in this policy. Such written explanations shall be filed with the [Director of Finance, Director of Purchasing, other position responsible for implementing this policy, Green Purchasing Team] within 15 days of making the product choice (see Attachment for sample procurement determination form).

6.5 Performance evaluations for all staff responsible for buying products on behalf of [jurisdiction] shall include assessments of their successful implementation of this policy.

6.6 All contracts and grants providing services or products to [jurisdiction] shall include evaluation of their compliance with this policy.

 

7.0 PROGRAM EVALUATION AND MEASUREMENT

7.1 The [Director of Finance, Director of Purchasing, other position responsible for implementing this policy, Green Purchasing Team] shall institute a system for tracking the purchases of environmentally preferable products. Whenever practicable, vendors will be required to provide reports on their sales of environmentally preferable products to assist [jurisdiction] in this tracking.

7.2 The [Director of Finance, Director of Purchasing, other position responsible for implementing this policy] shall provide a narrative report annually to the [jurisdiction Board of Supervisors, City Council, or other body] on the success of this policyÕs implementation. To the extent practicable, such report shall include information on the annual volume and dollar amount of environmentally preferable products purchased compared to the total amount of products purchased, within general product categories. When possible, reports shall include a narrative evaluation of the performance, safety, and environmental benefits achieved through use of the environmentally preferable products purchased. Reports should relate progress in meeting the objectives of this Policy as stated in Sections 1.0 and 2.0 and in accordance to the Specifications categories used in this Policy.

7.3 Reports shall include notation of any barriers encountered in procurement of environmentally preferable products, recommendations for resolution, and/or description of assistance needed for overcoming the obstacles.

8.0 EFFECTIVE DATES

8.1 This policy shall take effect on [date].

8.2 The first annual report shall be issued within one year following the effective date of this policy.

 

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ATTACHMENT

Sample Procurement Determination Form

 

Item: _______________________________________________________

 

____ This item is required to meet Environmentally Preferable Purchasing guidelines as described in [jurisdictionÕs policy, resolution or legislation identification information].

____ I have considered the Environmentally Preferable Purchasing guidelines and searched for product or service options that meet them.

____ Compliance with [jurisdictionÕs policy identification] was not attainable for this purchase because:

____ Item is not available within a reasonable period of time.

(Need date: ___________ Date available: ____________)

____ Item fails to meet a performance standard in the specifications.

Specifically, __________________________________________________

____________________________________________________________

____________________________________________________________

____ Item is not available, or is not available from 2 or more sources.

Market research was performed by calling ____(insert number) vendors, but only ______________________________ (enter name) was able to supply the item.

_____ Item was only available at an unreasonable price (i.e., EPP item cost more than non-compliant item).

Price of EPP item: ___________________

Price of non-compliant item: ________________

_____ Compliance would conflict with state or federal law requiring that:

__________________________________________________________

 

___________________________
Signature of Purchaser

__________________________
Printed Name of Purchaser

___________________
Date