Tracking the purchase of environmental products is the most difficult part of the job. Tracking is complex because products are purchased using a variety of purchasing systems: purchasing cards, purchase requests, purchasing agreements, sub-contracts, etc. We need to gather data from each of these systems.

To gather data from a sub-contract, the requirement for the sub-contractor to report (what to report and due date) needs to be built into the contract and purchase agreement.

To gather data from purchasing card and purchase request purchases, we have two possibilities: suppliers can track for you or you can track using your organization's purchasing system software. Both have advantages and disadvantages. When suppliers track, they will capture accurate data but will not be able to capture the CAP: the cost, availability, and performance justified exceptions why your staff were not able to purchase certain products with the specified attributes. Also, some small businesses are sometimes challenged to track and report each and every product purchased. When your organization tracks, you usually can capture the CAP but suffer from the "garbage in garbage out" principle. Typically when the purchaser tracks, it relies on the person (perhaps hundreds of purchase card holders) to reliably denote whether the product they purchased contained the specified attribute or not.

When tracking the justified exception purchases (products your organization was not able to purchase with recycled/biobased content, EPEAT registered, energy efficient), be sure to document those exceptions. Such documentation might be needed should your site be audited for compliance with environmental purchasing requirements.

Some examples of tracking systems at DOE sites are:

• Paducah Site set up their financial system, Deltec, to use commodity codes to track designated product purchases. A commodity code is assigned to each item. If this item meets EPP requirements, then it also is assigned a trans code of 86. The Deltec system can produce reports of what products are purchased and which purchased products meet the EPP requirements.
  
• Strategic Petroleum Reserve (SPR) is using the SAP financial software to manage their procurement inventories. The SAP system consists of a master catalog that flags items that are EPP designated. To request a purchase, a keyword search must be performed for each product. Before a product can even be sent for approval, a set of questions must be answered regarding EPP requirements, which can then be tracked using the custom data tab. This SAP system eliminates the need for a paper trail because everything can be done electronically. For details, see the SPR presentation on tracking using SAP.