The door and window industry should be well aware now of the Federal Trade Commission’s (FTC) Guide to Environmental Marketing Claims, more commonly referred to as the Green Guides. Laura Koss, FTC staff attorney, offered further insights into the guides and how companies must pay close attention when making environmental claims. The presentation was given as part of the legislative meeting of the Window and Door Manufacturers Association (WDMA) and the National Lumber and Building Material Dealers Association (NLBMDA) held this week.

Koss said that when designing marketing materials and messages remember to take consumer perception in mind.

“It’s all about consumer perceptions and how they perceive claims,” said Koss. “If you take one thing away today it’s the importance of specificity.”

She reminded attendees of the five window companies who settled with the FTC last year over deceptive energy and cost claims. In that case, companies were making up claims.

“You have to have evidence that most consumers would receive the maximum benefit,” said Koss. “Qualifications should be clear and prominent. They have to be able to read it and it has to be in close proximity to the claim and it has to be before a customer makes the purchase decision. You can’t send them to the website.”

She pointed out that when the FTC looks at an ad they are looking at the overall perception a reasonable consumer will have.

“Even if you don’t say green or energy efficient, if you have green images that is deceptive,” she said. “If you use a certification seal on your ad consumers think that your product is endorsed by that agency so you still have to qualify that claim.”

Koss admitted that the biggest issue the FTC dealt with in the recent revision of the green guides was multi attribute certification.

“How do you qualify all that?,” she asked. The FTC ultimately suggested a statement that could include: “Virtually all products impact the environment. For details on which attributes we evaluated go to (website discussing product).”


While one group of WDMA/NLBMDA attendees were learning all about FTC the other was being educated regarding the Occupational Safety and Health Administration (OSHA) by Sanji Kanth, P.E., directorate of enforcement programs for the office of chemical process safety and enforcement initiatives. Specifically he discussed industry-related incidents.

According to Kanth, OSHA uses a site specific targeting program (SST) to determine inspections.

“We have only 1,600-2,000 compliance officers, to effectively use our officers we target industries which have … high rates of incidences,” he said.

The lumber industry proved to have more inspections, violations and penalties than the door and window industry according to Kanth, under certain codes.

Penalties for lumber-related code violations totaled close to $2 million while penalties door and window-related code violations were just under $1 million.

Kanth also said that 3.2 was the national average number of violations issued per inspection.

Combustible dust was one major area for violations in manufacturing and compliance safety. Kanth said use of vacuums, enclosureless dust collectors and magnetic separators can help reduce this dust accumulation.

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