Green Seal 2009 — Version Comparison of GS-37 (Third Edition 2006 vs Fourth Edition 2008)

An 18-page side-by-side tabular comparison published by Green Seal, Inc. on August 29, 2009 documenting the criterion-by-criterion differences between the Third Edition (February 27, 2006) and Fourth Edition (August 29, 2008) of Green Seal’s Environmental Standard for Industrial and Institutional Cleaners, GS-37. The document is explicitly framed (p. 1) as a comparison artefact and not the complete standard: “This is not the complete standard or criteria, but rather differences between the two versions. Please refer to the complete standard for exact criteria and the list of acronyms and abbreviations, available at www.greenseal.org.” Revised criterion language is highlighted in red in the source. The Third Edition column reproduces the 2006 text and the Fourth Edition column reproduces the 2008 text; criterion families covered include scope, product performance testing, acute toxicity, CMR substances, asthmagens, skin sensitization, skin absorption, prohibited ingredients, VOC content, inhalation toxicity, aquatic toxicity, bioaccumulating compounds, aquatic biodegradability, eutrophication, combustability, fragrances, color components, concentrates, closed dilution-control systems and concentrates, animal testing, packaging requirements, training, and labeling.

Heavy-metal relevance is concentrated in two criterion families: the Prohibited Ingredients clause (which lists named heavy metals barred from product formulation in both editions, with the named-metal list narrowing between the two editions) and a wholly new Heavy Metal Restrictions sub-clause within the Fourth Edition’s Packaging Requirements (which sets a sum-of-concentrations numerical ceiling on four heavy metals in primary packaging). In the Third Edition (2006) Prohibited Ingredients clause the named metals barred from product formulation are arsenic, lead, cadmium, cobalt, chromium, mercury, nickel, and selenium (eight named metals plus the umbrella phrase “Heavy metals including”). In the Fourth Edition (2008) the named-metal list in the Prohibited Ingredients clause narrows to lead, hexavalent chromium, and selenium (three named metals, with the speciation refinement “either in the elemental form or compounds”). The Fourth Edition adds 2-butoxyethanol and phthalates to the prohibited-ingredients list. The Fourth Edition’s wholly new Packaging Requirements > Heavy Metal Restrictions sub-clause states that heavy metals — explicitly enumerating lead, mercury, cadmium, and hexavalent chromium — shall not be intentionally introduced into packaging, and that the sum of the concentration levels of these metals present shall not exceed 100 parts per million by weight (0.01%); an exception applies for refillable packages or packages that would not exceed the maximum but for the addition of post-consumer materials, and intentional introduction does not include the use of one of the metals as a processing aid or intermediate to impart certain chemical or physical changes during manufacturing where the incidental retention of a residual is not desired or deliberate and the final packaging complies with the 100 ppm incidental-concentration ceiling. A parallel Other Restrictions sub-clause in the same Packaging Requirements section prohibits intentional introduction of phthalates and chlorinated packaging material into packaging.

The document also records two boundary changes in the GS-37 product scope between the two editions: the Fourth Edition excludes FIFRA-registered cleaners (which were included in the Third Edition) and adds toilet bowl cleaners and carpet spot cleaners as in-scope product categories. The Fourth Edition introduces a new criterion family — Inhalation Toxicity — with two compliance pathways (Chronic Inhalation Toxicity via R48/23 listing or OECD Harmonized Integrated Classification System ≤1.0 mg/L vapor NOAEL, or Chamber Testing per the GREENGUARD Children and Schools method). The Fourth Edition introduces Bioaccumulating Compounds as a new criterion (BCF >100, log BCF >2 per ASTM E-1022-94(2007) or OECD 305 Bioconcentration Flow-through Fish Test), revises the Acute Toxicity oral LD50 ceiling from ≤2,000 mg/kg to ≤5,000 mg/kg, adds asthmagens as prohibited ingredients (no criterion in Third Edition), and tightens Skin Sensitization to require the Local Lymph Node Assay (LLNA) per OECD Guideline 429 / OPPTS 870.2600 for new products with Buehler and Magnusson-Kligman methods retained as acceptance pathways when LLNA data are unavailable. The Fourth Edition adds a Closed Dilution-Control Systems and Concentrates criterion family with three new definitions (sections 2.5, 2.6, 2.22, 2.33) and concentration ratios for general purpose cleaners (1:32) and glass, restroom, and carpet cleaners (1:16). The Fourth Edition revises the Packaging Requirements primary-package rule (plastic primary packages shall be recyclable, refillable, source-reduced, or contain at least 25% post-consumer material, clearly marked with the appropriate Society of the Plastics Industry symbol; non-plastic primary packages shall contain at least 25% post-consumer material or demonstrate maximum-available-post-consumer-material effort), prohibits aerosol cans and prohibits concentrated products from being packaged in spray-dispenser bottles or other ready-to-use package types.

The document is the comparison artefact only; it is not the binding GS-37 standard text in either edition. Where a numerical limit appears in this document, it appears because the comparison reproduces the relevant rule from the underlying standard edition. Downstream HMI work citing GS-37 numerical heavy-metal limits should consult the underlying standard editions (GS-37 Fourth Edition August 29, 2008, and any post-2008 revision) as the binding sources; this comparison document is a navigation aid showing what changed between editions, not the binding text itself.

Key numbers

Numerical content below is the subset most relevant to HMI synthesis on industrial and institutional cleaning product groups: the prohibited-metals lists for both editions, the packaging-metal sum ceiling, and adjacent numerical thresholds (VOC limits, dilution-ratio requirements, oral LD50, vapor pressure thresholds, post-consumer material percentage) that contextualise the heavy-metal limits within the standard’s overall quantitative register.

Heavy-metal-specific prohibitions and limits

Non-metal numerical limits revised between editions (preserved for context)

Scope changes between editions

Heavy-metal-specific summary

The comparison document captures two distinct heavy-metal regulatory mechanisms within GS-37 and shows how they evolved between Third and Fourth Editions.

(1) Prohibited Ingredients in product formulation. Both editions prohibit “heavy metals” in the formulated cleaner, but the named-metal list differs. The Third Edition (2006) lists arsenic, lead, cadmium, cobalt, chromium, mercury, nickel, and selenium. The Fourth Edition (2008) lists lead, hexavalent chromium, and selenium, with the speciation refinement “either in the elemental form or compounds.” The Fourth Edition footnote (p. 4) explains that the named-list is justified by demonstrated endocrine-disruption, neurotoxicity, and systemic-toxicity health concerns and that “other chemicals may have such health concerns but are not listed because they may already be prohibited through other criteria in the standard.” The comparison document does not quantify a concentration ceiling in either edition’s Prohibited Ingredients clause; the clause is a binary prohibition on intentional formulation, with downstream operational specifics (impurity allowances, threshold for incidental presence) located in the underlying standard text not reproduced in this comparison.

(2) Heavy Metal Restrictions in primary packaging (Fourth Edition only). The Fourth Edition adds a wholly new Packaging Requirements > Heavy Metal Restrictions sub-clause naming four metals — lead, mercury, cadmium, and hexavalent chromium — and setting a numerical sum-of-concentrations ceiling of 100 parts per million by weight (0.01%) on intentional introduction of these four metals into packaging, with the processing-aid / intermediate carve-out and the post-consumer-material exception described above. This is the comparison document’s single explicit heavy-metal numerical limit. The 100 ppm sum ceiling corresponds to the four-metals sum convention used in the U.S. Coalition of Northeastern Governors (CONEG) Model Toxics in Packaging Legislation (1989) and in EU Directive 94/62/EC Article 11, both of which set a 100 ppm sum ceiling on the same four metals in packaging; this comparison document does not name those external regulations as references but the structural parallel is direct.

The narrowing of the named-metal list between editions (8 metals in 2006 → 3 metals in 2008 plus the elemental/compound speciation refinement) means that arsenic, cadmium, cobalt, chromium (without hexavalent specification), mercury, and nickel are not by-name prohibited in the Fourth Edition Prohibited Ingredients clause; coverage of those metals in 2008 operates through other criterion families (acute toxicity, asthmagen, skin sensitization, skin absorption, inhalation toxicity, aquatic toxicity, bioaccumulating compounds) rather than through a name-listed prohibition. The Fourth Edition’s Packaging Heavy Metal Restrictions sub-clause separately names mercury and cadmium (and lead and hexavalent chromium) in the packaging context with the 100 ppm sum ceiling.

Methods (brief)

Not applicable in the experimental sense. This is a programme-comparison document, not an analytical study. It does not perform original sampling, analytical measurement, or contamination quantification. The document reproduces criterion text from the Third Edition (February 27, 2006) and Fourth Edition (August 29, 2008) of GS-37 side by side in tabular form, with revised criterion language highlighted in red. The document does not state the analytical methods Green Seal uses to verify heavy-metal absence in formulated products or in primary packaging; those methods are located in the underlying standard editions or in Green Seal’s certification audit procedures, not in this comparison artefact.

The comparison document references the following test-method identifiers in its non-metal criteria (preserved here as scientific-method names per CLAUDE.md Part 14 Exception 2): ASTM D4488-95 A5 (Third Edition particulate-soil-removal performance test for general-purpose cleaners); ASTM D5343 (bathroom-cleaner soil-removal test); ASTM D92-97 Cleveland Open Cup (combustability flashpoint); ASTM D 4206 (sustained-flame test); ASTM E-1022-94(2007) (Bioconcentration Standard Guide for Fishes and Saltwater Bivalve Molluscs, Fourth Edition Bioaccumulating Compounds criterion); ISO 13736; ISO 2719; ISO 7346-2 (fish acute aquatic toxicity); ISO 9439, 9888, 10707, 10708, 9408, 14593, 7827, 9887 (biodegradability); OECD Test Guidelines 201 (algae), 202 (daphnia), 203 (fish), 301A-F (ready biodegradability), 302A/B/C (inherent biodegradability), 305 (Bioconcentration Flow-through Fish Test), 310 (biodegradability), 401 (acute oral toxicity), 402 (acute dermal toxicity), 403 (acute inhalation toxicity), 406 (Buehler / Magnusson-Kligman skin sensitization), 429 (Local Lymph Node Assay skin sensitization), 204 (chronic fish aquatic toxicity); OPPTS 870.2600 (EPA skin sensitization); California Air Resources Board Method 310 (VOC content); GREENGUARD Children and Schools Standard Method for Measuring and Evaluating Chemical Emissions from Cleaners and Cleaning Maintenance Systems Using Dynamic Environmental Chambers (Fourth Edition Inhalation Toxicity > Chamber Testing pathway); 40 CFR Part 797 Subpart B (aquatic toxicity for non-fish organisms); EPA BioWin / EpiSuite QSAR (Fourth Edition biodegradability supporting evidence); ACGIH Threshold Limit Value (TLV) list with skin notation (Fourth Edition Skin Absorption criterion); German Deutsche Forschungsgemeinschaft (DFG) Maximum Allowable Concentrations (MAK) list with H notation (Fourth Edition Skin Absorption criterion); European Chemicals Bureau R48/23 listing (Fourth Edition Chronic Inhalation Toxicity criterion); OECD Harmonized Integrated Classification System for Human Health and Environmental Hazards of Chemical Substances and Mixtures (Fourth Edition Chronic Inhalation Toxicity criterion).

Speciation. The Fourth Edition introduces speciation discipline for chromium by naming “hexavalent chromium” specifically in both the Prohibited Ingredients clause (in product formulation) and in the Packaging Heavy Metal Restrictions sub-clause. The Third Edition prohibits “chromium” without speciation. Neither edition speciates arsenic (the Third Edition prohibits “arsenic” without inorganic/total distinction; the Fourth Edition does not name arsenic) or mercury (the Third Edition prohibits “mercury” without inorganic/methyl distinction; the Fourth Edition Packaging clause names “mercury” without speciation).

Basis. The Prohibited Ingredients clauses operate on intentional formulation as a binary prohibition (no numerical concentration threshold reproduced in this comparison document). The Fourth Edition Packaging Heavy Metal Restrictions sub-clause expresses its numerical ceiling as a sum of the four named metals’ concentrations not exceeding 100 ppm by weight (0.01%) in the packaging material; the basis is mass-per-mass of packaging, not of the formulated product within the packaging. VOC content limits are expressed as percent by weight of the product as used. Eutrophication phosphorus limit is expressed as percent by weight of total phosphorus in the product as used. Concentration ratios are expressed as dilution ratios (1:32, 1:16) of concentrate to use solution.

Implications

• The comparison document records that GS-37’s by-name heavy-metal prohibitions in product formulation narrowed substantially between the Third Edition (2006: eight named metals — As, Pb, Cd, Co, Cr, Hg, Ni, Se) and the Fourth Edition (2008: three named metals — Pb, Cr-VI, Se), while heavy-metal coverage was simultaneously broadened in scope by the addition of a wholly new Packaging Heavy Metal Restrictions sub-clause with a 100 ppm sum-of-concentrations numerical ceiling on lead, mercury, cadmium, and hexavalent chromium in primary packaging. Downstream HMI synthesis citing GS-37 as a regulatory floor for heavy metals in industrial and institutional cleaning products should make the by-edition and the formulation-vs-packaging distinctions explicit.
• The Fourth Edition’s introduction of hexavalent-chromium speciation (in both the Prohibited Ingredients product clause and the Packaging Heavy Metal Restrictions sub-clause) is the relevant speciation discipline change between editions. The Third Edition’s “chromium” prohibition covers all chromium species; the Fourth Edition’s “hexavalent chromium” prohibition is narrower as a matter of by-name coverage in the Prohibited Ingredients clause but operates alongside the Packaging hexavalent-chromium sub-clause and the underlying CMR-substance and skin-absorption criteria. Future HMI synthesis treating GS-37 as a chromium reference should default to “chromium” (umbrella) when citing the Third Edition by-name prohibition and to “hexavalent chromium” specifically when citing the Fourth Edition by-name prohibition or the Fourth Edition Packaging sub-clause.
• The comparison document is the comparison artefact, not the binding standard text in either edition. HMI sessions that require the operative GS-37 numerical heavy-metal limits in either edition should consult the underlying standard editions (GS-37 Third Edition February 27, 2006, and GS-37 Fourth Edition August 29, 2008, both available from Green Seal). The sibling KADC file Green_Seal_GS-37_Industrial_Institutional_Cleaners_2024.pdf (present in the same KADC folder but not yet ingested) is the post-2008 standard text (current as of 2024); that document is a separate source candidate for the operative Green Seal standard.
• This document is not a primary source for any contamination distribution, occurrence value, or threshold-setting analysis. It is a programme-administration document recording a standard’s between-edition diff. HMTc threshold-setting work on industrial and institutional cleaning product categories should treat this comparison as upstream regulatory context, not as a literature contributor to per-analyte percentile calculations.

Limitations

• Comparison artefact, not binding standard text. The document states explicitly on p. 1 that “This is not the complete standard or criteria, but rather differences between the two versions. Please refer to the complete standard for exact criteria and the list of acronyms and abbreviations.” The reproduced criterion text on every interior page is selected to display what changed between editions, not to be the operative rule text. HMI sessions that need the operative GS-37 rule must read the underlying standard edition itself.
• No original measurements and no by-product contamination values. The document contains no original sampling, no analytical measurement, no contamination distribution, no by-product occurrence values. It documents what the standard requires, not what products actually achieve. Any HMI session reasoning about how many cleaning products meet the GS-37 numerical limits in either edition must consult Green Seal’s certification database or independent occurrence surveys, not this document.
• One explicit heavy-metal numerical limit only. The single explicit heavy-metal numerical limit in this comparison is the Fourth Edition Packaging Heavy Metal Restrictions sub-clause’s 100 ppm sum-of-concentrations ceiling on the four named metals (Pb + Hg + Cd + Cr-VI) in primary packaging. All other heavy-metal coverage in either edition is binary prohibition or class-membership gating via the broader criterion families (asthmagen, CMR, skin sensitization, skin absorption, acute toxicity, inhalation toxicity, aquatic toxicity, bioaccumulating compounds). Element-specific numerical concentration ceilings in the formulated product itself are not reproduced in this comparison document; they may or may not exist in the underlying standard text.
• Dated 2009; standard has since been further revised. The comparison documents Third Edition (2006) and Fourth Edition (2008) only. Green Seal has since issued further revisions to GS-37 (a 2024 edition file is present in the same KADC folder, Green_Seal_GS-37_Industrial_Institutional_Cleaners_2024.pdf). HMI sessions citing the current GS-37 must consult the most recent edition, not this 2009 comparison of the 2006 and 2008 editions.
• Heavy-metals silences in non-Prohibited-Ingredients clauses are silences, not denials. The Prohibited Ingredients clause in either edition is the by-name heavy-metal coverage. The Acute Toxicity, Skin Sensitization, Skin Absorption, Inhalation Toxicity, Toxicity to Aquatic Life, Bioaccumulating Compounds, and CMR clauses operate at the substance / criterion level and capture heavy-metal compounds whose harmonised classifications trigger those criteria (without naming the metals individually). Reading this comparison as evidence that, e.g., cadmium is not covered by Fourth Edition GS-37 outside of the Packaging sub-clause would be incorrect: cadmium compounds with CMR classifications, acute-toxicity classifications, or aquatic-toxicity classifications are still gated by those clauses, independent of by-name listing in Prohibited Ingredients.
• No CAS numbers or speciation depth for the named metals. The Prohibited Ingredients clauses name metals at the element level only (“lead”, “mercury”, “cadmium”, “hexavalent chromium”, etc.) without CAS numbers. The Fourth Edition introduces “either in the elemental form or compounds” as a speciation qualifier on the three Fourth Edition Prohibited Ingredients metals (Pb, Cr-VI, Se) but does not enumerate compound classes. HMI sessions interpreting the metal coverage must default to broad coverage absent narrower specification in the underlying standard text.
• C-tier qualitative source. Evidence tier C because: (i) programme-comparison document, not the binding standard text in either edition; (ii) no original measurements, no analytical methods used by Green Seal in compliance verification, no contamination values; (iii) the single explicit heavy-metal numerical limit (Packaging 100 ppm sum) is reproduced from the Fourth Edition standard, not generated by this document; (iv) the underlying standard editions (GS-37 Third Edition 2006 and GS-37 Fourth Edition 2008) are the binding texts and would carry higher tier if separately ingested. Tier matches sibling EU Ecolabel programme-context pages ec2024-eu-ecolabel-user-manual-detergents, jrc2025-eu-ecolabel-revision-detergents-tr2-ahwg2, ral2024-eu-ecolabel-factsheet-household-detergents, eeb2022-eu-ecolabel-30-year-briefing.

Provenance

• Source PDF: raw/manual-fetch/Kimi_Agent_Download Corruption Issue/household_papers/06_Regulatory_EPA_GreenSeal/Green_Seal_GS-37_Comparison_2009.pdf
• SHA-256: 882f58db9cecbe0edf2ce9e3e7289ce60f7a0e20a959f48ae1d39718ce858de2
• File size: ~109 KB; 18 pages of side-by-side tabular content with revised text highlighted in red.
• Publisher: Green Seal, Inc. (US-based independent non-profit environmental certifier).
• Document date: August 29, 2009 (cover header).
• Document title: “Version Comparison of Green Seal’s Environmental Standard for Industrial and Institutional Cleaners, GS-37 — Third Edition from 2006 vs. Fourth Edition from 2008”.
• Underlying standard editions documented in the comparison: GS-37 Third Edition (February 27, 2006) and GS-37 Fourth Edition (August 29, 2008).
• DOI: none assigned (programme documentation).
• License: © 2009 Green Seal, Inc.; redistributable as standard programme documentation under the Green Seal scheme.
• Access date: 2026-06-03.
• Acquisition path: included in the Kimi Agent Download Corruption Issue (KADC) folder household_papers/06_Regulatory_EPA_GreenSeal/, alongside ec2024-eu-ecolabel-user-manual-detergents (EU Ecolabel user manual for detergents and cleaning products), ral2024-eu-ecolabel-factsheet-household-detergents (EU Ecolabel consumer factsheet), jrc2025-eu-ecolabel-revision-detergents-tr2-ahwg2 (JRC TR2 consultation deck for EU Ecolabel criteria revision), eeb2022-eu-ecolabel-30-year-briefing (EEB NGO briefing on EU Ecolabel), epa2024-safer-choice-standard-dfe (U.S. EPA Safer Choice Standard), epa2024-safer-choice-master-criteria-ingredients (U.S. EPA Safer Choice Master Criteria for Safer Ingredients), davidsuzuki2014-toxic-household-cleaners (David Suzuki Foundation household-cleaners report), Green Seal GS-37 (2024 standard edition), Green Seal GS-52 (specialty household cleaners), Green Seal GS-8 (household cleaners), NIOSH HHE 2015-0053 (hospital cleaning), California SB258 right-to-know factsheets, NY State Cleaning Product Disclosure Programme, WECF Women and Chemicals briefing, and Bello et al. 2009 occupational exposures in cleaning.

Wiki pages this source may touch

• all-purpose-cleaners — within the GS-37 scope in both editions (“Industrial and institutional general-purpose … cleaners”, p. 1). Routed as regulatory_context: the Third-Edition Prohibited Ingredients clause names As/Pb/Cd/Co/Cr/Hg/Ni/Se; the Fourth-Edition Prohibited Ingredients clause names Pb/Cr-VI/Se; the Fourth-Edition Packaging Heavy Metal Restrictions sub-clause sets the 100 ppm sum-of-concentrations ceiling on Pb+Hg+Cd+Cr-VI in packaging. The product slug is the closest HMI taxonomy match to “general-purpose cleaners.”
• bathroom-tub-tile-cleaners — within the GS-37 scope in both editions (“Industrial and institutional … bathroom … cleaners”, p. 1; “Bathroom cleaners” performance criterion at p. 1). Routed as regulatory_context. Same Prohibited Ingredients and Packaging heavy-metal coverage as above.
• window-glass-mirror-cleaners — within the GS-37 scope in both editions (“Industrial and institutional … glass … cleaners”, p. 1; “Glass cleaners” performance criterion at p. 2). Routed as regulatory_context. Same heavy-metal coverage.
• carpet-cleaners — within the GS-37 scope in both editions (“Industrial and institutional … carpet cleaners”, p. 1; “Carpet cleaners” performance criterion at p. 2). Routed as regulatory_context. Same heavy-metal coverage.
• carpet-spot-removers — added to GS-37 scope in Fourth Edition only (“Carpet spot cleaners added”, p. 1). Routed as regulatory_context. Fourth Edition Prohibited Ingredients (Pb/Cr-VI/Se) and Packaging Heavy Metal Restrictions (Pb+Hg+Cd+Cr-VI sum ≤100 ppm) apply; Third Edition did not cover this product type.
• toilet-bowl-cleaners — added to GS-37 scope in Fourth Edition only (“Toilet bowl cleaners added”, p. 1). Routed as regulatory_context. Fourth Edition Prohibited Ingredients and Packaging Heavy Metal Restrictions apply; Third Edition did not cover this product type. Note: GS-37 also addresses water-hardness-removal efficacy for products labelled for toilet bowl or urinal cleaning (p. 1, Product Performance Testing).
• lead — named in BOTH editions’ Prohibited Ingredients clauses (Third Edition list: As, Pb, Cd, Co, Cr, Hg, Ni, Se; Fourth Edition list: Pb, Cr-VI, Se) and in the Fourth Edition Packaging Heavy Metal Restrictions sub-clause (Pb among the four named metals subject to the 100 ppm sum ceiling). Routed as regulatory_context.
• mercury — named in the Third Edition Prohibited Ingredients clause and in the Fourth Edition Packaging Heavy Metal Restrictions sub-clause; NOT by-name named in the Fourth Edition Prohibited Ingredients clause (which narrowed to Pb/Cr-VI/Se). Routed as regulatory_context. The by-edition coverage shift is the relevant note: by-name product prohibition in 2006 only; by-name packaging prohibition added in 2008.
• cadmium — named in the Third Edition Prohibited Ingredients clause and in the Fourth Edition Packaging Heavy Metal Restrictions sub-clause; NOT by-name in Fourth Edition Prohibited Ingredients. Routed as regulatory_context. Same by-edition coverage shift as mercury.
• chromium-hexavalent — named in the Fourth Edition Prohibited Ingredients clause (“hexavalent chromium … either in the elemental form or compounds”) and in the Fourth Edition Packaging Heavy Metal Restrictions sub-clause. Routed as regulatory_context. The speciation discipline (Cr → Cr-VI) is introduced in the Fourth Edition.
• chromium — named in the Third Edition Prohibited Ingredients clause (without hexavalent specification). Routed as regulatory_context. The Third Edition broader-chromium prohibition was narrowed to hexavalent chromium specifically in the Fourth Edition.
• arsenic — named in the Third Edition Prohibited Ingredients clause; NOT by-name in Fourth Edition Prohibited Ingredients or Packaging clauses. Routed as regulatory_context. The by-edition coverage shift removes arsenic from the by-name list between 2006 and 2008.
• nickel — named in the Third Edition Prohibited Ingredients clause; NOT by-name in Fourth Edition Prohibited Ingredients or Packaging clauses. Routed as regulatory_context. Same by-edition shift.
• cobalt — named in the Third Edition Prohibited Ingredients clause; NOT by-name in Fourth Edition Prohibited Ingredients or Packaging clauses. Routed as regulatory_context. Same by-edition shift.

Verification notes

• Identity-check results on 2026-06-03 against wiki/sources/: DOI null (programme documentation, no DOI assigned); raw_handle grep for KADC_green-seal-gs-37-comparison-2009 returned no matches; cite-key grep for variants greenseal2009, greenseal-gs37, gs-37, gs37-comparison, and green-seal-gs-37 returned no existing matches; broader green-seal and greenseal substring scan in wiki/sources/ returned no GS-37, GS-52, or GS-8 source page (the only “green” hits in wiki/sources/ are unrelated tea, Greenland mercury isotopes, and Greenpeace papers — none are Green Seal documents). Ingested as NEW. Sibling Green Seal documents (GS-37 2024 standard edition, GS-52 specialty household cleaners 2022, GS-8 household cleaners 2022) are present in the same KADC folder but are not yet ingested; they would be separate NEW source pages.
• SHA-256 of the source PDF was computed from disk on 2026-06-03 (882f58db9cecbe0edf2ce9e3e7289ce60f7a0e20a959f48ae1d39718ce858de2).
• The document has no DOI (programme comparison document, not a journal article). doi is null and no_doi_assigned: true.
• Evidence tier set to C on the basis of: (i) programme-comparison document, not the binding GS-37 standard text in either edition; (ii) no original measurements, no analytical methods, no contamination values; (iii) the document’s one explicit heavy-metal numerical limit (Packaging 100 ppm Pb+Hg+Cd+Cr-VI sum) is reproduced from the Fourth Edition standard, not generated by this comparison; (iv) the underlying standard editions are the binding texts and would carry higher tier if separately ingested. Tier matches the sibling EU Ecolabel programme-context pages in the same KADC folder.
• Source type set to regulatory-standard-comparison. The document is a side-by-side comparison of two editions of a third-party voluntary certification standard. It is not a peer-reviewed paper, not a Commission Decision or government regulation, not an NGO briefing, not a consultation deck, not a user manual, and not the binding standard text itself. regulatory-standard-comparison is the most accurate label.
• License set to ”© 2009 Green Seal, Inc. (programme documentation; redistributable as standard programme documentation under the Green Seal scheme)“. Green Seal programme documentation is routinely redistributable as standard programme materials.
• metals: ["[[metals/lead]]", "[[metals/mercury]]", "[[metals/cadmium]]", "[[metals/chromium-hexavalent]]", "[[metals/chromium]]", "[[metals/arsenic]]", "[[metals/nickel]]", "[[metals/cobalt]]"] because every metal in this list is by-name named in at least one of the two editions’ Prohibited Ingredients clauses or the Fourth Edition Packaging Heavy Metal Restrictions sub-clause. Both chromium and chromium-hexavalent are included because the by-edition speciation shift is relevant: the Third Edition Prohibited Ingredients clause names “chromium” without speciation (umbrella [[metals/chromium]]); the Fourth Edition Prohibited Ingredients clause and Packaging sub-clause name “hexavalent chromium” specifically ([[metals/chromium-hexavalent]]). Selenium is named in BOTH editions’ Prohibited Ingredients clauses (Third and Fourth) but is NOT in HMI’s metal taxonomy snapshot (selenium is not a slug under wiki/metals/); selenium is therefore omitted from the metals: array per CLAUDE.md Part 14 (taxonomy slugs only) and surfaced as a missing-slug observation below. 2-butoxyethanol and phthalates are organic-substance additions to the Fourth Edition Prohibited Ingredients and Packaging clauses, not metals; they are not added to the metals: array.
• ingredients: [] because the source is a programme-comparison document that names categories of substances (heavy metals, alkylphenol ethoxylates, dibutyl phthalate, ozone-depleting compounds, optical brighteners, 2-butoxyethanol, phthalates, etc.) but not food or personal-care ingredients in HMI’s ingredient taxonomy (which is a food-ingredient taxonomy per the taxonomy snapshot). No new ingredient pages are created (per skill hard constraints).
• products lists six existing product slugs covering the GS-37 scope: all-purpose-cleaners (closest match to “general-purpose cleaners”); bathroom-tub-tile-cleaners (bathroom cleaners); window-glass-mirror-cleaners (glass cleaners); carpet-cleaners (carpet cleaners); carpet-spot-removers (carpet spot cleaners, added in Fourth Edition); toilet-bowl-cleaners (toilet bowl cleaners, added in Fourth Edition). All six slugs already exist in wiki/products/ per the taxonomy snapshot; no new product pages created (per skill hard constraints). Note: GS-37 is for “industrial and institutional” cleaners specifically; HMI’s current product taxonomy does not have institutional/industrial-specific slugs for these product types, so the household/general slugs are routed as broad regulatory_context. The Fourth Edition’s “restroom cleaners” (in the VOC table) is mapped to bathroom-tub-tile-cleaners as the closest HMI taxonomy match.
• matrices: [] because the source is a multi-product-category programme-comparison document without a single matrix focus. No new matrix slug is proposed.
• jurisdictions: [US] because Green Seal, Inc. is a US-based non-profit (founded 1989 in Washington DC) and GS-37 is a US voluntary environmental standard. Green Seal certifications are accepted internationally but the standard itself is published from a US programme.
• near_duplicates: [] because no other Green Seal source pages exist in wiki/sources/ and this comparison document is the only between-edition diff for GS-37 in the KADC folder. The 2024 GS-37 standard edition file, GS-52 specialty household cleaners 2022 file, and GS-8 household cleaners 2022 file are sibling documents in the same KADC folder; they would be separate-source-page candidates rather than near-duplicates if ingested.
• Wiki/HMTc firewall (Part 2): the comparison document does not propose threshold values for HMTc certification, and this page’s Implications section does not propose any. GS-37 is referenced as upstream regulatory context with explicit caveats that this document is the between-edition comparison rather than the binding standard text. The Fourth Edition’s 100 ppm packaging-metals sum ceiling is reproduced from the Fourth Edition standard as a regulatory fact; this page makes no claim that the 100 ppm sum is a science-based HMI synthesis value or an HMTc threshold proposal. No Part 2 drift risk.
• Brand firewall (Part 12): the comparison document does not name any commercial brand of cleaning product. It names test-method identifiers (ASTM standards, ISO standards, OECD test guidelines, OPPTS guidelines, CARB Method 310), regulatory and standards bodies (Green Seal, FDA, EPA, ACGIH, DFG, European Chemicals Bureau, OECD, CARB, Society of the Plastics Industry, ASTM, ISO, FIFRA, CSPA, GREENGUARD), CAS-identified or named-substance classes (alkylphenol ethoxylates, dibutyl phthalate, 2-butoxyethanol, phthalates, ozone-depleting compounds, optical brighteners), and the GREENGUARD Children and Schools certification programme (cited as a test-method reference for the Fourth Edition Inhalation Toxicity > Chamber Testing pathway, not as a brand attribution to contamination). Per CLAUDE.md Part 14 (Exception 2 — Scientific-method vendor/material names locked 2026-05-17), test-method identifiers and standards-body / programme references are scientific-method references, not commercial brand attribution to contamination values. No brand-firewall action required.
• Quantitative content reproduced on this page (Prohibited Ingredients named-metal lists for both editions, Fourth Edition Packaging Heavy Metal Restrictions 100 ppm Pb+Hg+Cd+Cr-VI sum ceiling, VOC limits by product-category, acute oral LD50 5,000 vs 2,000 mg/kg cutoff, dilution ratios 1:32 / 1:16, Inhalation Toxicity NOAEL/LOAEL thresholds, Bioaccumulating Compounds BCF >100 / log BCF >2, Eutrophication 0.5% phosphorus, Combustability 150 °F flashpoint, post-consumer-material 25%) is reproduced from the source PDF (pp. 1-18) with page locators. No numerical heavy-metal limits beyond the Packaging 100 ppm sum are stated in the source and none are claimed here.
• No new ingredient, product, or matrix pages were created during this ingest, per CLAUDE.md Part 10 and the skill’s hard constraints. All product slugs in the frontmatter are existing taxonomy.
• Missing-slug observations surfaced for Karen (not created by this ingest; for future Step 0 Lock or auto-stub decisions):
  • metals/selenium — named in BOTH editions of GS-37 Prohibited Ingredients (“Heavy metals including … selenium” in Third Edition; “Heavy metals including … selenium” in Fourth Edition). Selenium is not currently in HMI’s metal taxonomy snapshot. If a wiki/metals/selenium.md page were created, this source would be a regulatory_context contributor.
  • regulations/green-seal-gs-37 — the underlying GS-37 standard editions (Third Edition February 27, 2006, Fourth Edition August 29, 2008, and post-2008 revisions including the 2024 edition file present in this KADC folder). Green Seal’s industrial and institutional cleaner standard is the operative regulatory document; this comparison artefact references it but is not the binding text. No regulations/green-seal-* slugs currently exist.
  • regulations/coneg-model-toxics-in-packaging-1989 — the U.S. Coalition of Northeastern Governors Model Toxics in Packaging Legislation (1989) sets the same 100 ppm sum-of-concentrations ceiling on the same four metals (Pb + Hg + Cd + Cr-VI) in packaging that the Fourth Edition GS-37 Packaging Heavy Metal Restrictions sub-clause adopts. The CONEG model legislation has been adopted by 19+ US states. Not referenced by name in this comparison document, but the structural and numerical parallel is direct.
  • regulations/eu-directive-94-62-ec-packaging — EU Directive 94/62/EC Article 11 sets a 100 ppm sum-of-concentrations ceiling on the same four metals in packaging in the EU. Not referenced by name in this comparison document but is the parallel international regulation for the same metals-in-packaging mechanism.
  • products/restroom-cleaners — referenced in the Fourth Edition VOC limits table (Table p. 5) as a distinct category from bathroom cleaners. HMI’s current taxonomy maps both to bathroom-tub-tile-cleaners; if a separate restroom-cleaners slug were desired (industrial / institutional restroom-cleaner category as distinct from household bathroom-tub-tile cleaner), the slug does not currently exist. Not created here. None of those underlying regulations or alternate slugs are created here. The HMI metal selenium page in particular is a freq-2 candidate (named in both editions of GS-37) but the auto-stub script handles ingredient stubs only, not metal stubs; new metal pages are Karen’s decision.
• The post-2008 GS-37 standard text (sibling KADC file Green_Seal_GS-37_Industrial_Institutional_Cleaners_2024.pdf) is not ingested by this Phase-1 ingest of the 2009 comparison document. If the 2024 standard text is later ingested, it would be a higher-tier (B-tier) source for the operative current GS-37 heavy-metal limits; this 2009 comparison document would remain the by-edition historical-diff artefact for the 2006 vs 2008 transition.
• The PDF is 18 pages of side-by-side tabular content. All 18 pages were read in full during ingest (pp. 1-9 in the first read pass, pp. 10-18 in the second). The full text of revised criterion language (red text in source) was captured. No part of the PDF was skipped.
• This page is manual_phase1 ingest by Claude Opus 4.7 on 2026-06-03.
• Audit subagent (fresh-context general-purpose subagent, 2026-06-03) returned verdict REVISE with two findings; verified independently against the PDF and applied:
  • Finding 1 (Check 5 housekeeping ⚠️): Implications bullet 3 contained a self-referential wikilink [[sources/greenseal2009-gs37-version-comparison]] where the intent was to point to the sibling 2024 GS-37 standard PDF in the same KADC folder. Verified self-reference against the page; corrected to a plain file-name reference (Green_Seal_GS-37_Industrial_Institutional_Cleaners_2024.pdf) without a wikilink, since that document is not yet ingested as a wiki source page.
  • Finding 2 (Check 1 ⚠️): Key-numbers VOC row label “bathroom/restroom cleaners” was a cross-edition cell-mapping that obscured the by-edition labelling shift in the source PDF (3rd Ed uses combined “general-purpose and bathroom”; 4th Ed uses “restroom” terminology). Verified against PDF p. 5; tightened both VOC rows (general-purpose, and bathroom (3rd Ed) / restroom (4th Ed)) to make the by-edition cell-mapping explicit. Numerical values unchanged.
  • Audit checks 2, 3, 4, and 5 (slug vocabulary, speciation/methods, Part 12 brand firewall, Part 2 wiki/HMTc firewall): all ✅ clean per subagent verdict; no changes needed. Check 1 numerical fidelity was substantively ✅ with three ⚠️ flags, two of which were source-typography variants documented but not errors (ISO 7346.2 vs 7346-2 in source; OECD 305 wording trim), and one of which was the VOC row-label tightening applied above. No numerical claims on the page were found to be wrong against the PDF.

Page history

The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.