United States Environmental Protection Agency Solid Waste and Emergency Response (OS-305) EPA530-N-92-005 Fall 1992 FTC Announces Environmental Marketing Guidelines for Industry On July 28, the Federal Trade Commission (FTC) issued guide- lines for use by companies that choose to market their products and packaging as environmentally benefi- cial—a trend that has been growing in recent years. These guidelines are intended to help reduce consumer confusion and aid manufacturers in responsibly advertising the environ- mental attributes of their products and Dackaging. According to EPA Admin- istrator William K. Reilly, reliable product information will assist con- sumers in harnessing the formidable power of the marketplace to help achieve environmental goals. In announcing the guidelines, FTC lhairperson Janet D. Steiger said, |"Our goal is to protect consumers and to bolster their confidence in environmental claims, and to reduce manufacturers' uncertainty about which claims might lead to FTC aw-enforcement actions, thereby encouraging marketers to produce and promote products that are less harmful to the environment." Steiger also noted the extensive cooperation, expertise, and support FTC received rom EPA in the development of the guidelines. EPA, FTC, and the U.S. Office of Consumer Affairs (OCA) are part of an nteragency Environmental Marketing (Continued on page 8) 1992 MSW Characterization Reveals Substantial Increase in Recovery Rates There is both encouraging and so- bering news in the latest EPA as- sessment of the nation's residential and commercial waste. The percentage of municipal solid waste (MSW) recov- ered from the nation's waste stream for These latest statistics come from Characterization of Municipal Solid Waste in the United States: 1992 Update, which was recently released by EPA. Based on data collected through 1990, the update reports ecovery Rates for Some MSW Components by Weight recycling and composting^ increased from 13 percent in 1988 to 17 percent in 1990. This increase is due to the combined efforts of individuals, busi- nesses, industry, and governments. Despite this good news, Americans still threw away more garbage than ever. The total amount of MSW increased from 180 million tons jn 1988 to 196 million tons in 1990, which means the per capita rate jumped from 4.0 to 4.3 pounds per person per day. MSWgeneration, disposal, and recov- ery rates from the past 30 years and projects figures for 1995 and 2000. A newstatisticappearingintheupdateis an estimate of residential versus com- mercial sources of MSW. Residential sources are estimated to make up 55 to 65 percent of the MSW stream, while commercial sources are esti- mated at 35 to 45 percent. (Continued on page 8) Reusable News is printed with soy/canola ink on paper that contains at least 50 percent recycled fiber. ------- EPA Clarification: MWC Ash Not a Hazardous Waste under RCRA On September 18,1992, EPAclari- fied its position that ash gener- ated by solid waste-to-energy incinerators (MWC ash) is not consid- ered hazardous waste. EPA has de- cided that regulating this ash as a nonhazardous solid waste is the proper interpretation of the federal Resource Conservation and Recov- ery Act (RCRA). EPA also has deter- mined that its new municipal solid waste landfill requirements will en- sure that the disposal of MWC ash is protective of human health and the environment. EPA clarified its position for two reasons. First, a Clean Air Act mora- torium preventing hazardous waste regulation of MWC ash ended on November 15, 1992. Second, in a related court case, the U.S. Su- preme Court requested the opinion of the United States on the regula- tion of MWC ash. For more information or to order a copy of the Policy Directive (#9573.00-01) that describes EPA's position, call the RCRA/Superfund Hotline (see the "Hot Off the Hotline" box on page 6).l Minnesota Mall Debuts with In-House Recycling Facility ineusable News is the if quarterly newsletter of the EPA Office of Solid Waste's Mu- nicipal and Industrial Solid Waste Division. Reusable News reports on the efforts of EPA and others to safely and effec- tively manage the nation's gar- bage and provides useful information about key issues and concerns in municipal solid waste management. 2 Address comments or suggestions to: John Leigh, Editor (OS-305) U.S. Environmental Protection Agency 401 M Street, SW. Washington, DC 20460 MALLOFAlBERICA Mall of America in Bloomington, Minnesota, which opened in Au- gust 1992, is the first shopping center to incorporate a complete recycling system in-house. According to devel oper Melvin Simon & Associates, thl mall is the nation's largest shoppinl and family entertainment compleJ combining 400 stores and a 26-rid| theme park under one roof. Mall America generates 900 tons of rec> clable materials per month, as mucj as a small city. (Continued on page i Clearing the Air EPA Develops New Materials on Leaf Burning With a flash of his black cloak, a magician transforms a pile of leaves into a dark humus. "Why burn your 'leaves, which creates air pollution, when you can recycle them into beneficial com- post? "he queries. This is one of the ^M-.;.:.;:; concepts underconsid- '&£££; .. e ii- .;;/••>-'•,'MyflftXV eration for a new public ^ service announcement lja! (PSA) video on leaf burning being devel- oped by EPA. While burning of leaves, brush, and other yard trimmings may occur in some communities, the nuisance and health and safety effects can be severe. Edu- cating individuals about the impact of leaf burning and offering some alterna- tives is the goal of the TV and radio PSAs, a new brochure, and a fact sheet EPA is producing for release this year. Along with hundreds of communi- ties across the country, EPA is con- cerned that citizens may choose to burn their collected leaves, especially in areas that have enacted bans on landfill disposal of yard trimmings. Burning leaves results in the release of pollutants that can aggravate a range of respiratory ailments, includ- ing asthma, emphysema, and aller- gies. In addition, leaf burning may pose a fire hazard. The TV and radio spots are in- tended to educate the public about these effects, and may include a few tips on backyard composting as an alternative to burning. In addition, EP is developing educational literatim on leaf burning. A fact sheet is beinc produced that details the healtt effects of leaf burninc and lists other possible means of manage ment. A brochure also is being developec urging citizens tc take responsibility for keeping thei neighborhoods fret from leaf burning Both of these material! are designed to provid additional informatior to individuals reachec by the PSAs. These materials wi be distributed to regions of the countr that have banned the disposal of yarc trimmings in landfills. EPA is joining witt the U.S. Department of Agriculture anc its educational arm, the Cooperative Extension Service, to increase the effi- ciency of the distribution. EPA hopes tc have the Extension Service help dis tribute the materials, and many of th items will refer to the local Extensio Agent for more information. With a office in virtually every county in t United States, the Extension Servi will be of great assistance in educating Americans about the effects of lea burning. For more information about these new materials, call Scott Voorhees o EPA at (919) 541 -5348, or write to hirr at the U.S. Environmental Protectior Agency, Office of Air Quality Planning and Standards, MD-15, Research Tri angle Park, NC 27711.1 ------- Federal Government Leads by Example as Host of Recycled Products Trade Fair New softballs made from old ones, rags for computer screens manufactured from recycled diapers, toilet paper and paper cups created from shredded documents, pencils made from cormgated cardfeard and old newspa- pers, and even guitars fashioned from plastic containers. These items were just a few of the recycled wares on display at the Government Buy Recycled Products Trade Fair and Showcase held in Washington, DC, on June 29 and 30. The purpose of the trade fair was to educate govern- ment officials about available products made from recycled materials, to convince vendors that the government is committed to buying such products, and to help vendors better understand the procurement process. "We have $190 billion in buying power that we can use to close the loop," explained Gail Wray, the Federal Recycling Coordi- nator and chairperson of the steering committee that planned the trade fair. More than 200 disjributojs ajnj£ manufacturers exhibited products made from recycled materials (in- cluding paper, wood, metal, plas- tic, glass, and rubber). Over 3,000 individuals from federal agen- cies, state governments, and uni- versities came to see these innovative products, to hear speakers such as EPA Adminis- trator William K. Reiljy and Department of the Interior Secre- tary ManuelLujan, and to learn about federal purchasing of such products. As a result, the federal govern- ment began negotiations with several businesses to purchase products made from recycled materials. One of the businesses manufactures lightweight deco- rative wall boards, bulletin boards, carpet cushioning, pack- aging, and other materials made from 100 percent recycled news- print. Another business is explor- ing the possibility of collecting plastic shrink wrap removed from office supplies and other prod- ucts used by the federal govern- ment. The company would use the plastic shrink wrap in its manufacture of office trash con- tainers; some of these containers might, in turn, be sold back to the government. Many recycled products, in- cluding some of those shown at the trade fair, are listed in the Recycled Products Guide compiled by the General Serv- ipes Administration (GSA) for federal procurement off icials. For information on how to obtain this guide, call the GSA Centralized Mailing List Service at (817) 334-5215. The trade fair was sponsored by several federal agen- cies, including EPA, GSA, the Office of Management and Budget, the Council on Environmental Quality, and the Department of Defense. Cosponsors included the Tennes- see Valley Authority, Department of Agriculture, Depart- ment of the Interior, and Department of Energy. The fair is part of an overall procurement strategy launched on Octo- ber 31, 1991, when President Bush signed an Executive Order directing federal agencies to accelerate programs to buy products made from recycled materials. For more information, contact the Office of Federal Recycling at (202) 266-6980. fi TMi "8UY RiCYCH®" QUIZ! The products below, which were displayed at the trade fair, were all manufactured from recycled materials. Guess what each product is and from what recycled material it was made. •sai]} dejos uiojj 6uuoo|j juaqjosqe >|oons 'V 'saxoq pajeBnuoo wojj l • 'saji; dejos.wojj s>poi|o |aai)M '2 'sauioq epos oijse|d UJDJJ Buijadjeo '\. ------- Focus on icitlar Ready to Roll Again: Recycled Rubber Required in Future Roads Scrap tires will soon find new life by being recycled into paving for roads they once travelled. The Intermodal Surface Transports Efficiency Act (ISTEA), enacted in December1991, requires states to pave roads with asphalt that contains recycled scrap tire rut or other recycled materials. Asphalt containing used rubber has become more common as policymakers seek to stimulate markets recycled scrap tires. Starting in 1994, five percent of federally funded roads paved with asphalt must contain recycled scrap tire rubber. The percentag roads containing recycled scrap tire rubber required will increase by 5 percent each year until 1997, when the requirement reache" percent. In addition to using recycled rubber, states can fulfill a portion of the requirement with other approved recycled materials. The Federal Highway Administration (FHWA) has the authority to withhold federal highway funds if a particular state fails to comply with this requirement. As required by ISTEA, EPAand FHWAare conducting a joint study examining the economic and environmental impacts and the technical performance of recycled materials in asphalt. The final report is due in June 1993. For more information, contact Bruce Peirano of EPA's Office of Research and Development at (513) 569-7540 or Lou Papet of FHWA at (202) 366-1324. T: Bhe ende; Chrysler ' ' held a forum on March 1 public. Atthe forum, VHP activities in vehicle recycling research collaboration with t VRP, formed in November 1991, will muster to develop automobile design and recycling tecf material from every scrap vehicle is recycled, ac VRP Management Committee. When a vehicl< most valuable parts to a dealer or collision she such as antifreeze and air conditioner refrigerar is then shredded, and the metal is sent to recy ------- line Turnpike Cashes in on Ticket Reuse Program early as the mid-1980s, directors of the Maine Turnpike Authority (MTA) saw the opportunity to implement a ticket reuse program >r their roadway. Late last year, that idea became reality, much to the delight of MTA. Rather than always issuing new paper toll > to drivers on the turnpike, MTA reuses tickets to the extent possible. • years, MTA has been recovering a small portion of operating costs by selling its used toll tickets for recycling. The new ticket reuse im continues the MTA custom of combining the ecologically sound with the economically sensible. MTA Deputy Executive Director ibby anticipates that MTA will reduce purchases of new tickets by 20 million per year through the reuse program. With 1,000-count ; of reused tickets costing over $4 less than boxes of new tickets, these reductions will translate n annual savings of about $100,000. I tickets are now collected from turnpike tollbooths and sentto a centralized sorting site, <•/ * tickets are separated by a bar-code system according to both vehicle type and point of ** }s Jonto the turnpike. The'tickets are then packaged and shipped back to the toll station Inated in their bar-code. Tickets that fail a paper quality test are immediately rejected he sorting process and recycled. iginally, Libby and his colleagues estimated that each ticket would tand two or three uses before wearing out. Much to their surprise, „ s are being reused an average of five to six times. Other states and ike systems are closely watching the outcome of Maine's ticket reuse am to determine its applicability to their own roadways. more information, contact Neil Libby of the Maine Turnpike Authority 17)871-7771. Car Manufacturers Shift ste Reduction Into High Gear Partnership (VRP), a collective >y General Motors, Ford, and 5 effective automobile recycling, luce its mission and goals to the > updated participants on current o their ideas regarding possible talent from a variety of sources tly, as much as 75 percent of the tokh Labana, Chairperson of the 'ie dismantler typically sells the [cture and resale. Excess fluids, ivered for recycling. The vehicle nains—primarily rubber, plastic, glass, and wire—is landfilled. It is these leftovers, called "fluff," that VRP is hoping will be recovered as a result of its efforts. VRP plans to establish vehicle design guidelines to make the entire automobile more recyclable. The guidelines may advocate design for easier disassembly and the use of uniform materials for some vehicle parts. This uniformity should avoid costly materials separation, thereby increasing the economic feasibility of recycling. By combining resources and systematizing work plans, the VRP member companies can streamline research and avoid duplicating projects, according to Labana. VRP's activities will be guided by a program committee comprised of representatives from automobile manufacturers, parts suppliers, recyclers, dismantlers, shredders, and other businesses involved in scrap vehicle recycling. Three project groups have been set up to examine proposed projects and evaluate their economic and technical viability. For more information, contact Santokh Labana of Ford Motor Company at (313) 594-7740. ------- Hot Off the Hotline uestion: If a household hazardous waste (HHW) col- . lection program accepts land mixes HHW and waste I from conditionally exempt;small quantity generators I (CESQGs), is thatimixture subject to the full hazardous waste "Subtitle C' requirements of the Resource; Conservation and Recovery Act (RCRA)? nswer: No. If state-approved collection programs mix HHW and waste from iCESQGs, the mixture is not subject to the 'full RCRA hazardous waste regulations. Thus HHW collection iprograms do not need to obtain expensive hazardous waste permits prior to accepting CESJ3G waste. EPA believes this will encourage recycling and reuse of CESQG waste through HHWicollection programs. EPA cautions, however, that'collectioniprograms must abide by any existing state requirements. ; Resources The following publications are available at no charge from the EPA iRCRA/Superfund Hotline. Call (800) 424- 9346, or TDD (800) 553-7672 for the hearing impaired, Monday through Friday, 8:30 a.m. to 7:30 p.m. EST. In Washington, DC, (the number is (703) 920-9810 or TDD (703) 486-3323. Characterization of Municipal Solid Waste in The United States: 1992 Update— Executive Sumniary (EPA530-S-92-019). This executive summary provides highlights from the latest of a series of reports characterizing the municipal solid waste (MSW) stream. A related fact sheet (EPA530-F-92-019) outlining the report is also available. A copy of the complete:update (PB92-207 166) is available from the National Technical Information Service ($27.00 for paper, $12.50 for microfiche) by calling (800) 553-6847,Monday through Friday, 8:30 a.m. to 5:30 p.m." "he update reports quantities (by weight and volume) of MSW generated, recovered, combusted, and landfilled for the past 30 years and projects figures fcr 1995 and 2000. ; No Hazardous Wsste Listing for UsediOil that Is Being Disposed (EPA530-F- 92-006). This env ronmental fact sheet explains why used oil being disposed of is not considered a hazardous waste, i Management Standards Issued To Control Potential Risks from Recycled Used Oil—No Hazardous Waste Listing (EPA530-F-92-018). This environmental fact sheet describes management standards for recycled used oil and explains why recycled used oil s not consideredia hazardous vj/aste. Did You Know? !n 1990, 73.3 million tons of paper and paperboard were discarded, making these materials the single largest component of the municipal solid waste (MSW) stream. While corrugated boxes made up nearly 1/3 of all the paper and paperboard in the MSW stream (newspapers were a distant second at less than 1/5), these materials also had the highest recovery rate of paper products at 48 percent. Once recovered, corrugated boxes are recycled into many different paper products, including tissue products, paperboard, construction paper, and liner board used to make more corrugated boxes. 5' Minnesota Mall Debuts with In-House Recycling Facility (Continued from page 2) The recycling facility, designed I Brownihg-Ferris Industries (BF| performs all phases of waste prc essing. "With so many stores art millions of visitors," explains BFI Rl gional Vice-President Steve Bentol "it takes a carefully designed, b| simple recycling system tearm with a motivational program to mal< it all work." To encourage shoppers to red cle, public recycling areas are l(| cated throughout the mall. Thes areas contain recycling bins ar serve as distribution sites for par phlets on recycling. Recycling st£ circulate on foot to carry recyclable from the public bins to the proces^ ing center. Retailers sort their commingle trash in designated "trash rooms" o each of the mall's four floors. A syj tem of chutes delivers the sorte materials to mechanical compactor in the mall's central service are* Compacted recyclables are the bailed and prepared for shipping. Fed by the collection staff and th system of chutes, the facility ca process 35 tons of material durin an eight-hour work shift. By provic ing immediate separation of waste the system reduces contaminatio| and increases resale value of rec; cled materials. The facility is pn jected to achieve an 80 percer recovery rate. Mall executives hope the shop ping center will serve as a state-o the-art model for in-house recycling providing a showcase to the public commercial developers, and go\ ernment officials. "To our know edge, no other shopping mall in th world has its own built-in recyclin center," says Herbert Simon, Pres dent of Melvin Simon & Associates BFI Chairman William Ruckelhau agrees, "This puts Mall of Americ on the leading edge of waste ha dling in this country." For more information on the recyl cling facility at Mall of America, cor tact Rick Doering of BFI at (61; 854-4978.1 ------- "Taking Action," is a Reusable News feature that spotlights the everyday efforts of individuals to reduce, reuse, and recycle in the home, office, and community. If you know of anyone who has made an innovative contribution to meeting the municipal solid waste challenge, but not as part of an environmental profession, please write John Leigh, Reusable News, Office of Solid Waste, U.S. EPA (OS-305), 401 M Street, SW., Washington, DC 20460. Joston Designer Helps Colleagues Shift to Recycled Papers t a 1988 meeting of the Boston chapter of the American Institute of Graphic Arts (AiGA), Claudia Thompson, a aphic designer from Cambridge, Massachusetts, proposed 3 idea of writing a short buyers' guide to recycled paper. The sponse was a unanimous, 'Yes!" Many of Thompson's col- igues had looked into buying recycled paper and discovered rt no comprehensive source of product information existed. jalizing that such a resource would make it easier for graphic signers across the country to effect a large-scale shift to cycled paper, Thompson decided to take action. Encouraged by AIGA's response, Thompson inde- jndently raised over $140,000 to fund the project and to ;tribute copies of the book of 7,000 AIGA members across 3 country. By 1992, what was to have been a 30-page guide id grown into a 200-page book entitled Recycled Papers: The Essential Guide. Published jointly by AiGA and the MIT Press, the book describes how recycled papers are made, explains the current definitions and standards for recycled paper, and provides detailed information on the types of recycled paper available. Thompson's purpose in writing Recycled Papers was to "...help all of us become informed buyers—in the hope that we will achieve a substantial increase in recycling rates for [printing and writing] papers." If early response to the book is any indication, she may well realize this goal. "The response has really been wonderfully warm," says Thompson, who was recently presented with an Environmental Leadership Award from the Cambridge Environmental Citizens' Organization. To order Recycled Papers: The Essential Guide ($25 pa- perback, $40 cloth), call the MIT Press at (800) 356-0343.1 :irst Ever Design Forum on the Environment ecognizing a growing need to de- velop environmentally sound design inciples, EPA recently awarded a grant the WORLDESIGN Foundation, Inc., public charity affiliated with the Indus- al Designers Society of America )SA). The grant helped to fund INTER- ESIGN '92, the first ever educational sign forum on the environment. Each year, INTERDESIGN work- lops bring together industrial design ofessionals from around the world to dress design questions facing the >st nation. Past workshop themes ive ranged from homes for the el- rly to safer faci lilies for wi nter spo its. This year's workshop, held August 16 at San Jose State University, fo- sed on environmental considerations industrial design. It was the first IN- ERDESIGN workshop to involve pri- arily students and faculty of industrial sign. Universities from Russia, Po- id, Germany, France, England, Ja- in, and the United States were resented. Before arriving at the workshop, jdents identified industrial proc- ses from their region that could be redesigned to reduce their impact on the environment. At the workshop, stu- dents and faculty formed 12 multina- tional teams, each charged with redesigning one of the industrial proc- esses that had been identified. Each team developed functionally innovative ways to limit pollution or conserve re- sources and created visual repre- sentations of these ideas. Because designers influence how products are made, how they are used, and when their usefulness ends, they have a key role in environmental pro- tection. According to Project Director Peter Wooding, INTERDESIGN '92 produced useful insights in the areas of natural resource conservation, solid waste management, and pollution con- trol for the world's next generation of industrial designers. For more information on INTER- DESIGN '92, contact Kristina Goodrich of IDSA at (703) 759-7679. § " EPA Sponsors Special Issue of Innovation A second EPA grant to the WORLDESIGN Foundation, Inc., funded a special issue of Innovation, the quarterly journal of the Industrial Design Society of America (IDSA). Now in its tenth year, IDSA's award-winning journal has a reader- ;:ship of nearly 8,000 professional designers across the United States. EPA's grant allowed IDSA to increase the distribution of Innovation for its special issue, reaching designers, educators, students, manufacturers, and policymakers worldwide. The issue presented case studies demonstrating how designers have incorpo- rated environmental criteria into the design process. One study described the design of a special bin that facilitates the sorting of recyclables in the kitchen. Another study described a holographic screen that displays written information without using paper. The issue also featured articles on reducing industrial impact on the biosphere, utilizing solar energy, harnessing market forces to protect the earth, and increasing recycling in industrial processes. Perhaps most importantly, the issue expressed IDSA's conviction that designers can become "central contributors in the complex process of healing the planet." ------- FTC Announces Environmental Marketing Guidelines for Industry (Continued from page 1) Claims Task Force. The Task Force's goal is to provide a cohesive federal response to the issues raised by the inconsistent and sometimes innappropriate use of environmental marketing claims. By establishing the guidelines, the FTC has made a significant contribution to this goal. The guidelines include direction on broad types of environmental claims, as well as on very specific claims (see box on this page). In addition, the guidelines advise marketers only to make claims that they can substantiate. The guidelines provide examples of claims that are considered deceptive and claims that are considered acceptable by FTC. One example of potentially deceptive labeling in the guidelines refers to a hypothetical box of aluminum foil labeled with the term "recyclable," with nothing else to inform the consumer whether "recyclable" refers to the foil itself or to the box. If the manufacturer cannot substantiate that both the box and the foil are recyclable, the term is likely to be considered deceptive. An example of potentially acceptable labeling in the guidelines refers to a hypothetical shampoo marketed as "biodegradable." If the manufacturer has reliable evidence that the product is commonly disposed of in sewage systems where it rapidly breaks down into elements found in nature, the claim is likely to be considered acceptable. For more information on the FTC guidelines or to obtain a copy of the guidelines, contact FTC at (202) 326-3753. For more information on EPA envi- ronmental labeling activities, contact Carol Weisner of EPA at (202) 260-4489J 1992 MSW Characterization Reveals Substantial Increase in Recovery Rates (Continued from page 1) Looking to the future, the update pro- jects recovery rates of 20 to 30 percent in 1995 and 25 to 35 percent in the year 2000. Such increases in recovery rates are essential to keep pace with the nation's growing waste stream. The up- date projects that MSW generation will increase to 222 million tons—or 4.5 pounds per person per day—by the year 2000. As for other MSW management op- tions, landfilling declined from 73 per- cent in 1988 to 67 percent in 1990. By contrast, incineration of MSW showed a slight increase from 14 percent in 1988 to 16 percent in 1990. To order copies of the update, an executive summary, or a fact sheet on the major findings, see the "Hot Off the Hotline" box on page 6.§ Summary of FTC Guidelines *f::he environmental marketing! k guidelines released by the Fed-! eral Trade Commission (FTC) in Jul1. include both general and specific di" rection on marketing claims. The] general guidelines are: E Any disclosures or qualifications of claims must be clear and prominent enough to prevent deception. e Claims should clearly state whether they apply to the product, its packaging, or both. 13 Claims should not overstate environmental benefits. E" Claims based on a comparison should present the basis for the comparison clearly enough to avoid deception. The specific guidelines include di- rection about when and how it is or is not deceptive to use the following eight common claims: .HI General environmental benefit, e.g., environmentally friendly. 13 Degradable, biodegradable, or photodegradable. C Compostable. E Recyclable. 8 Recycled content. C Source reduction. B Refillable. D Ozone-safe or ozone-friendly. The mention of publications, products, or organizations in this newsletter does not constitute endorsement or approval for use by the U.S. Environmental Protection Agency. U.S. Environmental Protection Agency Office of Solid Waste Communications Services Branch (OS-305) 401 M Street, SW. Washington, DC 20460 Official Business, Penalty for Private Use $300 ------- |