United States Solid Waste EPA530-R-98-003
Environmental Protection and Emergency Response July 1998
Agency (5305W) www.epa.gov
vxEPA Background Document for
Proposed CPG III and
Draft RMAN III
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BACKGROUND DOCUMENT FOR PROPOSED CPG III AND
DRAFT RMAN III
CONTENTS
I. INTRODUCTION 1
A. History 1
B. Contents of These Supporting Analyses 2
II. BACKGROUND 6
A. Requirements 6
1. RCRA Section 6002 7
2. Executive Order 12873 8
B. Criteria for Selecting Items for Designation 9
1. Use of Materials Found in Solid Waste 10
2. Economic and Technological Feasibility and Performance 10
3. Impact of Government Procurement 11
4. Availability and Competition 12
5. Other Uses for Recovered Materials 12
6. Other Considerations 13
C. Methodology for Selecting Items for Designation 14
D. Broad Categories Versus Specific Items 16
III. ITEM DESIGNATION CATEGORIES 17
IV. DEFINITIONS 18
V. CONSTRUCTION PRODUCTS 19
A. Carpet Backing 19
1. Item Description 19
2. Rationale for Designation 20
a. Impact on Solid Waste 20
b. Technological Feasibility and Performance 20
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c. Availability and Competition 20
d. Economic Feasibility 21
e. Government Purchasing 21
f. Barriers to Purchasing 21
g. Designation 22
3. Procurement Recommendations 22
a. Recovered Materials Content 22
b. Preference Program 23
c. Specifications 24
B. Carpet Cushion 24
1. Item Description 24
2. Rationale for Designation 26
a. Impact on Solid Waste 26
b. Technological Feasibility and Performance 26
c. Availability and Competition 27
d. Economic Feasibility 27
e. Government Purchasing 27
f. Barriers to Purchasing 28
g. Designation 28
3. Procurement Recommendations 28
a. Recovered Materials Content 28
b. Preference Program 29
c. Specifications 30
C. Flowable Fill 30
1. Item Description 30
2. Rationale for Designation 33
a. Impact on Solid Waste 33
b. Technological Feasibility and Performance 34
c. Availability and Competition 37
d. Economic Feasibility 38
e. Government Purchasing 39
f. Barriers to Purchasing 39
g. Designation 40
3. Procurement Recommendations 40
a. Recovered Materials Content 40
b. Preference Program 41
c. Specifications 42
D. Railroad Grade Crossing Surfaces 45
1. Item Description 45
2. Rationale for Designation 47
a. Impact on Solid Waste 47
b. Technological Feasibility and Performance 48
c. Availability and Competition 54
d. Economic Feasibility 55
e. Government Purchasing 55
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f. Barriers to Purchasing 57
g. Designation 58
3. Procurement Recommendations 58
a. Recovered Materials Content 58
b. Preference Program 61
c. Specifications 61
E. Building Insulation Products 64
1. Additional Procurement Recommendations 64
a. Preference Program 64
b. Specifications 61
VI. PARK AND RECREATION PRODUCTS 66
A. Park and Recreational Furniture 66
1. Item Description 66
2. Rationale for Designation 68
a. Impact on Solid Waste 68
b. Technological Feasibility and Performance 69
c. Availability and Competition 74
d. Economic Feasibility 74
e. Government Purchasing 74
f. Barriers to Purchasing 75
g. Designation 75
3. Procurement Recommendations 76
a. Recovered Materials Content 76
b. Preference Program 79
c. Specifications 79
B. Playground Equipment 81
1. Item Description 81
2. Rationale for Designation 82
a. Impact on Solid Waste 83
b. Technological Feasibility and Performance 84
c. Availability and Competition 87
d. Economic Feasibility 87
e. Government Purchasing 87
f. Barriers to Purchasing 88
g. Designation 88
3. Procurement Recommendations 89
a. Recovered Materials Content 89
b. Preference Program 90
c. Specifications 91
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VII. LANDSCAPING PRODUCTS 93
A. Plastic Lumber Landscaping Timbers and Posts 93
1. Item Description 93
2. Rationale for Designation 95
a. Impact on Solid Waste 96
b. Technological Feasibility and Performance 97
c. Availability and Competition 99
d. Economic Feasibility 100
e. Government Purchasing 100
f Barriers to Purchasing 100
g. Designation 100
3. Procurement Recommendations 101
a. Recovered Materials Content 101
b. Preference Program 104
c. Specifications 105
B. Food Waste Compost 106
1. Item Description 106
2. Rationale for Designation 107
a. Impact on Solid Waste 107
b. Technological Feasibility and Performance 108
c. Availability and Competition 109
d. Economic Feasibility 110
e. Government Purchasing Ill
f. Barriers to Purchasing 112
g. Designation 113
3. Procurement Recommendations 113
a. Recovered Materials Content 113
b. Preference Program 114
c. Specifications 115
VIII. NON-PAPER OFFICE PRODUCTS 116
A. Plastic Binders, Clipboards, File Folders, Clip Portfolios, and
Presentation Folders 116
1. Item Description 116
2. Rationale for Designation 116
a. Impact on Solid Waste 117
b. Technological Feasibility and Performance 117
c. Availability and Competition 117
d. Economic Feasibility 118
e. Government Purchasing 118
f. Barriers to Purchasing 119
g. Designation 119
IV
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3. Procurement Recommendations 120
a. Recovered Materials Content 120
b. Preference Program 121
c. Specifications 121
IX. MISCELLANEOUS PRODUCTS 122
A. Absorbents and Adsorbents 122
1. Item Description 122
2. Rationale for Designation 125
a. Impact on Solid Waste 125
b. Technological Feasibility and Performance 126
c. Availability and Competition 129
d. Economic Feasibility 130
e. Government Purchasing 130
f Barriers to Purchasing 131
g. Designation 132
3. Procurement Recommendations 133
a. Recovered Materials Content 133
b. Preference Program 136
c. Specifications 136
B. Industrial Drums 138
1. Item Description 138
2. Rationale for Designation 139
a. Impact on Solid Waste 139
b. Technological Feasibility and Performance 139
c. Availability and Competition 141
d. Economic Feasibility 142
e. Government Purchasing 142
f. Barriers to Purchasing 143
g. Designation 143
3. Procurement Recommendations 143
a. Recovered Materials Content 143
b. Preference Program 146
c. Specifications 147
C. Awards and Plaques 148
1. Item Description 148
2. Rationale for Designation 148
a. Impact on Solid Waste 148
b. Technological Feasibility and Performance 149
c. Availability and Competition 149
d. Economic Feasibility 149
e. Government Purchasing 150
f. Barriers to Purchasing 150
g. Designation 151
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3. Procurement Recommendations 151
a. Recovered Materials Content 151
b. Preference Program 152
c. Specifications 152
D. Mats 153
1. Item Description 153
2. Rationale for Designation 153
a. Impact on Solid Waste 154
b. Technological Feasibility and Performance 154
c. Availability and Competition 154
d. Economic Feasibility 155
e. Government Purchasing 155
f Barriers to Purchasing 155
g. Designation 156
3. Procurement Recommendations 156
a. Recovered Materials Content 156
b. Preference Program 159
c. Specifications 159
E. Signage 160
1. Item Description 160
2. Rationale for Designation 162
a. Impact on Solid Waste 162
b. Technological Feasibility and Performance 163
c. Availability and Competition 166
d. Economic Feasibility 167
e. Government Purchasing 168
f. Barriers to Purchasing 171
g. Designation 172
3. Procurement Recommendations 172
a. Recovered Materials Content 172
b. Preference Program 173
c. Specifications 174
F. Strapping and Stretch Wrap 175
1. Item Description 175
2. Rationale for Designation 176
a. Impact on Solid Waste 176
b. Technological Feasibility and Performance 177
c. Availability and Competition 180
d. Economic Feasibility 180
e. Government Purchasing 181
f. Barriers to Purchasing 182
g. Designation 182
VI
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3. Procurement Recommendations 182
a. Recovered Materials Content 182
b. Preference Program 184
c. Specifications 185
X. OTHER ITEMS CONSIDERED FOR CPG III DESIGNATION 186
A. Items Still Under Consideration 186
B. Items Dropped From Further Consideration 187
1. Miscellaneous Products Dropped From Consideration 188
a. Recycled Ink 188
b. Shotgun Shells 188
XL DESIGNATED ITEM AVAILABILITY 188
XII. ECONOMIC IMPACT ANALYSIS 189
XIII. SUPPORTING INFORMATION 189
A. Carpet Cushion 189
B. Coal Fly Ash/Foundry Sand/Flowable Fill 189
C. Plastic Lumber 190
D. Playground Equipment 190
E. Compost 190
F. Sorbents 190
G. Signage 191
H. Strapping 191
I. Multi-Material 191
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TABLES
Table 1: List of Acronyms 3
Table 2: Recovered Materials Content of Carpet Backing 23
Table 3: Draft Recovered Materials Content Recommendations for Backing for
Nylon Broadloom and Carpet Tiles 24
Table 4: Materials Used in Carpet Cushion 25
Table 5: Recovered Materials Content of Carpet Cushion 29
Table 6: Draft Recovered Materials Content Recommendations for Carpet Cushion 29
Table 7: Typical Proportions for High Fly Ash Content Mixes 35
Table 8: Typical Proportions for Low Fly Ash Content Mixes 35
Table 9: Recovered Materials Content of Flowable Fill 41
Table 10: Materials Quantities for Flowable Fill Mixture Containing
Foundry Sands and Coal Fly Ash 42
Table 11: Standard Specifications, Test Methods, and Practices for Flowable Fill 43
Table 12: Public Crossings by Crossing Surface: Calendar Year 1995 46
Table 13: Recovered Materials Content of Railroad Grade Crossings 60
Table 14: Draft Recovered Materials Content Recommendations for Railroad Grade Crossings . 61
Table 15: State of Alabama Railroad Crossing Surface Guidelines 62
Table 16: Recommended Recovered Materials Content Levels for Building Insulation 64
Table 17: Recovered Materials Content of Park and Recreational Furniture 77
Table 18: Draft Recovered Materials Content Recommendations for Park and
Recreational Furniture (Park Benches and Picnic Tables) 79
Table 19: Recovered Materials Content of Playground Equipment (Non-Structural Pieces) .... 89
Table 20: Draft Recovered Materials Content Recommendations for Playground Equipment ... 90
Vlll
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Table 21: Recovered Materials Content of Landscaping Timbers and Posts 102
Table 22: Draft Recovered Materials Content Recommendations for
Landscaping Timbers and Posts 104
Table 23: Materials Used in Solid Plastic Binders, Clipboards, File Folders,
Clip Portfolios, and Presentation Folders 116
Table 24: Recovered Materials Content of Plastic Binders, Clipboards, File Folders,
Clip Portfolios, and Presentation Folders 120
Table 25: Draft Recovered Materials Content Recommendations for Plastic Binders,
Clipboards, File Folders, Clip Portfolios, and Presentation Folders 121
Table 26: Sorbent Materials 123
Table 27: Recovered Materials Content of Sorbents 133
Table 28: Draft Recovered Materials Content Recommendations for Absorbents
and Adsorbents 136
Table 29: DOT Drum Packaging Groups 140
Table 30: Recovered Materials Content of Industrial Drums 146
Table 31: Draft Recovered Materials Content Recommendations for Industrial Drums 146
Table 32: Recovered Materials Content of Awards and Plaques 151
Table 33: Draft Recovered Materials Content Recommendations for Awards and Plaques .... 152
Table 34: Recovered Materials Content of Mats 157
Table 35: Draft Recovered Materials Content Recommendations for Mats 159
Table 36: Recovered Materials Content of Signage 173
Table 37: Draft Recovered Materials Content Recommendations for Signage 174
Table 38: Recovered Materials Content of Strapping 184
Table 39: Draft Recovered Materials Content Recommendations for Strapping 185
Table 40: ASTM Specifications and Guidance for Types of Strapping 185
IX
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I. INTRODUCTION
A. History
Section 6002(e) of RCRA requires EPA to designate items that are or can be made with recovered
materials and to recommend practices to assist procuring agencies in meeting their obligations with
respect to designated items under RCRA section 6002. After EPA designates an item, RCRA requires that
each procuring agency, when purchasing a designated item, must purchase that item composed of the
highest percentage of recovered materials practicable.
Executive Order 12873 (Executive Order) establishes the procedure for EPA to follow in
implementing RCRA section 6002(e). Section 502 of the Executive Order directs EPA to issue a
Comprehensive Procurement Guideline (CPG) that designates items that are or can be made with
recovered materials. Concurrent with the CPG, EPA must publish its recommended procurement practices
for purchasing designated items, including recovered materials content levels, in a related Recovered
Materials Advisory Notice (RMAN). The Executive Order also directs EPA to update the CPG annually
and to issue RMANs periodically to reflect changing market conditions. The first CPG (CPG I) was
published on May 1, 1995 (60 FR 21370). It established 8 product categories, designated 19 new items,
and consolidated 5 earlier item designations. The first CPG update (CPG II) was published on November
13, 1997 (62 FR 60962), and designated an additional 12 products. Today, in CPG III, EPA is proposing
to designate the following 19 additional items:
Construction Products
Nylon carpet with backing containing recovered materials
Carpet cushion
Flowable fill
Railroad grade crossing surfaces
Park and Recreation Products
Park benches and picnic tables
Playground equipment
Landscaping Products
Food waste compost
Plastic lumber landscaping timbers and posts
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Non-Paper Office Products
Solid plastic binders
Plastic clipboards
Plastic file folders
Plastic clip portfolios
Plastic presentation folders
Miscellaneous
Absorbents and adsorbents
Awards and plaques
Industrial drums
Mats
Non-road signs, including sign supports and posts
Manual-grade strapping
B. Contents of These Supporting Analyses
This document, hereafter referred to as the proposed CPG Ill/Draft RMAN III background
document, explains EPA's overall objectives, the process for designating procurement items, and the
methodology used in recommending recovered materials content levels for items designated in the proposed
CPG III. In addition, the proposed CPG Ill/Draft RMAN III background document lists the recommended
procurement practices for designated items.
Also for the reader's convenience, the table below lists acronyms referenced throughout this
document.
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Table 1
List of Acronyms
Acronym
AASHTO
ACAA
ACI
ACR
AF&PA
ANSI
APC
APP
APWA
ARTBA
ASTM
EOF
C&D
CCC
CDC
CFR
CLSM
COAP
CPG
CPSC
DLA
DOD
DOE
DOT
Term
American Association of State Highway and
Transportation Officials
American Coal Ash Association
American Concrete Institute
Association of Container Reconditioners
American Forest and Paper Association
American National Standards Institute
American Plastics Council
Affirmative Procurement Program
American Public Works Association
American Roads and Transportation Builders
Association
American Society for Testing and Materials
Basic Oxygen Furnace
Construction and Demolition Debris
Carpet Cushion Council
Centers for Disease Control and Prevention
Code of Federal Regulations
Controlled Low-Strength Material
Coalition for Absorbent Producers
Comprehensive Procurement Guideline
U.S. Consumer Product Safety Commission
Defense Logistics Agency
U.S. Department of Defense
U.S. Department of Energy
US Denartrnent nf Transnnrtatinn
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Acronym
DRMO
EAF
EPA
FDA
FHWA
FR
FRA
GPO
GSA
HOPE
HSWA
HUD
ISTEA
IV
LDPE
LLDPE
MAC
MSW
NIH
NIOSH
NPS
OFPP
OSHA
PDI
PE
Term
Defense Reutilization Marketing Office
Electric Arc Furnace
U.S. Environmental Protection Agency
Food and Drug Administration
Federal Highway Administration
Federal Register
Federal Railroad Administration
U.S. Government Printing Office
U.S. General Services Administration
High Density Polyethylene
Hazardous and Solid Waste Amendments of
1984
U.S. Department of Housing and Urban
Development
Intermodal Surface Transportation Efficiency
Act of 1991
Inherent Viscosity
Low Density Polyethylene
Linear Low Density Polyethylene
Multiple Awards Contract
Municipal Solid Waste
National Institutes of Health
National Institute for Occupational Safety and
Health
National Park Service
Office of Federal Procurement Policy
Occupational Safety and Health Administration
Plastic Drum Institute
Polvethvlene
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Acronym
PET
PLTA
PP
PS
PSI
PVC
RCRA
RIC
RMAN
RPG
SCAA
SCBA
SMS
SRI
SSCI
TxDOT
UN
USAF
USDA
USPS
uv
voc
Term
Polyethylene Terephthalate
Plastic Lumber Trade Association
Polypropylene
Polystyrene
Pounds Per Square Inch
Polyvinyl Chloride
Resource Conservation and Recovery Act of
1976
RCRA Information Center
Recovered Materials Advisory Notice
Recycled Products Guide
Spill Control Association of America
Self-Contained Breathing Apparatus
Spunbonded-Meltblown-Spunbonded
Steel Recycling Institute
Steel Shipping Container Institute
Texas Department of Transportation
United Nations
U.S. Air Force
U.S. Department of Agriculture
U.S. Postal Service
Ultraviolet
Volatile Organic Compound
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II. BACKGROUND
A. Requirements
The Resource Conservation and Recovery Act (RCRA or the Act) section 6002 and Executive
Order 12873 (Executive Order) specify requirements for the procurement of products containing recovered
materials. The requirements of RCRA section 6002 apply to "procuring agencies," as defined in RCRA
section 1004(17); the Executive Order applies only to Federal "executive agencies," as defined in section
202 of the Executive Order.
Section 6002(e) of RCRA requires EPA to designate items that are or can be made with recovered
materials and to recommend practices to assist procuring agencies in meeting their obligations with respect
to the procurement of designated items under RCRA section 6002. After EPA designates an item, RCRA
requires that each procuring agency, when purchasing a designated item, must purchase that item composed
of the highest percentage of recovered materials practicable.
The Executive Order specifies the procedure for EPA to follow in implementing RCRA section
6002(e). Section 502 of the Executive Order directs EPA to designate items in the CPG and to recommend
procurement practices for purchasing designated items, including recovered materials content levels, in a
related RMAN. The Executive Order also directs EPA to update the CPG annually and to issue RMANs
periodically to reflect changing market conditions.
The following sections provide an overview of RCRA section 6002 and the Executive Order and
explain the basis for designating specific products as procurement items subject to RCRA section 6002.
Appendix I contains a summary of the generation and recovery of materials in the solid waste stream.
Appendix II provides a more detailed explanation of the provisions and requirements of RCRA section
6002. Appendix III provides additional details on the Executive Order, and Appendix IV briefly discusses
additional Federal procurement policies and requirements.
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1. RCRA Section 6002
RCRA section 6002 requires EPA to designate items that are or can be made with recovered
materials and to recommend practices to assist procuring agencies in purchasing the designated items. Once
an item is designated by EPA, procuring agencies that use appropriated Federal funds to purchase the item
are required to purchase it containing the highest percentage of recovered materials practicable (and in the
case of paper, the highest percentage of postconsumer recovered materials), taking into consideration the
limitations set forth in section 6002(c)(l)(A) through (C) (i.e., competition, price, availability, and
performance). The requirement applies when the purchase price of the item exceeds $10,000 or when the
total cost of such items, or of functionally equivalent items, purchased during the preceding fiscal year was
$10,000 or more.
RCRA section 6002(d)(2) requires that, within 1 year after EPA designates an item, Federal
agencies revise their specifications to require the use of recovered materials to the maximum extent possible
without jeopardizing the intended end use of the item. Section 6002(d)(l) further requires Federal agencies
responsible for drafting or reviewing specifications to review all of their product specifications to eliminate
provisions prohibiting the use of recovered materials and requirements specifying the exclusive use of
virgin materials. To comply with section 6002(d)(2), the revision process for items designated in CPG III
should be completed within 1 year after the final CPG III is published in the Federal Register.
Once EPA designates an item, responsibility for complying with RCRA section 6002 rests with the
procuring agencies. For each item designated by EPA, RCRA section 6002(i) requires each procuring
agency to develop an affirmative procurement program (APP), which sets forth the agency's policies and
procedures for implementing the requirements of RCRA section 6002. The APP must ensure that the
agency purchases items composed of recovered materials to the maximum extent practicable and that these
purchases are made consistent with applicable provisions of Federal procurement law. In accordance with
RCRA section 6002(i), the APP must contain at least four elements:
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1. A recovered materials preference program.
2. An agency promotion program.
3. A program for requiring vendors to estimate, certify, and reasonably verify the recovered
materials content of their products.
4. A program to monitor and annually review the effectiveness of the APP.
Appendix V provides detailed information on APPs.
Finally, RCRA section 6002(g) requires the Office of Federal Procurement Policy (OFPP) to
implement the requirements of RCRA section 6002 and to coordinate this policy with other Federal
procurement policies in order to maximize the use of recovered materials. RCRA further requires OFPP to
report to Congress every two years on actions taken by Federal agencies to implement such policy.
2. Executive Order 12873
Executive Order 12873, Federal Acquisition, Recycling, and Waste Prevention, was signed by
President Clinton on October 20, 1993. Section 502 of the Executive Order establishes a two-part process
for EPA to use when developing and issuing the procurement guidelines for products containing recovered
materials, as required by RCRA section 6002(e). The first part of the process, issuing the CPG, involves
designating items that are or can be made with recovered materials. The CPG is developed using formal
notice-and-comment rulemaking procedures and is codified at 40 CFR Part 247. The Executive Order
requires EPA to update the CPG annually.
The second part of the process is the publication of the RMAN, which provides recommendations
to procuring agencies on purchasing the items designated in the CPG. The Executive Order directs EPA to
publish the RMAN in the Federal Register for public comment. The RMAN, however, is not codified in
the CFR, because the recommendations are guidance. RMANs are issued periodically to reflect changes in
market conditions and provide procurement recommendations for newly designated items.
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B. Criteria for Selecting Items for Designation
While not limiting consideration to these criteria, RCRA section 6002(e) requires EPA to consider
the following when determining which items it will designate:
1. Availability of the item,
2. Potential impact on the solid waste stream of item procurement,
3. Economic and technological feasibility of producing the item, and
4. Other uses for the recovered materials used to produce the item.
EPA consulted with Federal procurement and requirement officials to identify other criteria to
consider when selecting items for designation. Based on these discussions, the Agency concluded that the
limitations set forth in RCRA section 6002(c) should also be factored into its selection decisions. This
provision requires each procuring agency to procure a designated item composed of the highest percentage
of recovered materials practicable, while maintaining a satisfactory level of competition. A procuring
agency, however, may decide not to procure an EPA-designated item containing recovered materials if it
determines: (1) the item is not reasonably available within a reasonable period of time; (2) the item fails to
meet the performance standards set forth in the agency's specification; or (3) the item is available only at an
unreasonable price. EPA recognized that these limitations could restrict procuring agencies from
purchasing EPA-designated items with recovered materials content, and, thereby, could limit the potential
impact of an individual item designation. (The limitations of section 6002(c) also effectively describe the
circumstances in which a designated item is "available" for purposes of the statute.) For this reason, EPA
also takes into account the limitations cited in RCRA section 6002(c) in its selection of items for
designation.
The Agency developed the following criteria for use in selecting items for designation: use of
materials found in solid waste; economic and technological feasibility and performance; impact of
government procurement; availability and competition; and other uses for recovered materials. The items
proposed for designation in CPG III have all been evaluated with respect to EPA's criteria. Details of these
evaluations are discussed in Sections V through IX of this document.
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1. Use of Materials Found in Solid Waste
All items designated in CPG III are manufactured with materials recovered or diverted from the
solid waste stream. These include both materials recovered or diverted from municipal solid waste (MSW)
and materials recovered or diverted from other solid waste streams, such as construction and demolition
(C&D) debris and other nonhazardous industrial waste streams. Once recovered or diverted, these materials
are reclaimed and refined, disassembled and remanufactured, or separated and processed for use as
feedstock to manufacture a new product. Appendix I provides an overview of the materials in MSW in the
United States and provides a more detailed explanation of the materials used in the products proposed for
designation in CPG III.
The potential impact that procuring agencies may have on the solid waste stream by procuring
EPA-designated items varies depending on the sophistication of the process used to recover or refine the
materials and on the recovered materials content of the final product. Additionally, although designating a
single item may not have a significant impact on the amount of solid waste recovered or diverted from the
waste stream, EPA believes that designating several items made from the same recovered material can lead
to the diversion of substantial quantities of that material from the waste stream.
Information on the recovered materials used to produce items proposed for designation by EPA is
presented in subsection 2(a), "Impact on Solid Waste," within the individual item discussions in Sections V
through IX of this document.
2. Economic and Technological Feasibility and Performance
Before selecting an item for designation, EPA determines that, based on its market research, it is
economically and technologically feasible to use recovered materials to produce the item. EPA uses several
indicators in making this determination. The availability of the item in the marketplace and procurement of
the item by Federal and/or other procuring agencies are primary indicators that it is economically and
technologically feasible to manufacture the product with recovered materials content. Other indicators
include the ability of the item to meet performance specifications, the general acceptance of the item by
consumers and purchasers, and the use of recovered feedstock by manufacturers.
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RCRA directs EPA to "designate items that are or can be produced with recovered materials and
whose procurement by procuring agencies will carry out the objectives of RCRA section 6002." This being
the case, there may be instances where a particular item is not currently made with recovered materials
content, but a similar item is. In those cases where the Agency believes that there are no
technical reasons that prevent an item from being manufactured with recovered materials, and there is a
demonstrated use of recovered materials in a similar item, EPA also may consider designation of the item
that currently does not contain recovered materials.
Prior to selecting an item for designation, EPA also considers the ability of the item to meet the
standards, specifications, or commercial item descriptions set forth by Federal agencies or national
standard-setting organizations.
Information on the economic and technological feasibility of producing items proposed for
designation by EPA, including the availability of the item and the number of manufacturers that produce
the item, the ability of the item to meet Federal or national specifications, the recovered materials content
levels used by manufacturers to produce the item, and other information relevant to the economic and
technical feasibility of producing and using the item, is discussed in section 2(b), "Technological Feasibility
and Performance," and section 2(d), "Economic Feasibility," in the individual item discussions in Sections
V through IX of this document.
3. Impact of Government Procurement
The impact of government procurement of products containing recovered materials is a
combination of: (1) direct purchases by Federal agencies, (2) purchases made by state and local agencies
using Federal monies, and (3) purchases made by contractors to these government agencies. When
considering items for designation, EPA examines whether government agencies and their contractors
purchase the items.
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Government procurement also has an impact that extends far beyond the Federal, state, and local
levels. As noted in RCRA and the Executive Order, the Federal government often serves as a model for
private and other public institutions. Because of this secondary effect, EPA includes items that are not
unique to or primarily used by government agencies. Many of the items that EPA selects for designation are
selected because they have broad application in both the government and private sectors.
Information on the impact of government procurement for each item proposed for designation in
CPG III is presented in section 2(e), "Government Purchasing," in the individual item discussions in
Sections V through IX of this document.
4. Availability and Competition
The items EPA selects for designation are available from national, regional, or local sources. The
relative availability of an item influences the ability of a procuring agency to secure an adequate level of
competition when procuring it. In the event that a satisfactory level of competition is unattainable, a
procuring agency may elect to waive the requirement to purchase an EPA-designated item based on the
limitations listed in RCRA section 6002(c).
Information on the availability of each item proposed for designation in CPG III, including the
number of manufacturers that produce the item, is presented in subsection 2(c), "Availability and
Competition," in the individual item discussions in Sections V through IX of this document.
5. Other Uses for Recovered Materials
In selecting items for designation, EPA also considers the following: (1) the possibility of one
recovered material displacing another recovered material as feedstock, thereby resulting in no net reduction
in materials requiring disposal; (2) the diversion of recovered materials from one product to another,
possibly creating shortages in feedstocks for one or both products; and (3) the ability of manufacturers to
obtain recovered materials in sufficient quantity to produce the item under consideration.
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While other uses for recovered materials are a consideration, they are not a determining factor
when selecting items for designation, because there is a need for additional markets for all recovered
materials used to manufacture the designated items.
6. Other Considerations
EPA also considers price as a factor affecting the availability of an item. The price of products,
whether made from virgin raw materials or recovered materials, is affected by many variables, including
the availability and costs of material feedstocks, energy costs, labor costs, rate of return on capital,
transportation charges, and the quantity of the item ordered. In addition, price may vary depending on
whether the product is a common stock item or whether it requires a special order. Price also can be
affected by the geographical location of the purchaser, because some products are not uniformly available
throughout the United States. The best sources of current price information, therefore, are the
manufacturers and vendors of the recycled products.
Relative prices of recycled products compared to prices of comparable virgin products also vary.
In many cases, recycled products may be less expensive than their virgin counterparts. In other cases,
virgin products may have lower prices than recycled products. Other factors also affect the price of virgin
products. For example, temporary fluctuations in the overall economy can create oversupplies of virgin
products, leading to a decrease in prices for these items. Therefore, while price is a consideration, it is not
in most cases, a determining factor when selecting items for designation. It becomes a determining factor
only when EPA obtains evidence that the relative price of an item with recovered materials content is
significantly higher than the relative price of a comparable virgin product. For this reason, EPA did not
address price in the individual item discussions in Sections V through IX of this document.
EPA has also considered the feasibility of designating experimental or developmental products
containing recovered materials. In the Agency's experience, such designations do not result in Federal
procurement of products containing recovered materials, because the items are not reasonably available,
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or only one source exists, leading to an unsatisfactory level of competition. For this reason, EPA does not
intend to designate experimental or developmental products until it can be shown that they meet all of
EPA's selection criteria, as described above.
C. Methodology for Selecting Items for Designation
EPA used the following process to determine which items to designate in the CPG. First, EPA
reviewed and updated information on items previously considered for designation but for which more
information was needed.
Next the Agency gathered information on new items from comments submitted in response to the
initial CPG, which was proposed on April 20, 1994. On September 20, 1995, EPA published a FR notice
requesting information from the public on potential items for inclusion in CPG. From December 1, 1995,
through February 29, 1996, EPA accepted information from interested parties to consider when selecting
items for designation, recommending recovered materials content levels for selected items, and revising
recommendations for existing designated items.
In the September 20, 1995, notice, EPA requested information regarding the following seven areas:
1. Barriers to Purchasing Products Containing Recovered Materials:
# What government specifications, standards, purchasing policies, or purchasing
procedures preclude government agencies from purchasing the item containing
recovered materials?
2. Use of Materials in Solid Waste:
# Is the item made using a material that represents a significant portion of the solid
waste stream or presents a solid waste disposal problem?
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3. Economic and Technological Feasibility and Performance:
# Does the item perform as well as necessary to meet a procuring agency's needs?
# Are there government, American Society for Testing and Materials (ASTM), or
other consensus standards or specifications that would enable a procuring agency
to buy the item containing recovered materials?
# Is the item available at a reasonable price considering normal market fluctuations?
4. Impact of Government Procurement:
# Is the item purchased in appreciable quantities by the Federal government or by
state and local governments?
5. Availability and Competition:
# Is the item available from an adequate number of sources to ensure competition?
# Is the item generally available, rather than available in a limited market area?
6. Recovered Materials Content Levels:
# What levels of recovered materials content are used in the product?
# Is the recovered materials content postconsumer material? What percentage is
postconsumer?
7. Sources of information:
# What is the source of the information provided (e.g., industry studies, technical
journals)?
CPG III proposes to designate some of the items recommended in the public comments on the
September 1995 FR notice.
After EPA conducted additional product research, the information was presented to an interagency
work group composed of individuals representing major Federal procuring agencies. The work group
members identified additional items to be considered for designation, based on their experiences developing
product specifications, their knowledge of the marketplace, and their respective agencies' procurement
practices. The work group reviewed the available information and prioritized the products into several
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categories: (1) products that EPA should propose for designation in CPG HI, (2) products that might be designated in
the near future pending receipt of additional information and further review, and (3) products that EPA cannot propose
for designation because of limited availability, unreasonable price, negligible effects on the waste stream, or the current
inability of manufacturers to produce the items with recovered materials content.
Items proposed for CPG III designation are described in detail in sections V through IX of this
document. Those items that will be considered for designation at later date are presented in section X.A,
and those items that cannot be proposed for designation at this time are discussed in section X.B, along
with a brief explanation of the basis for this determination.
D. Broad Categories Versus Specific Items
EPA has adopted two approaches in its designation of items that are made with recovered materials. For
some items, such as paper products, the Agency designated broad categories of items and provided information in the
RMAN as to their appropriate applications or uses. For other items, such as plastic envelopes, EPA designated
specific items, and, in some instances, included in the designation the specific types of recovered materials or
applications to which the designation applies. The Agency provided the following explanation for these approaches to
designating items in the preamble to the first CPG (60 FR 21369, May 1, 1995):
EPA sometimes had information on the availability of a particular item made with a specific
recovered material (e.g., plastic), but no information on the availability of the item made
from a different recovered material or any indication that it is possible to make the item
with a different recovered material. In these instances, EPA concluded that it was
appropriate to include the specific material in the item designation in order to provide vital
information to procuring agencies as they seek to fulfill their obligations to purchase
designated items composed of the highest percentage of recovered materials practicable.
This information enables the agencies to focus their efforts on products that are currently
available for purchase, reducing their administrative burden. EPA also included
information in the proposed CPG, as well as in the draft RMAN that accompanied the
proposed CPG, that advised procuring agencies that EPA is not recommending the
purchase of an item made from one particular material over a similar item made from
another material. For example, EPA included the following statement in the preamble
discussion for plastic desktop accessories (59 FR 18879, April 20, 1994): "This designation
does not preclude a procuring agency from purchasing desktop accessories manufactured
from another material, such as wood. It simply requires that a procuring agency, when
purchasing plastic desktop accessories, purchase these accessories made with recovered
materials..."
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The Agency understands that some procuring agencies may believe the designation of a broad
category of items in the CPG requires them to: (1) procure all items included in such category with
recovered materials content and (2) to establish an affirmative procurement program for the entire category
of items, even where specific items within the category may not meet current performance standards. This
is clearly not required under RCRA as implemented through the CPG and the RMAN. RCRA section 6002
does not require a procuring agency to purchase items with recovered materials content that are not
available or that do not meet a procuring agency's specifications or reasonable performance standards for
the contemplated use. Further, RCRA section 6002 does not require a procuring agency to purchase such
items if the item with recovered materials content is only available at an unreasonable price or the purchase
of such item is inconsistent with maintaining a reasonable level of competition. However, EPA stresses
that, when procuring any product for which a recovered materials alternative is available that meets the
procuring agency's performance needs, if all other factors are equal, the procuring agency should seek to
purchase the product made with highest percentage of recovered materials practicable.
III. ITEM DESIGNATION CATEGORIES
Items designated in the CPG are organized in the following product categories: paper and paper
products, vehicular products, construction products, transportation products, park and recreation products,
landscaping products, non-paper office products, and miscellaneous products. The categories were
developed to describe the application of each designated item.
# Paper and Paper Products. Includes printing and writing papers, newsprint, tissue
products, paperboard products, and packaging. This category does not include paper and
paper products used in construction applications. A final RMAN for paper and paper
products containing recovered materials was issued on May 29, 1996, at 61 FR 26985. No
paper products are included in CPG III.
# Vehicular Products. Products used in repairing and maintaining automobiles, trucks, and
other vehicles. Examples include re-refined lubricating oils, retread tires, and engine
coolants. No vehicular products are proposed for designation in CPG III.
# Construction Products. Products used in constructing roads and the interior and exterior
components of commercial and residential buildings. Examples include building materials
and paint. In CPG III, EPA is proposing to designate carpet backing, carpet cushion,
flowable fill, and railroad grade crossing surfaces in the construction products category.
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# Transportation Products. Products used for directing traffic, alerting drivers, and
containing roadway noise and pollution. Examples include parking stops and traffic
control devices. No transportation products are proposed for designation in CPG III.
# Park and Recreation Products. Products used in operating and maintaining parks and
recreational areas. Examples include playground equipment and running tracks. In CPG
III, EPA is proposing to designate park and recreational furniture, specifically, park
benches and picnic tables, and playground equipment in the park and recreation products
category.
# Landscaping Products. Products used to contain, maintain, or enhance decorative and
protective vegetation or areas surrounding buildings and roadways. Examples include
compost and hydraulic mulch. In CPG III, EPA is proposing to designate food waste
compost and plastic lumber landscaping timbers and posts in the landscaping products
category.
# Non-Paper Office Products. Equipment and accessories used by government agencies and
businesses to perform daily operational and administrative functions of an office.
Examples include toner cartridges, desktop accessories, and waste receptacles. In CPG III,
EPA is proposing to designate plastic binders, clipboards, file folders, clip portfolios, and
presentation folders in the non-paper office products category.
# Miscellaneous Products. Includes all other products not covered by the categories listed
above. In CPG III, EPA is proposing to designate absorbents and adsorbents, awards and
plaques, industrial drums, mats, signage, and strapping in the miscellaneous products
category.
IV. DEFINITIONS
The proposed item designations and the purchasing recommendations in draft RMAN III use the
terms "postconsumer materials" and "recovered materials." The definitions for these terms are shown below
for the convenience of the reader. These definitions were included as part of the original CPG and can also
befoundat40CFR§247.3.
Postconsumer materials means a material or finished product that has served its intended end use
and has been diverted or recovered from waste destined for disposal, having completed its life as a
consumer item. Postconsumer material is part of the broader category of recovered materials.
Recovered materials means waste materials and byproducts which have been recovered or
diverted from solid waste, but such term does not include those materials and byproducts generated
from, and commonly reused within an original manufacturing process.
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V. CONSTRUCTION PRODUCTS
A. Carpet Backing
1. Item Description
Carpet backing is a layer of woven or nonwoven material used to hold carpet fibers in place and
provide structural support. Carpet backing differs depending on how the carpet is constructed.
Approximately 90 to 95 percent of all carpet manufactured in the United States is called broadloom (or
"roll carpet") and is constructed in the following manner: carpet fibers (nylon, polyester, wool, etc.) are
inserted into a layer of woven material and glued into place. This layer of woven material, the primary
backing, is most often made of polypropylene (PP). Another layer of woven materials, the secondary
backing, is then applied to the primary backing to provide stability. The secondary backing is also usually
made of PP, although it can also be made of jute.
The remaining 5 to 10 percent of carpet manufactured in the United States is carpet squares or
tiles. They are manufactured first as broadloom carpet, but a third layer of polyvinyl chloride (PVC),
polyurethane, or other hardback material is applied to the secondary backing for enhanced durability. The
carpet is then usually cut into 18 by 18-inch squares. Carpet tiles are used in modular flooring systems,
such as in office settings, and can offer more flexibility than broadloom carpet. Individual tiles can be
replaced when they become worn. According to one manufacturer, the backing on this type of carpet is the
single heaviest component of the carpet, typically constituting two to four times more weight than the face
yarn.
Some manufacturers also adhere carpet cushion to the back of carpet (rather than installing carpet
over a separate cushion). Manufacturers refer to this cushion as backing and use such terms as "cushion
back" or "foam back." This research distinguishes carpet cushion from carpet backing; carpet cushion is
discussed in Section V.B of this document.
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2. Rationale for Designation
EPA believes that nylon carpet tiles and broadloom carpet made with backing containing recovered
materials meet the statutory criteria for selecting items for designation.
a. Impact on Solid Waste
Recovered content vinyl carpet backing is made of postconsumer carpets. As shown in Appendix I,
plastic is a significant component of the solid waste stream.
According to one manufacturer, carpet tiles with recovered-content backing weigh approximately 8.4
pounds per square yard. Approximately 22.4 percent of a carpet tile by weight contains recovered materials.
About 2 pounds of recovered materials, therefore, are used in each square yard of this manufacturer's carpet
tiles. If a government agency purchased 1,000 square yards of the carpet tiles with recovered-content backing,
approximately 2,000 pounds of materials would be diverted from the waste stream.
b. Technological Feasibility and Performance
According to the company, recovered-content vinyl carpet backing performs as well as virgin vinyl
backing and meets the company's performance specifications. Carpet manufactured by this company with
recovered-content backing comes with a 15-year warranty. As this product was only made commercially
available in December 1996, EPA has not been able to identify any users of the recovered-content backing.
The company is marketing its product in unspecified trade and government publications.
c. Availability and Competition
EPA did not identify any manufacturers or distributors of broadloom carpet with recovered-content
backing. Carpet tiles with recovered-content vinyl backing are currently available from one company that
distributes its products nationwide. It is anticipated that other manufacturers could enter the marketplace in
1997. The company bids larger government projects directly but relies on its distributor network for
smaller projects.
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d. Economic Feasibility
Carpet tiles with recovered-content vinyl backing are cost-competitive with carpet tiles
manufactured with virgin vinyl backing. Carpet tiles, however, are generally more expensive than
broadloom carpet, because they are sturdier and are designed to last longer.
e. Government Purchasing
EPA assumes that virtually all government agencies purchase carpet. Because carpet tiles are
generally used in office settings, EPA also assumes that some government agencies buy carpet tiles. EPA is
still attempting to determine to what extent government agencies buy carpet tiles as opposed to broadloom
carpet, considering that carpet tiles are often more expensive than broadloom carpet.
EPA learned that one manufacturer has been working with the U.S. General Services
Administration (GSA) to place its carpet tiles with recovered-content backing on GSA's carpet schedule
(Schedule 72, Part 1, Section A). This company indicated that GSA's current specification for recovered-
content carpet applies only to carpet made with recovered-content polyester fibers. A GSA representative
stated that the product should be available on the carpet schedule by mid-June 1997. The company also
stated that the state of Florida has purchased its carpet through the state's SNAPS program, a special
purchase schedule that provides early introduction of recycled-content, energy-efficient, and other
environmental products.
f. Barriers to Purchasing
The higher cost of carpet tiles compared to other types of carpet might be a purchasing barrier for
carpet tiles with recovered-content vinyl backing. EPA did not identify any other barriers to purchasing
carpet tiles with recovered-content vinyl backing.
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g. Designation
EPA proposes to designate nylon carpet (broadloom and tiles) made with backing containing
recovered materials. A final designation would not preclude a procuring agency from purchasing
broadloom carpet or carpet tiles made from other materials, such as wool. It simply requires that a
procuring agency, when purchasing nylon carpet tiles or nylon broadloom carpet, purchase these items with
backing containing recovered materials when they meet applicable specifications and performance
requirements.
3. Procurement Recommendations
a. Recovered Materials Content
EPA contacted two manufacturers of woven PP primary and secondary backings. One of these
manufacturers had submitted a comment to EPA, stating it is "technologically and economically infeasible
to manufacture carpet backing with recycled PP at this time." The manufacturer went on to state,
"Extrusion of recovered polymer for carpet backing purposes would result in such production problems as
draw breaks, slow holes, higher waste generation, and lower yields. One consequence of such production
difficulties is a higher unit cost for the end product." The company continues to attempt to use recovered
materials in its backing, however.
Another manufacturer of woven PP backings is also not using recovered materials in carpet
backing due to the difficulty of removing impurities from recovered materials.
EPA identified one carpet manufacturer that is manufacturing carpet tiles with recovered-content
PVC backing for use in commercial settings. The company manufactures the PVC backing using
postconsumer materials from old carpets. This manufacturer recovers 100 percent of the carpet it brings
back and does not need to separate the carpet into its component parts in order to recover the materials. The
company estimates that its recovered-content carpet backing contains 75 percent postconsumer materials.
The recycled-content carpet backing has the same performance characteristics as virgin backing
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and comes with a 15-year warranty. It is cost-comparable to virgin carpet backing as well. The company
plans to make roll carpet with the recovered-content backing commercially available sometime in 1997.
Also, the company hopes to offer roll carpet with recovered-content cushion backing in 1998.
Although EPA did not identify any other carpet tile manufacturers currently using a significant
portion of recovered materials in their vinyl backing, some companies are experimenting with using
recovered materials in vinyl backing. One company, for example, stated that it is currently testing a small
amount (less than 10 percent) of in-house scrap and postconsumer materials in its hard vinyl backing. The
company is using only a small amount of postconsumer backing due to the difficulties of separating used
carpet backing from the face fibers. Another company stated that it had previously ground postconsumer
carpet to use in a variety of products, including carpet backing. The equipment used to grind the carpet was
destroyed in a recent fire, however. As a result, the company is currently using only in-house scrap
materials in its vinyl carpet backing. The company plans to be back on line grinding postconsumer carpets
in a year.
Table 2 presents information provided by manufacturers of carpet backing on recycled content
availability.
Table 2
Recovered Materials Content of Carpet Backing
Material
PVC
Postconsumer Content (%)
Company A: 75
Company B: <5
Total Recovered
Materials Content (%)
Unknown
<10
b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 3,
procuring agencies establish minimum content standards for use in purchasing carpet backing.
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Table 3
Draft Recovered Materials Content Recommendations for
Backing for Nylon Broadloom and Carpet Tiles
Material
Old carpets
Postconsumer content (%)
35-70
Total recovered materials content (%)
100
c.
Specifications
EPA is not aware of any performance specifications for carpet backing.
B. Carpet Cushion
1. Item Description
Carpet cushion, also known as carpet underlay, is padding placed beneath carpet. According to the
Carpet Cushion Council (CCC), carpet cushion improves the acoustical and thermal insulation properties
of carpet, reduces the impact caused by foot traffic or furniture indentation, enhances comfort, and
prolongs appearance. It is available in a variety of thicknessesthe most common being %- and 1A-
inchand is used in both residential and commercial settings, although it appears to be less common in
commercial settings. Carpet cushion can be sold separately or preattached to the carpet. Carpet can also be
installed without any cushioning. Carpets with preattached cushions are referred to as "cushion back" or
"foam back" carpets. Approximately 20 percent of commercial carpet sold has a preattached cushion. The
remainder of this report focuses on separate, nonattached cushion.
Carpet cushions can be made from three large categories of materials: polyurethane foam, fiber,
and rubber. A variety of materials within each of these categories can be used to make carpet cushion, as
shown in Table 4.
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Table 4
Materials Used in Carpet Cushion
Category
Polyurethane Foam
Fiber
Rubber*
Material Type
Prime
Grafted prime
Densified prime
Bonded*
Mechanically frothed
Hair
Jute*
Synthetic fibers*
Flat rubber
Rippled rubber
* Can be made with recovered materials.
Of these materials, cushions made from bonded urethane, synthetic fiber, and rubber can be made
from recovered materials. In addition, some jute cushions can contain recovered materials. Preattached
carpet cushion is generally made of polyurethane foam. EPA is not aware of any manufacturers currently
using recovered materials in preattached carpet cushion. EPA identified one manufacturer that plans to
offer carpet with preattached recovered-content cushion backing in 1998.
Bonded urethane is a multicolored conglomeration of scraps. According to the CCC, about 70
percent of all bonded urethane is made from recovered materials. The postconsumer content ranges from
15 to 50 percent, with 15 percent being the most common percentage. The postconsumer source is old
carpet cushion. Although manufacturers must use different machinery to make bonded urethane cushions,
some make both bonded and prime urethane cushions. Synthetic fiber cushions are made from 100 percent
recovered scrap from the carpet fabrication process or purchased from processors. Manufacturers are
unable to use postconsumer fibers because they contain latex, which manufacturers are unable to separate
from the fibers to make the cushion. Synthetic fiber cushion manufacturers do not use virgin fiber because
it is prohibitively expensive. Rubber carpet cushions are manufactured from postconsumer rubber from
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old tires. They contain 60 to 90 percent postconsumer rubber. EPA also identified one manufacturer
making jute carpet cushions from postconsumer burlap. They contain 40 percent postconsumer jute.
The CCC estimates that 700 million square yards of carpet cushion are sold each year by 32
manufacturers. EPA identified 12 manufacturers of recycled-content carpet cushion and contacted seven
of them. EPA was unable to determine the percent of carpet cushion production that is virgin or recycled.
2. Rationale for Designation
EPA believes that carpet cushion containing recovered materials meets the statutory criteria for
selecting items for designation.
a. Impact on Solid Waste
Recovered content carpet cushions are made of postconsumer urethane, recovered synthetic fiber,
and rubber from old tires. Two manufacturers indicated that their 100 percent recovered-content synthetic
fiber cushions weigh from 18 to 40 ounces per square yard. The majority of this weight consists of the
fibers. Therefore, if Federal agencies bought 10,000 square yards of carpet cushion, they would divert
1,125 to 2,500 pounds of material from the waste stream. In addition, a manufacturer of bonded urethane
cushions stated that its cushions weigh from 3 to 8 pounds per cubic foot. Federal agencies purchasing
10,000 cubic feet of bonded urethane cushions would therefore divert 30,000 to 80,000 pounds of
urethane scrap from the waste stream. A manufacturer of postconsumer rubber carpet cushions stated that
3 square yards of cushion can be made from one used tire. Agencies purchasing 10,000 square yards of
rubber cushion would divert 3,333 tires from the waste stream. Appendix I details the generation and
recovery of polyurethane, fiber, and rubber in MSW.
b. Technological Feasibility and Performance
Manufacturers indicated that their recycled-content carpet cushions perform as well as virgin
cushions in terms of cushioning and durability and meet standards set by the Carpet and Rug Institute and
the CCC. These standards include requirements for density, thickness, tensile strength, and elongation.
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Resistance to flammability is not a requirement for carpet cushion in national building codes. Commercial
carpet cushion standards differ depending on whether the cushion is Class 1, 2, or 3. Class 1 cushions are
used for moderate traffic areas such as conference rooms and executive offices. Class 2 cushions are used
for heavy traffic areas such as clerical areas and corridors. Class 3 cushions are used for extra heavy
traffic areas such as lobbies and cafeterias. Recovered-content carpet cushions perform well regardless of
whether the carpet is made of nylon, wool, or polyester fibers and are available in a variety of thicknesses.
Two manufacturers also stated that their recycled-content cushions meet specifications set by the U.S.
Department of Housing and Urban Development (HUD). EPA obtained copies of the CCC and HUD
specifications; neither appears to prohibit the use of recovered materials in carpet cushions. Both
specifications include the above requirements for bonded urethane, rubber, and synthetic fiber cushions.
c. Availability and Competition
EPA identified 12 companies that manufacture recycled-content carpet cushion. They are located
throughout the country, and their products are available through distributors nationwide.
d. Economic Feasibility
One manufacturer indicated that its carpet cushions were 10 percent less expensive than cushions containing
virgin materials. Another indicated that their cushions were priced competitively with virgin cushions.
e. Government Purchasing
GSA offers four different types of cushion on its carpet schedule: rubber, urethane, natural fiber
(e.g., hair and jute), and synthetic fiber cushions. During the 5-year period between October 1992 and
May 1997, government agencies spent approximately $1,072,091 on carpet cushion. The GSA
representative stated that many government agencies do not use cushion or buy carpet with preattached
cushion. GSA's current carpet cushion specifications do not include requirements for postconsumer
content, although GSA's representative stated the schedule does include bonded urethane cushion, which
is made from fabrication scrap. GSA expressed interest in learning of manufacturers of recovered-content
rubber carpet cushion.
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HUD has installed 100 percent recovered content carpet cushion in approximately 25 percent of its
executive office suites, although the representative contacted was not aware of the total quantity of
recovered content cushion purchased. The agency has been using recovered content cushion since 1986.
The state of Florida also has installed 100 percent recovered content carpet cushion. The state
specification for carpet cushion does not preclude the use of recovered materials; in fact, the state has
approved one brand of recovered content cushion.
f. Barriers to Purchasing
EPA did not identify any barriers to purchasing carpet cushions containing recovered materials.
g. Designation
EPA proposes to designate carpet cushion made from bonded polyurethane, jute, synthetic fibers,
or rubber containing recovered materials. A final designation would not preclude a procuring agency from
purchasing carpet cushion made from other types of materials, such as prime polyurethane foam. It
simply requires that a procuring agency, when purchasing bonded polyurethane, jute, synthetic fiber, or
rubber carpet cushion, purchase this item containing recovered materials when it meets applicable
specifications and performance requirements.
3. Procurement Recommendations
a. Recovered Materials Content
Recovered content carpet cushions made from postconsumer rubber contain 60 to 90 percent
postconsumer rubber from old tires. Synthetic fiber cushions contain 85 to 100 percent recovered
materials. Bonded polyurethane cushions contain 15 to 50 percent postconsumer polyurethane.
Table 5 presents information provided by manufacturers of carpet cushion on recycled content
availability.
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Table 5
Recovered Materials Content of Carpet Cushion
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
Synthetic Fiber
Bonded Polyurethane
Rubber
Jute
Unknown Plastic
Company A: Unknown
Company B: 100
Company C: Unknown
Company D: 10
Company E: Unknown
Company F: Up to 20
Company G: 65 - 80
Company H: 92
Company I: 80
Company J: 40
Company K: Unknown
85
Unknown
100
90
Unknown
Up to 70
Unknown
Unknown
Unknown
Unknown
80
b.
Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 6,
procuring agencies establish minimum content standards for use in purchasing carpet cushion.
Table 6
Draft Recovered Materials Content Recommendations for
Carpet Cushion
Product
Bonded
polyurethane
Jute
Synthetic fibers
Material
Old carpet cushion
Burlap
Carpet fabrication scrap
Postconsumer
content (%)
15-50
40
Total recovered materials
content (%)
15-50
40
100
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Product
Rubber
Material
Tire rubber
Postconsumer
content (%)
60-90
Total recovered materials
content (%)
60-90
c. Specifications
EPA is not aware of any performance specifications for carpet cushion.
C. Flowable Fill
1. Item Description
In response to the September 20, 1995, request for information, EPA received a number of
comments about flowable fill. The American Coal Ash Association (ACAA) maintains that flowable fill
made with coal fly ash should be designated in the CPG. The use of coal fly ash in flowable fill has proven
to be technically feasible, environmentally sound, and cost-effective in areas of the country where coal fly
ash is available. In addition, it has become so widely accepted in highway construction projects that the
ASTM and more than 20 states have developed testing methods and specifications for its use. Flowable
fill containing spent foundry sand has been used successfully in several state demonstration projects and
efforts to develop specifications for its use.
Flowable fill is a low strength material that is mixed to a wet, flowable slurry and is used as an
economical fill or backfill material. Flowable fill is also designed to support traffic without settling and yet
have the ability to be readily excavated. It is usually a mixture of coal fly ash, water, a coarse aggregate
(such as sand), and portland cement. Flowable fill flows like a liquid (similar to a watery milkshake), sets
like a solid, is self-leveling, and requires no compaction or vibration to achieve maximum density. For
some mixes, an optional filler material, such as spent foundry sand, coal bottom ash, or quarry fines, is
added. Flowable fill can take the place of concrete, compacted soils, or sand commonly used to fill around
pipes or void areas.
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Other names for flowable fill include: flowable mortar, controlled low-strength material (CLSM),
lean mix backfill, lean fill, controlled density fill, unshrinkable fill, flowable fly ash, hydraulic cement, low
strength slurry backfill, flowable backfill, and flowable grout. Applications for flowable fill include:
# Backfill:
Sewer trenches
Utility trenches
Building excavations
Bridge abutments
Conduit trenches
# Structural Fill:
Foundation subbases
Sub footing
Floor slab bases
Pipe bedding
# Other uses:
Filling abandoned wells
Filling abandoned sewers and manholes
Abandoned underground storage tanks
Voids under existing pavement
Retaining wall backfill.
EPA considered the two primary recovered materials used in flowable fill, coal fly ash and spent
foundry sand.
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Coal Fly Ash
Coal fly ash is a byproduct of burning coal to generate electricity. Flowable fill can be made with
two types of coal fly ash: Class F or Class C. Class F fly ash has a lime content of less than 10 percent.
Large amounts of Class F fly ash serve primarily as an aggregate in cementitious construction mixes.
Burning anthracite or bituminous coal, which is found primarily in the eastern United States, produces
Class F fly ash. Ready mix concrete producers in the eastern United States have access to, and therefore
primarily use, Class F fly ash. Some eastern utilities, however, have recently changed to burning
subbituminous coal, found in the western United States, to avoid installing scrubbers, since subbituminous
coal has a lower sulfur content than anthracite or bituminous coals. As a result, more Class C coal fly ash
is now being produced east of the Mississippi River.
Class C ash has cementitious properties, and the amount that can be used in flowable fill is limited
by the desired strength. When Class C fly ash is used, portland cement can be left out of the mix. Class C
fly ash typically has a lime content of 20 percent or more.
Foundry Sand
Spent foundry sand is another recovered material that can be used as an aggregate in flowable fill.
Foundry sand is clean, high quality silica sand or lake sand bonded to form molds for ferrous (iron and
steel) and nonferrous (copper, aluminum, and brass) metal castings. After casting, the sand can often
contain a number of contaminants, including residual metals and binder materials.
There are basically two types of spent foundry sand, "green" sand and chemically bonded sand.
Green sand, used in ferrous metal castings, consists of high quality silica sand, approximately 10 percent
bentonite clay (as the binder), 2 to 5 percent water, and about 5 percent sea mold (e.g., a carbonaceous
mold additive that helps improve the casting finish). Chemically bonded sand is used in nonferrous metal
castings and usually contains 97 percent foundry sand and a small amount of organic binders and
catalysts. Nearly 95 percent of all spent foundry sand is green sand.
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Technically, foundry sand from both ferrous and nonferrous metal castings can be used in flowable
fill mixtures. While both ferrous and nonferrous foundry sand can be used in flowable fill mixtures,
typically nonferrous foundry sand is hazardous because it can contain leachable phenols and heavy metals,
such as cadmium, lead, copper, nickel, and zinc. High concentrations of these contaminants may preclude
their use in flowable fill mixtures. In contrast, ferrous foundry sand is not known to be hazardous. For this
reason, EPA is limiting the designation to flowable fill containing ferrous foundry sand.
Over the past five years, states began experimenting with spent foundry sand in flowable fill
mixtures. To date, Pennsylvania, Indiana, Wisconsin, Ohio, and New York have all reported successes
using spent foundry sand, as a replacement for natural sand, in flowable fill applications. Illinois,
however, has attempted to use spent foundry sand in flowable fill mixtures and found that it is unsuitable
due to poor performance and economics.
2. Rationale for Designation
EPA believes that flowable fill containing recovered materials meets the statutory criteria for
selecting items for designation.
a. Impact on Solid Waste
Coal Fly Ash
In 1995, approximately 54.2 million tons of coal fly ash were generated. As shown in Appendix I,
approximately 13.6 million tons, or 25 percent of the coal fly ash generated, were recovered and used in
concrete or other building materials and transportation applications. Coal fly ash is also
used in cement and concrete production, roadbase and subbase construction, structural fills and
embankments, filler in asphalt mixes, grouting, and waste stabilization applications. About 300,000 tons
of recovered coal fly ash were diverted from landfills in 1995.
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Foundry Sand
Annual generation of foundry sand has been estimated at between 6 and 15 million tons. Flowable
fill mixtures generally contain between 50 and 85 percent foundry sand. The actual volume used, however,
depends on the type of fly ash used and the performance requirements for the flowable fill. According to
contacts from Wisconsin, the amount of foundry sand used in flowable fill applications is rather small.
Generally, only 100 to 300 tons of sand are used per project. Foundry sand is also being used as a fine
aggregate substitute in construction applications, as kiln feed in the manufacture of portland cement, as a
bulking agent for compost, and as supplemental cover material at landfill sites. The Federal Highway
Administration (FFiWA) estimates that approximately 20 percent of the spent foundry sand generated is
recycled. Appendix I of this document details the amount of coal fly ash and foundry sand in the solid
waste stream.
b. Technological Feasibility and Performance
Coal Fly Ash
According to FFiWA, substantial information has been accumulated regarding the use of coal fly
ash over the past 10 years. Flowable fill has been used both on land and in water with excellent success.
Flowable fill containing coal fly ash outperforms flowable fill made with only portland cement or sand,
according to most of the manufacturers and engineers EPA contacted. Coal fly ash gives flowable fill
qualities that are superior for many types of jobs. For example, flowable fill can be excavated, code-dyed
for later excavation, and can act as an emulsifier, allowing the fill to flow as a distinct unit.
Flowable fill mixes are usually designed based on the percentage of coal fly ash by dry weight. High
fly ash mixes generally contain 95 percent fly ash and 5 percent portland cement. Low fly ash mixes have a
broader range of mix proportions because they usually contain fillers other than fly ash (e.g. sand). Tables
7 and 8 present what the FHWA considers typical proportions for high and low ash content mixes:
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Table 7
Typical Proportions for High Fly Ash Content Mixes
Component
-------
Flowability is a function of the water content. In general, it is desirable to design the mixture to be
as flowable as possible to take advantage of the self-compacting qualities of flowable fill. Time of set
relates directly to the mixture's cement content. Generally, high coal fly ash mixes containing 5 percent
Portland cement achieve sufficient set to support the average adult male in 3 to 4 hours, depending on the
temperature and humidity. After 24 hours, construction equipment can move across the surface without
damage. In some instances, low fly ash mixes containing high calcium fly ash have been set within 1 to 2
hours after placement. For both mixes, particularly high fly ash mixes, increased cement content or
decreased water content, or both, should reduce the setting time.
Bleeding and shrinkage is possible in high fly ash mixtures with relatively high water contents.
Evaporation of the bleed water can result in shrinkage up to 10.42 mm/m (1/8-in/ft) of depth of the fill.
Shrinkage can occur laterally and vertically, but no shrinkage or long-term settlement of the flowable fill
mixture occurs after the initial set.
Flowable fill is generally mixed to support 50 to 100 psi. In specific applications, contractors can
limit the strength of the mix so that later excavation of the hardened flowable fill will be possible. The
strength can be controlled by altering the amount and portland cement of Class C coal fly ash, which have
cementitious properties.
Flowable fill hardens more quickly than concrete, shortening work time and traffic disruption where
applicable. Depending on the amount of portland cement in the flowable fill mixture, it can gain strength in
as quickly as 20 minutes; concrete, by contrast, takes at least 4 hours to gain strength.
Foundry Sand
Engineering properties that must be considered when using spent foundry sand in flowable fill
mixtures include the following:
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# Particle Shape. The grain size distribution of spent foundry sand is more uniform and
somewhat finer than conventional concrete sand. The fineness of foundry sand
contributes to good suspension, thus limiting segregation of flowable fill. The spherical
shape of spent foundry sand contributes to good flow characteristics. The fineness of the
particles, however, results in lower strength or bearing capacity of hardened flowable fill.
In addition, foundry sand usually contains a high concentration of heavy metals, which
may limit its usability in flowable fill applications.
# Strength Characteristics. Although some organic binder materials can interfere with
cement hydration, low (rather than high) strength development is, in most cases, more
desirable with flowable fill to permit excavation at a later date (for utility repairs and
maintenance). It has been reported that the flowable fill incorporating spent foundry sand
aggregates, fly ash, a small quantity of portland cement, and water readily satisfies
specified limited strength criteria.
# Soundness. The performance of spent foundry sands in soundness tests depends on the
amount of clay binder materials present in the spent foundry sand, the amount of
clustering of the fines, and the coating on the individual particles. The greater amount of
clay binder or clustering, or the thicker the coatings, the higher the soundness loss.
Regardless, spent foundry sands generally exhibit favorable performance in soundness
testing, with soundness losses of less than 10 percent (indicative of durable aggregate).
# Deleterious Substances. Poorly managed spent foundry sand could contain
objectionable materials such as wood, garbage, metal, carbon, and dust as well as large
chunks of sand. For use in flowable fill, spent foundry sand must be managed to ensure
that the sand is clean and processed to the proper size. Foundry sand is often
contaminated with up to 12 percent organic material.
# Corrosivity. Depending on the binder and type of metal cast, the pH of spent foundry
sand can vary from approximately 4 to 8. It has been reported that some spent foundry
sand can be corrosive to metals. Others have indicated that flowable fill mixes containing
spent foundry sand, due to the absence of chlorides and high pH values are noncorrosive
in nature, usually between 11.4 and 12.3.
c. Availability and Competition
Coal Fly Ash
Ninety percent of the roughly 3,000 ready mix producers in the United States make some type of
flowable fill. An estimated 65 to 75 percent of ready mix producers utilize coal fly ash, and roughly 55 to
65 percent of ready mix producers use some type of coal fly ash in flowable fill. An engineer at
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FHWA estimated that about 20 states currently use flowable fill and several others are currently studying
the material. Flowable fill made with foundry sand (and coal fly ash) currently is available in parts of New
York, Ohio, Indiana, Wisconsin, and Pennsylvania.
Coal fly ash is available in most parts of the country. There are approximately 460 coal-fired
utility generation stations in the United States. Sparsely populated states, however, may not have a local
source of coal fly ash to make flowable fill use practical. EPA identified 17 coal fly ash marketers.
Foundry Sand
Spent foundry sand is available from all foundries. Most foundries are located in the Midwest,
particularly in Illinois, Wisconsin, Michigan, Ohio, and Pennsylvania.
d. Economic Feasibility
The two main factors in determining the economic feasibility of using recovered materials in
flowable fill are transportation and labor costs. Transportation costs for flowable fill made with coal fly
ash or foundry sand will vary depending on the distance from those materials to the project site. For
example, a contact from Montana stated that it would not be economically feasible if the source of the
material is more than 150 miles away. Another contact from Wisconsin claims that, because natural fill
materials are abundant (particularly in the western part of the state), the source of the recovered material
would have to be within 30 to 40 miles of the project site to make it economically feasible.
In general, it is not the cost of the recovered material used in flowable fill that is prohibitive but
rather the cost of flowable fill compared with natural fill materials. Flowable fill mixtures can cost
anywhere from $30 to $40 per cubic yard, whereas, natural fill materials usually cost between $2 and $10
per cubic yard. Thus, unless contractors have accounted for labor costs associated with placement of the
material and future labor and maintenance costs, they are likely to use the less expensive natural fill
material.
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The use of flowable fill can, however, save on future labor and maintenance costs. Concrete is more labor-
intensive than flowable fill, because flowable fill can be poured into any size tench with machinery and requires no
manual labor or compaction. Concrete, on the other hand, requires manual labor to smooth its surface and to
compact it in tenches, which must be made large enough to safeguard against cave-ins. Flowable fill does not require
inspection or compaction, and it sets more quickly than concrete.
e. Government Purchasing
State and local transportation departments are one of the largest markets for flowable fill, and they
use Federal funds for road repair and construction. EPA contacted several state and county transportation
departments. Erie County, in Buffalo, New York, uses flowable fill with coal fly ash and foundry sand in
specific applications. California anticipates that its coal fly ash usage will be 1,288 tons and flowable fill
usage will be 2,644 tons for the years 1997 and 1998. Illinois reported wide usage of Class C fly ash in
flowable fill mixes but was unable to provide estimated usage figures. Colorado, Delaware, Florida,
Kentucky, Minnesota, and New Hampshire reported minimal use of flowable fill in the last few years, but
also reported that coal fly ash is part of these states' mixes. Georgia recently wrote a flowable fill
specification and has used it in specialized cases. Flowable fill with coal fly ash recently passed the
specification committee in Indiana. Montana reported very minimal use of flowable fill and no use of coal
fly ash in its current flowable fill mixes.
f. Barriers to Purchasing
The main barriers to purchasing flowable fill containing coal fly ash or foundry sand are the cost
of transportation and the perceptions of highway construction contractors.
In some parts of the country, in areas far from sources of coal fly ash, it might be too expensive
because of high transportation costs. Also, flowable fill, once mixed and on the truck, is not practically
usable if it must be hauled over 30 miles to the construction site, since it hardens so quickly. Soil, lime,
natural sand, or other materials are often less expensive and more accessible in some areas for use as a fill
material. Volumetric mixer trucks, storage silos, or other specialized equipment may be necessary but
unavailable in some areas, or too expensive for a department to purchase.
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In addition, soil, sand, and concrete have been used as fill materials for decades, and the
construction industry is generally resistant to the use of new materials. Although EPA found many states
that allow flowable fill to be used, flowable fill is not yet widely used, according to a senior engineer at
FHWA. One reason is that, currently, there is not a very high level of understanding of flowable fill.
Designation could help facilitate knowledge and awareness of the benefits of using flowable fill made with
coal fly ash and foundry sand.
g. Designation
In CPG III, EPA is proposing to designate flowable fill containing recovered coal fly ash and/or
ferrous foundry sands. A final designation would not preclude a procuring agency from purchasing other
types of fill materials, such as conventional concrete or compacted soil. It simply requires that a
procuring agency, when purchasing or contracting for the use of flowable fill, purchase this item
containing recovered materials when it meets applicable specifications and performance requirements.
3. Procurement Recommendations
a. Recovered Materials Content
Coal Fly Ash
The percentage of coal fly ash in flowable fill varies a great deal and depends on the strength
needed for the job. A range of 22 percent to 88 percent coal fly ash in flowable mixes is used by one
manufacturer. One ash marketer quoted a range of 5 to 95 percent coal fly ash in flowable fill. FHWA's
Fly Ash Facts for Highway Engineers also quotes a range of 6 to 95 percent fly ash in different flowable
fill mixtures. Most manufacturers, marketers, and engineers were very reluctant to provide even rough
estimates, since coal fly ash content in flowable fill can vary widely depending on the properties needed in
the finished product.
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Foundry Sand
The amount of spent foundry sand in flowable fill mixtures can also vary. According to a study
conducted by the University of Wisconsin's Center for Byproducts Utilization, flowable fill "can be
manufactured using foundry sand as a replacement of fly ash up to 85 percent."
Table 9 presents information provided by manufacturers of flowable fill on recycled content
availability.
Table 9
Recovered Materials Content of Flowable Fill
Material
Coal Fly Ash
Foundry Sand
Postconsumer Content (%)
Company A: 22-88
Company B: 5-95
Company C: 50-85
Company D: Unknown
Total Recovered
Materials Content (%)
Unknown
Unknown
Unknown
Unknown
b.
Preference Program
EPA recommends that procuring agencies use flowable fill containing coal fly ash and/or ferrous
foundry sands for backfill and other fill applications. EPA further recommends that procuring agencies
include provisions in all construction contracts involving backfill or other fill applications, to allow for the
use of flowable fill containing coal fly ash and/or ferrous foundry sands, where appropriate.
The specific percentage of coal fly ash or ferrous foundry sands used in flowable fill depend on the
specifics of the job, including the type of coal fly ash used (Class C or Class F); the strength, set time, and
flowability needed; and bleeding and shrinkage. Therefore, EPA is not recommending specific coal fly ash
or ferrous foundry sands content levels for procuring agencies to use in establishing minimum content
standards for flowable fill. EPA recommends that procuring agencies refer to the mix proportions in
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Tables 7 and 8 for typical proportions for high and low coal fly ash content mixes. EPA further
recommends that procuring agencies refer to American Concrete Institute (ACI) report ACI 229R-94 for
guidance on the percentages of coal fly ash that can be used in flowable fill mixtures. Among other things,
ACI229R-94 addresses materials, including coal fly ash and foundry sands, mix design, and mixing,
transporting, and placing. It also provides examples of mixture designs containing coal fly used by the
states of Iowa, Florida, Illinois, Indiana, Oklahoma, Michigan, Ohio, and South Carolina. "Fly Ash Facts
for Highway Engineers" addresses materials, strength, flowability, time of set, bleeding and shrinkage.
A mix design for the use of foundry sand and coal fly ash in flowable fill was developed for Ford
Motor Company. Procuring agencies can obtain a copy of this design by contacting the RCRA Hotline at
800 424-9346. Table 10 provides the recommended trial mixture from this specification.
Table 10
Materials Quantities for Flowable Fill Mixture Containing Foundry Sands and Coal Fly Ash
Component
Cement
Coal fly ash
Foundry sand
Water
Quantity
per Cubic Yard
50 Ibs.
250 Ibs.
2850 Ibs.
500 Ibs.
c. Specifications
Coal Fly Ash
Several technical organizations have, or are developing, specifications for flowable fill containing
coal fly ash, including The American Concrete Institute (ACI), The American Association of State
Highway and Transportation Officials (AASHTO), and ASTM.
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EPA recommends that procuring agencies use ACI229R-94 and the ASTM standards listed in
Table 11 when purchasing flowable fill or contracting for construction that involves backfilling or other
fill applications.
Table 11
Standard Specifications, Test Methods, and Practices for Flowable Fill
ASTM Specification Number
D4832-95el
D 5239-92
D 5971-96
D 6103-07
D 6023-96
D 5971-96
D 6024-96
Title
Standard Test Method for Preparation and Testing of Controlled
Low Strength Material (CLSM) Test Cylinders
Standard Practice for Characterizing Fly Ash for Use in Soil
Stabilization
Standard Practice for Sampling Freshly Mixed Controlled Low
Strength Material
Standard Test Method for Flow Consistency of Controlled Low
Strength Material
Standard Test Method for Unit Weight, Yield, Cement Content
and Air Content (Gravimetric) of Controlled Low Strength
Material (CLSM)
Standard Practice for Sampling Freshly Mixed Controlled Low
Strength Material
Standard Test Method for Ball Drop on Controlled Low Strength
Material (CLSM) to Determine Suitability for Load Application
EPA has also identified more than 20 states with specifications for flowable fill containing coal fly
ash. These specifications generally vary from state to state. For example, some states require the coal fly
ash to be tested prior to its use, while others "maintain lists of approved sources and accept project
suppliers' certifications of fly ash quality," according to FFiWA's Fly Ash Facts for Highway Engineers.
States with specifications for flowable fill containing coal fly ash include: California, Colorado, Delaware,
Florida, Georgia, Illinois, Indiana, Kansas, Kentucky, Maryland, Massachusetts, Michigan, Minnesota,
Nebraska, New Hampshire, New Mexico, North Carolina, Ohio, Texas, Washington, West Virginia, and
Wisconsin. According to Fly Ash Facts for Highway Engineers "virtually any coal fly ash can be used in
flowable fill mixes."
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There are two basic types of flowable fill containing coal fly ash, high ash content and low ash
content. High fly ash content mixes generally contain coal fly ash, a small amount of portland cement, and
enough water to make the mixture flowable. Low coal fly ash content mixes contain a higher percentage of
filler material (e.g., sand), small amounts of coal fly ash and portland cement, and enough water to make it
flowable. ACI's CLSM specifications, mentioned above, are for a low coal fly ash mixture.
Foundry Sand
Currently, no national test methods or specifications exist for the flowable fill mixtures containing
foundry sand. Ohio is the only state EPA identified that has a specification for "Flowable Fill Made with
Spent Foundry Sand." Pennsylvania, Wisconsin, and Indiana, however, are all working on developing
specifications. The Pennsylvania Department of Transportation and Pennsylvania State University are just
beginning a 4-year "materials durability testing and analysis" study to help them develop specifications. In
addition, a group from the University of Wisconsin's Geotechnical Information Center is working with
Wisconsin's Department of Transportation to collect data to develop standard mix proportions,
specifications, and performance requirements for spent foundry sand used in flowable fill applications.
This study is completed, and the report is currently in draft format.
The FHWA is also in the process of developing guidelines to promote the use of flowable fill
containing foundry sand. The following information has been gleaned from FHWA's preliminary draft
guidance document but should only be used as a general overview of some of the technical issues
surrounding the use of spent foundry sand in flowable fill mixtures:
Foundry sand must be processed prior to its use in flowable fill mixtures. Spent
foundry sand should be free of foreign materials, burnt carbon, binders, and mold
additives that may inhibit cement hydration. Foundry sand from ferrous operations
needs to be screened and any oversized material removed. Before it can be used in
flowable fill, spent foundry sand usually needs to be blended with natural or other
fine aggregate to meet the gradation requirements specified by ASTM C33-93,
Standard Specification for Concrete Aggregates.
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D. Railroad Grade Crossing Surfaces
1. Item Description
Railroad grade crossings are surfacing materials placed between railroad tracks, and between the
track and the road at highway and street railroad crossings, to enhance automobile and pedestrian safety.
Railroad grade crossings are made, typically, of sectional treated timber, full wood plank, asphalt,
concrete slab, concrete pavement, rubber, or metal (see definitions below). According to a September,
1996, Federal Railroad Administration (FRA) report, the majority of railroad grade crossings surfaces in
the United States are asphalt. Wood is the second most prevalent material used, followed by rubber and
concrete. According to an official with FFiWA, the trend in railroad grade crossings is towards concrete,
specifically concrete modular systems that can be disassembled. The number of concrete railroad
crossings has increased in recent years due to changes in railroad preferences, advances in technology, and
increasingly competitive pricing.
EPA contacted several organizations to ascertain their preference or policy position on railroad
crossing materials. A contact at AASHTO indicated that they follow and endorse the positions held by
FFiWA. A representative with the American Public Works Association (APWA) reported the organization
does not have an official position, and an official with the American Roads and Transportation Builders
Association (ARTBA) reported the same.
Table 12 summarizes FRA's inventory of more than 168,000 public railroad crossings in the
United States by material type.
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Table 12
Public Crossings by Crossing Surface:
Calendar Year 1995
Crossing Surface
Asphalt
Sectional Treated Timber
Full Wood Plank
Rubber
Concrete Slab
Concrete Pavement
Metal
Unconsolidated (crushed stone)
Other
Total
Number of Crossings
84,361
27,100
25,203
6,535
2,208
796
340
16,540
834
163,917
Source: FRA, 1996
Definitions
FRA provides the following standard definitions for the different crossing surfaces:
# Sectional Treated Timber. Prefabricated units, approximately 8 feet in length, of treated
timber individually installed and removable for maintenance and replacement purposes.
# Full Wood Plank. Wood surface, other than sectional treated timber, covering the entire
crossing area above the crossties. Crossties are the wooden or concrete supports upon
which the track rails rest.
# Asphalt. Asphalt surface over the entire crossing area, or in the area between the planks or
other materials forming flangeway openings, with or without single planks on outside of
running rails. Flangeways are formed parts of the rail that eliminate contact of the running
rails with crossing surface materials.
# Concrete Slab (also "Panel" or "Modular"). Precast concrete slabs that are removable,
individually, for maintenance and replacement purposes.
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# Concrete Pavement (also "Tub" or "Platform"). Concrete surface that is continuous
over the track area and removable only by destruction of the surface.
# Rubber Slabs. Preformed rubber sections that are removable, individually, for
maintenance and replacement purposes.
# Metal Sections. Preformed sections of steel or other metal that are removable,
individually, for maintenance or replacement purposes.
# Unconsolidated. Ballast or other unconsolidated material (commonly crushed stone) placed above
the tops of crossties, with or without planks on one or both sides of the running rails.
# Other. Surfaces other than the above: structural foam, plastic, etc.
2. Rationale for Designation
EPA believes that railroad grade crossing surfaces containing recovered materials meet the
statutory criteria for selecting items for designation.
a. Impact on Solid Waste
Railroad grade crossings are manufactured with recovered rubber, coal fly ash, and steel. As
discussed in Appendix I of this document, these items comprise a significant portion of the solid waste
stream. The information obtained by EPA indicates that it is not feasible to use reclaimed asphalt in
asphalt railroad grade surface crossings because asphalt recycling equipment is designed for operation on
highways and roads, not on smaller projects such as railroad crossings. EPA does not believe that crumb
rubber modified asphalt can be used in railroad grade crossings because of cost and performance
constraints. EPA requests information on the use of either reclaimed asphalt or crumb rubber modified
asphalt in railroad grade crossing surfaces.
The majority of coal fly ash is produced in electric generating plants, where powdered coal is
burned to produce steam to drive the turbines. Coal fly ash typically represents about 75 percent of the
ash generated by coal combustion, with coarser, heavier bottom ash accounting for the remaining 25
percent. ACAA estimates that 54.2 million tons of coal fly ash were generated in 1995. Approximately 25
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percent of this material (13.6 million tons) was recovered and the remaining 40.6 million tons were stored
or disposed of. No figures are available on the amount of coal fly ash recovered for use in railroad
crossings. A 9 by 9-foot concrete panel, however, reportedly weighs approximately 7,000 pounds. A
common railroad crossing configuration involves three panels of this size. Thus, if a company were to use
cement with 15 percent coal fly ash content, each panel would contain 1,050 pounds of the recovered
material, and a crossing consisting of three panels would divert 3,150 pounds of coal fly ash from the
solid waste stream.
Rubber railroad grade crossing surfaces contain tire buffings from tire retreading operations, crumb rubber
from scrap tires, and off-specification virgin rubber. As with coal fly ash, there are other uses for scrap tires and
other applications for crumb tire rubber. However, additional markets for crumb rubber are needed.
All domestic steel contains recovered materials. Depending on the process used to manufacture the
steel, the railroad grade crossing surface can contain up to 100 percent recovered steel.
b. Technological Feasibility and Performance
Traditionally, wood and asphalt crossings have dominated the marketplace due to their low initial
cost. In the past few years, the railroad industry has changed its orientation from lowest initial cost
towards obtaining the best performance from grade crossings, which includes reusability. Since fuel costs
are a significant portion of a railroad's operating budget, the industry relies on routine track maintenance
to create a smoother track surface, which, in turn, increases fuel efficiency. The marketplace has moved to
greater use of concrete and rubber grade crossings due to their reusability after track maintenance, unlike
asphalt and wood which normally are removed and disposed of.
Rubber
According to one manufacturer of rubber railroad grade crossings, the average lifespan of a rubber
crossing is estimated to be 10 to 15 years. This life expectancy is based on the original quality of the
material; the application; traffic patterns (notably the presence of trucks); vehicular speeds; condition
(e.g., roughness) of the approach to the crossing; and the quality and condition of the sub-ballast,
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the ballast, the ties, and the rails. Ballast is material placed on a track roadbed to hold the track in
alignment and keep it elevated. Sub-ballast is the material upon which the ballast is laid, usually gravel,
cinders, or sand. Proper drainage and well-supported ties will significantly increase the life of the crossing.
Although not specific to recovered content rubber railroad crossings, a FHWA report issued in
1979 stated, "...a crossing constructed with one of several types of manufactured crossing surfaces,
although much higher in initial cost, will provide superior riding quality for even high speed and high
density vehicular traffic and generally will require minimum maintenance if the original installation is
made on a well-prepared track structure with good subgrade conditions." The same report also stated,
"...the additional cost of a proprietary crossing (e.g., rubber crossings) may well be warranted by the
longer life of the material, lower maintenance costs, superior riding quality, or a combination of these
features." According to a manufacturer, in general, full depth rubber crossings, where the height of the
rubber is even with the height of the rail, stay in place better than other crossings, provide a smoother
crossing, are easier to remove and replace (compared to other surfaces), and will not deteriorate as
rapidly. Full depth rubber crossings do not require shims, which are additional thin wooden panels that are
located between the rubber and the crossties.
In general, contacts agreed that rubber crossings are preferable for roads with lighter traffic flow
and lighter vehicles. Municipalities appear to favor full depth rubber crossings, as they provide a
smoother, quieter ride for passenger vehicles. One contact representing a major railroad, reported that,
although they do not typically use rubber railroad crossings on heavily traveled roads or those used by
heavy vehicles, they find them applicable on roads with lower traffic levels. According to two different
railroad company officials, however, rubber crossings are particularly suitable at crossings where there is
a curve in the track or where two tracks cross each other, typically called a railroad diamond or interlock.
In these cases, a flexible material is essential and rubber is usually the best choice, regardless of the level
of traffic.
EPA's research uncovered mixed opinions about the performance of rubber railroad crossings. A
railroad company official indicated that virgin rubber is somewhat more flexible than recovered content
rubber and it wears a little better. He stated, however, that recovered content rubber crossings are slightly
less expensive than virgin rubber crossings, and the performance differences were not pronounced. Only
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one manufacturer of rubber railroad grade crossings, of the four contacted, explained that they no longer
produce crossings made of tire buffings or crumb rubber, because they were finding it difficult to meet the
performance standards of nonrecovered content rubber. In particular, he noted difficulty in obtaining
comparable physical properties, such as tensile strength. The company now manufacturers rubber railroad
crossings only from uncured stock (off-spec) rubber.
A few states contacted by EPA expressed reservations regarding rubber railroad crossings, regardless of
the recovered content. An official with the Massachusetts Highway Department reported that a newly installed
recovered content rubber crossing was torn up by a snow plow, and another that had been in place for 6 months
did not hold up well. However, the source indicated that these problems were most likely due to improper
installation, not the recovered content. A Georgia Department of Transportation official reported that rubber is
sometimes used by shortline railroads and less traveled roads in the state. He indicated, however, that rubber
crossings can be problematic if not installed correctly. They do not hold up well under heavy loads or if
exposed to natural elements, such as salt from shoreline areas. The New York State Department of
Transportation has found that virgin rubber can be more readily produced in uniform quality and density than
recovered rubber. Furthermore, an employee with the railroad section of the Texas Department of
Transportation reported that the state is no longer purchasing any type of rubber railroad crossings. In his
opinion, using recovered content rubber for products that require strength properties is hindered by the use of
steel belts in tires. He said he has witnessed situations where bits of steel have ended up in the final product,
resulting in reduced strength properties. An official with the Florida Department of Transportation indicated
that the state has been using full-depth rubber crossings for the past ten years on roads with high average daily
traffic and they have held up fairly well with few problems. However, he pointed out that the rubber crossings
they currently purchase are manufactured from virgin material. They had purchased the recycled content shim-
type crossings prior to ten years ago, but found that the wood shims rotted and resulted in an unstable crossing,
so they switched to full-depth rubber. Finally, an official with the Vermont Department of Transportation
reported that the state is no longer purchasing the recycled content rubber crossings they had been procuring
several years ago. He said that the state found them to be slippery and to wear out quickly in 5 to 6 years. As
mentioned earlier, although many states have preferences for certain types of crossings in specific situations,
ASTM specifications are not normally considered by states. The contact from New York, however, indicated
that they do have requirements to meet the minimum ASTM and other specifications used by certain
manufacturers.
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Several of EPA's contacts have had positive experiences with rubber railroad grade crossings. The
following summarizes the positive comments conveyed by those contacted by EPA.
# City of Prineville, Oregon. The city has seven recovered content rubber railroad crossings in
place along a shorfline railroad that runs through Prineville and two neighboring counties. A
city official reported that they are very pleased with the performance of the crossings, which
have been in place for 5 to 7 years. He reports that they are durable and have shown no signs
of wearing or cracking. The official said that he prefers rubber over asphalt or wood, because it
has a higher life expectancy and is more durable. The city also uses concrete crossings, but
these have not been in place long enough to evaluate their performance.
# Delta Railroad Construction, Ashtabula, Ohio. This railroad contractor has installed
many rubber crossings, especially in the Boston area. An official with the company
reported that the recycled content rubber crossings they have installed have performed
reasonably well and are suitable for most applications, except for crossings with heavy,
industrial-type traffic.
# Long Island Railroad, New York. The railroad maintains more than 300 recovered
content rubber railroad crossings over 594 miles of mainline track. A railroad official
stated that the newer full-depth rubber crossings have held up fairly well and are quite
durable. The railroad began using recovered content rubber crossings comprising a shim
and a rubber pad about 10 to 15 years ago. This product consisted of wooden shims on the
railroad ties, a 2-1/2 inch rubber pad, and steel spikes driven into the rubber and ties. They
witnessed problems with these crossings because the wood shims would deteriorate over
time, making the crossings unstable. Several states experienced similar problems with this
type of crossing. For the past 4 years, however, the railroad has purchased full-depth
recovered content rubber crossings and has been satisfied. The only problem they have
observed has been with rubber peeling away from the steel used as reinforcement inside
rubber crossings. Although this problem had the potential to affect performance and
safety, it was expeditiously corrected. The railroad official indicated, however, that the
problem may have been due to improper installation.
Concrete
Concrete crossings can be found throughout North America in applications ranging from the most basic
rural environments to premium crossing configurations in metropolitan areas. Most are "panel" designs, where
the concrete is separated into modular panels that rest on top of the railroad ties. The other type of concrete
crossing is known as a "tub-type" or "platform" crossing, which replaces the entire track structure through the
crossing.
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EPA contacted four manufacturers of concrete railroad crossings and spoke with 10 state
department of transportation officials and railroad companies concerning their experiences with concrete
crossings. A manufacturer that uses coal fly ash in the concrete mixture stated that coal fly ash helps
produce a more workable and durable product that helps preclude the absorption of moisture into the
concrete, which helps prevent cracking and prolongs the life of the crossing. The use of coal fly ash also
contributes to the product's ability to resist temperature fluctuations and freeze and thaw cycles. While the
contact found no technical barrier to the use of coal fly ash, he identified a practical barrier in that coal fly
ash is not readily available in all areas of the country.
While state department of transportation officials were unsure whether the concrete used in the
concrete crossings they purchased contained coal fly ash, generally they have had positive experiences
with concrete crossings. The Louisiana Department of Transportation has installed modular concrete
railroad crossings over the last 3 to 4 years and has experienced only one design-related problem,
unrelated to the type of material: the approach put too much stress on the crossing. Concrete is their
primary choice for high to moderate volume areas. The New York State Department of Transportation
also has had success with modular unit concrete crossings. Slow speed shortlines in the state have found
the product more resistant to damage by snowplows. They also have found the product to be chemically
and mechanically resistant to freeze and thaw cycles on heavily salted roadways.
A Georgia Department of Transportation official added that, although they use mostly asphalt and
timber for crossings, the trend among the southeastern states is towards concrete. Based on personal
research on the use of concrete crossings, this official recommends concrete or rubber as the preferred
choice for railroad crossing improvements. In addition, one railroad contractor stated that there are
excellent concrete crossings available and that they are highly durable, lasting 20 to 30 years on average.
According to one manufacturer, concrete offers advantages in price, longevity, and ease of
installation. Another manufacturer of concrete modular systems claims that the product is much more
durable than asphalt.
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A few of the individuals EPA contacted had negative remarks concerning concrete railroad
crossings. One railroad official stated that concrete is more difficult to repair compared to rubber, because
of the weight of the concrete. Although modular crossings may be removed and replaced, their weight is
somewhat prohibitive. He added that heavy machinery is required to remove the cement slabs and that
smaller rail lines are unlikely to have this equipment. One manufacturer stated that special attention must
be given to the design and installation of precast concrete slab crossings to avoid the tendency of some
slab units to rock after a period of use. With a modular system, the crossing sits on the ties and is
dependent on the ties and fasteners for support. As the ties and fasteners deteriorate over time, the
concrete may become unstable. Platform concrete systems, which replace the entire crossing, must be
removed and disposed of during track maintenance. For this reason, this manufacturer only sells the
product to port authorities and slow speed tracks that will not require maintenance as frequently.
Asphalt
At crossings with heavier traffic, asphalt requires more attention than concrete or rubber to
maintain a smooth riding surface. Without frequent maintenance, rough surfaces result, posing safety
concerns. Conversely, asphalt crossings work very well under light traffic conditions and where train use
and weight is low enough not to require frequent resurfacing. As with other surfaces, the lifespan of
asphalt crossings is dependent on the condition of the subgrade and on traffic conditions. It is difficult to
gauge the lifespan of asphalt crossings because they may be removed for track maintenance before the life
of the material has expired. If left in place for a period of time, asphalt tends to degrade faster than rubber
or concrete under similar conditions.
Metal
Steel is the most commonly used material in metal railroad grade crossings. Steel sections can be
removed and replaced to allow for better aeration, compared to rubber, of the ballast and roadbed section,
but they can be subject to rapid corrosion and are sometimes difficult to hold in place. Steel is used
relatively infrequently and accounts for less than 0.50 percent of all railroad crossings. One contact stated
that steel is not commonly used because it offers poor resistance for vehicle tires during skids.
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Wood
Wood plank crossing surfaces can be continually maintained by replacement of deteriorated or
worn planks one at a time. The disadvantage is that the wood plank crossing cannot be removed in one
section for track maintenance and then be replaced. Wood plank crossings may deteriorate rapidly under
medium rail traffic or truck crossings.
Prefabricated sectional treated timber crossings permit the removal and replacement of individual
panels for maintenance and replacement purposes and provide good service at locations with moderate to
heavy highway and railroad traffic. The panels are generally thick enough not to require shims, thus
providing a smooth, stable crossing surface. In some heavy traffic locations, excessive wear might occur
in the normal vehicle track areas. Although no longer a concern in most states, wear might be severe in
locations where studded tires are permitted.
c. Availability and Competition
EPA identified three manufacturers of rubber railroad crossings containing recovered materials, all
of which offer their products nationwide. Two companies manufacture crossings from tire buffings and
crumb rubber, utilizing 20 to 25 million pounds and 10 to 11 million pounds of feedstock annually,
respectively. The third manufacturer uses approximately 3 to 4 million pounds of tire buffings in the
manufacture of railroad crossings.
EPA identified numerous companies that manufacture or distribute concrete railroad crossings,
with at least two that use coal fly ash. Many companies that distribute concrete railroad crossings contract
with ready mix manufacturers and are less aware of the material content of the concrete. However, one
manufacturer of concrete crossings reported that, of the four concrete suppliers it uses, three use coal fly
ash. There are about 3,000 ready mix producers in the United States. According to ACAA, an estimated
65 to 75 percent of ready mix operators utilize coal fly ash in a variety of products.
Steel used to manufacture railroad grade crossings contains up to 20 percent recovered materials.
Almost all steel produced in U.S. steel mills currently contains recovered material.
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d. Economic Feasibility
Asphalt and prefabricated sectional treated timber crossings are the least expensive materials and have
the lowest installation cost. Industry experts estimate material costs ranging from $35 to $60 per track foot for
asphalt and $50 to $75 per track foot for timber. Asphalt and prefabricated sectional treated timber crossings
must be completely torn out during work on the track, however. If track
maintenance is required frequently, asphalt can become much more expensive in the long run. Wood is also a
fairly inexpensive option, but is subject to splitting and splintering, requiring more frequent maintenance.
The initial cost of rubber and concrete crossings is high, especially compared to asphalt. The
higher upfront costs, however, may be offset by the longer lifespan of rubber and concrete crossings.
According to railroad contacts, material costs are often the least expensive portion of a crossing
installation. The total cost of a crossing will likely be $1,200 to $1,500 per track foot. Material costs per
track foot will range from $150 to $200 for concrete and from $160 to $210 for rubber crossings.
Concrete containing coal fly ash is economically available in most areas of the country. Its use, however,
may be limited by transportation issues and manufacturer material preferences. According to ACAA,
more than half of the ready mix concrete producers use coal fly ash. One manufacturer stated that a major
drawback to using coal fly ash in their area is that it is more expensive and prolongs the curing process,
including how the concrete is handled when poured. The manufacturer added, however, that a low
percentage of coal fly ash, such as 15 percent, used in concrete would not have an effect on the curing
process, but would still change the structure of the mixture slightly. Recovered content rubber crossings
tend to be slightly less expensive that those made of virgin rubber. Most rubber and concrete crossings are
modular and can be removed and then reinstalled following track maintenance. Although heavy equipment
is required to handle the modular sections, the consolidation of railroad companies has made that
equipment more available.
e. Government Purchasing
EPA identified five state departments of transportation, two Class I railroads, two regional and
shortline railroads, two passenger railroads, and two cities and counties that are currently using railroad
crossings with recovered content rubber. A Class I railroad is defined as a freight railroad that has
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revenues greater than or equal to $250 million, although this amount changes depending on fluctuations in
the inflation rate. Although EPA also identified five state departments of transportation using concrete
railroad crossings, none of the officials knew if the crossings contained coal fly ash. Based on EPA's
research, it is likely that at least some of the crossings contain coal fly ash.
Funds for the purchase of railroad grade crossings are available under the Intermodal Surface
Transportation Efficiency Act of 1991 (ISTEA) Surface Transportation Program. Funds are apportioned
to states by a legislatively prescribed formula based on state land area, population, rural road mileage, and
total number of public railroad-highway grade crossings in the state. At least 10 percent of the Surface
Transportation Program funds authorized by ISTEA must be set aside for carrying out Rail-Fiighway
Crossings and Hazard Elimination programs. Of this amount, states must reserve for each of the two
programs at least as much as was apportioned for each program in 1991. If a state's 10 percent set-aside
amount exceeds the combined apportionments for these two programs in fiscal year 1991, the excess
amount may be spent for either program but may not be used for other than safety purposes and may not
be used for routine maintenance. The Crossing Safety Improvements Program is funded at approximately
$140 to $150 million annually, about 25 percent of which is spent for new or improved crossing surfaces.
The expressed goal of this program is to eliminate 25 percent of grade crossings by closing access to
crossings and rerouting traffic. This, according to industry experts, will increase the demand for
improvements as the burden on remaining crossings increases. At the same time, with fewer crossings, a
higher percentage of the available funds for safety improvements will be available for each of the
remaining crossings, allowing for installation of more durable crossing surfaces such as rubber and
concrete.
At least half of the 10 percent set-aside funds for crossing improvements must be used for
installing protective devices at railway crossings. The other half may be spent on any type of safety
improvement. FHWA includes crossing surface improvements in their definition of protective devices.
According to industry experts, all states will use some of the funds for improving crossing surfaces.
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The 10 percent set-aside funds for grade crossing safety improvements are available at a 90
percent Federal share, with the remaining 10 percent paid by state and/or local authorities and/or the
railroad. In general, however, railroad companies (e.g., Union Pacific, Santa Fe, etc.) are not required to
pay a share of the cost of the new or improved grade crossing surfaces since, per chapter 23 of the Code
of Federal Regulations, Section 646.310(a)(l), these are deemed "of no ascertainable net benefit to the
railroads."
f. Barriers to Purchasing
EPA did not identify any technical barriers to the use of recovered materials in concrete, metal, or
rubber railroad crossings. States or railroads, however, may adopt guidelines for the purchase of a certain
type of crossing. Despite an industry trend to utilize more expensive, durable rubber and concrete
crossings, inexpensive wood and asphalt crossings, as noted above, are preferred in some less traveled
areas.
Recently, the use of rubber crossing surfaces has become more widespread, but these surfaces still
account for only a small percentage of total crossings. Moreover, while rubber grade crossing surfaces are
becoming more accepted and are often preferred, there is a long, institutionalized history of using cheaper
materials such as unconsolidated materials, wood, and asphalt for crossing surfaces. Rubber railroad
grade crossings also are not appropriate for all situations, such as lightly traveled rural areas. According
to one manufacturer, a Federal procurement program would likely increase their use in situations for
which they are suitable.
Recycled content rubber, concrete, and steel crossing surfaces have the environmental advantage of
containing recovered materials, some up to 100 percent. However, in deciding whether to implement a
Federal procurement program, certain other advantages should be considered. Specifically, the extended
life of rubber and concrete grade crossings vastly decreases costs associated with multiple removal,
replacement, and disposal of asphalt and wood crossing surfaces and may help reduce repairs of asphalt
street surfaces.
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g. Designation
In CPG III, EPA is proposing to designate railroad grade crossings containing recovered rubber,
concrete, or steel. A final designation would not preclude a procuring agency from purchasing railroad
grade crossings manufactured from another material. It simply requires that a procuring agency, when
purchasing railroad grade crossings made from rubber, concrete or steel, purchase the item made with
recovered materials when the item meets applicable specifications and performance requirements.
3. Procurement Recommendations
a. Recovered Materials Content
Several types of railroad grade crossings are available with recovered materials content, including
rubber, coal fly ash, and steel. They are described below.
Rubber
According to one manufacturer of rubber railroad grade crossings, all rubber grade crossings are
made of some form of recovered content rubber. Recovered content rubber falls into three categories: tire
buffings, crumb rubber, and off-specification (off-spec) virgin rubber. Tire buffings are the waste
byproduct of tire retreading operations. Crumb rubber is composed primarily of ground-up scrap tires.
Off-spec virgin rubber is rubber that is defective in some way and, therefore, not usable for its original
intended end use. Off-spec rubber is sold to processors for other applications. Tire manufacturers and
other rubber product manufacturers cannot use the off-spec rubber in their normal applications because of
safety requirements and unacceptable physical and chemical properties. Off-spec rubber must be used
relatively quickly because of the short shelf life of uncured rubber. While off-spec rubber is not
postconsumer material, because of the chemical changes that occur in the rubber while it is stored, if it is
not reprocessed and recycled, it would otherwise be discarded or used as fuel through incineration.
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Coal Fly Ash
Concrete used to manufacture railroad grade crossings may contain coal fly ash, a recovered
material. EPA contacted two manufacturers of concrete railroad crossings that incorporate coal fly ash
into the concrete mix. One manufacturer utilizes a 15 percent coal fly ash mix to create a high strength,
8,000 pounds-per-square-inch concrete railroad crossing. The other manufacturer produces a controlled
density fill product, or "flowable fill," that is a mixture of cement, fly ash, sand, and water for use as a
base for its concrete platforms. The company also manufacturers a concrete platform utilizing microsilica,
a fly ash derivative, which adds compressive strength to the concrete and helps prevent the intrusion of
salt water. Another major manufacture contacted by EPA is currently not using coal fly ash, but stated it
would be technically feasible to do so.
Steel
Steel used to manufacture railroad grade crossings contains at least 20 percent recovered materials.
Most steel produced in U.S. steel mills currently contains recovered material. The steel used to
manufacture railroad crossings may be produced by either basic oxygen furnace (EOF) process or electric
arc furnace (EAF) process, with EAF-produced steel likely used in most cases. The BOF process uses 25
to 30 percent recovered steel, while the EAF process uses virtually 100 percent recovered steel.
Asphalt
Although there are many cases of reground asphalt being used in highway construction, recovered
materials are not used in asphalt railroad crossings. An industry contact explained that the equipment used
in highway construction is large and designed for continuous operation on highways. This equipment
would not be practical or economical for use on small projects, such as railroad crossings.
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Theoretically, crumb rubber and plastic could be mixed with asphalt used for railroad crossings.
However, these materials have a tendency to stiffen the asphalt mixture to a point that might preclude its
use for railroad crossing applications. In addition, according to an official with the National Asphalt
Paving Association, using asphalt with these recovered materials for railroad crossings would be
extremely expensive.
Wood
Typically, wood used in crossings must be removed for periodic track maintenance. Since
crossings sustain more vehicular traffic than any other portion of the rail line, the wood is not reused
because it is typically damaged or splintered. According to one industry expert, this wood is not commonly
reused in railroad crossings, but rather is reused within the track as crossties or for other purposes, such
as in landscaping. Wood used for crossings is reused when tracks are repaired or replaced on shortline
railroads that operate with limited budgets. Shortline railroads, also referred to as Class III railroads, are
railroads that earn revenues of less than $24 million annually. They usually consist of less than 100 miles
of track.
Table 13 presents information provided by manufacturers of railroad crossings on recovered
content availability.
Table 13
Recovered Materials Content of Railroad Grade Crossings
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
Concrete containing coal fly
ash
Rubber
Company A: Unknown
Company B: Unknown
Company C: 15
Company D: Unknown
Company E: Unknown
Company F: Unknown
Company G: Unknown
Unknown
Unknown
15
Unknown
85
95
85-90
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b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 14,
procuring agencies establish minimum content standards for use in purchasing railroad grade crossing
surfaces containing recovered materials.
Table 14
Draft Recovered Materials Content Recommendations for
Railroad Grade Crossings
Surface
Material
Concrete
Rubber
Steel
Recovered Material
Coal fly ash
Tire rubber
Steel
Postconsumer
Content (%)
~
~
16-75
Total Recovered Materials
Content (%)
15-20
85-95
20-100
c.
Specifications
EPA identified no national specifications or standards that either require or preclude the use of
recovered materials in railroad crossings. Many states, however, have developed guidelines or criteria for
use in selecting a crossing surface. Different crossing grade surfaces may be appropriate for different
settings, based on highway traffic and functional classification, types of vehicles using the crossing,
railroad traffic and truck classification, condition of approach surface, engineering judgment, costs, and
the expected life of the surface. When state or Federal dollars are used to build or improve crossings,
states are required by law to offer competitive bidding and may specify a particular type of crossing (e.g.,
rubber). Several states specify rubber crossings as the surface of choice for high traffic-volume crossings.
In practice, state departments of transportation and railroad companies have preferences for certain
materials, and states work jointly with railroad companies in deciding what materials to use in grade
crossings.
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The state of Alabama has a policy to use full-depth rubber or concrete crossings when the railroad
is paying for the crossing or when the state department of transportation is paying for it through an agency
project. Table 15 shows the traffic guidelines the state observes.
Table 15
State of Alabama Railroad Crossing Surface Guidelines
Vehicles Per Dav
0 to 5,000
0 to 5,000
5,000 to 10,000
5,000 to 10,000
Soeed Limit
< 40 miles per hour
(mph)
< 40 mph
< 40 mph
> 40 mph
Trucks Per Dav
>250
<250
Crossine Tvoe
Asphalt/Timber
Solid Timber
Prefab Rubber
Rubber/Concrete
Source: ADT, 1997
The following ASTM standards for rubber products may be specified by customers of rubber
railroad crossings. Although ASTM standards are not widely used in bid documents, many manufacturers
provide them in their product literature.
# D2000-96 Rubber Products in Automotive Applications. This classification system
tabulates the properties of vulcanized rubber materials that are intended for, but not
limited to, use in rubber products for automotive applications.
# D2240-97 Rubber PropertyDurometer Hardness. This test method describes the
procedure for determining indentation hardness of substances classified as rubber, cellular
materials, elastomeric materials, thermoplastic elastomers, and some hard plastics.
# D412-97 Vulcanized Rubber and Thermoplastic Rubbers and Thermoplastic
ElastomersTension. These test methods describe procedures used to evaluate the tensile
(tension) properties of vulcanized rubbers, thermoplastic rubbers, and thermoplastic
elastomers.
# D297-93 Rubber ProductsChemical Analysis. These test methods cover the
qualitative and quantitative analysis of the composition of rubber products.
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# E303-93 Measuring Surface Frictional Properties Using the British Pendulum Tester.
This test method covers the procedure for measuring surface frictional properties using the
British Pendulum Skid Resistance Tester.
# D1171-94 Rubber DeteriorationSurface Ozone Cracking Outdoors or Chamber
(Triangular Specimens). This test method permits the estimation of the relative ability of
rubber compounds used for applications requiring resistance to outdoor weathering or
ozone chamber testing.
# D573-88 RubberDeterioration in an Air Oven. This test method describes a
procedure to determine the influence of elevated temperature on the physical properties of
vulcanized rubber.
# D395-89 Rubber PropertyCompression Set. These test methods cover the testing of
rubber intended for use in applications in which the rubber will be subjected to
compressive stresses in air or liquid media.
# D257-93 DC Resistance or Conductance of Insulating Materials. These test methods
cover direct-current procedures for the determination of direct current insulation
resistance, volume resistance, volume resistivity, surface resistance, and surface resistivity
of electrical insulating materials, or the corresponding conductances and conductivities.
# D2137-94 Rubber PropertyBrittleness Point of Flexible Polymers and Coated
Fabrics. These test methods cover the determination of the lowest temperature at which
rubber vulcanizes and rubber-coated fabrics will not exhibit fractures or coating cracks
when subjected to specified impact conditions.
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E. Building Insulation Products
1.
Additional Procurement Recommendations
EPA recommended purchasing practices, including recovered materials content levels, for thermal
building insulation products in RMAN I. EPA is revising those recommendations by adding a recovered
materials content level for plastic batt building insulation. When EPA issues final recommendations for
purchasing plastic batt building insulation products, procuring agencies should substitute the revised
Table 16 for the recommendations found in Section C-l of the 1995 RMAN I.
a. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 16
(Revised), procuring agencies establish minimum content standards for use in purchasing building
insulation products.
Table 16
Recommended Recovered Materials Content Levels for Building Insulation
Insulation Material
Cellulose loose-fill and
spray-on
Fiberglass
Perlite composite board
Phenolic rigid foam
Plastic, non-woven batt
Plastic foam-in-place,
polyisocyanurate/
polyurethane
Plastic rigid foam,
polyisocyanurate/
polyurethane
Recovered Material
Postconsumer paper
Glass cullet
Postconsumer paper
Recovered materials
Recovered and/or
postconsumer plastics
Recovered materials
Recovered materials
Total Recovered Materials (%)
75
20-25
23
5
100
5
9
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Insulation Material
Plastic foam, glass fiber
reinforced
polyisocyanurate/
polyurethane
Rock wool
Recovered Material
Recovered materials
Slag
Total Recovered Materials (%)
6
75
Note: The recommended recovered materials content levels are based on the weight (not volume) of materials in the insulating
core only.
b.
Specifications
EPA recommends that procuring agencies reference ASTM standard specification D 5359, "Glass
Gullet Recovered from Waste for Use in Manufacture of Glass Fiber," in Invitations for Bid and Requests
for Proposal.
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VI. PARK AND RECREATION PRODUCTS
A. Park and Recreational Furniture
1. Item Description
Park and recreational furniture is found in parks, outdoor recreational facilities, and the grounds of
office buildings and other facilities. This furniture consists primarily of park benches and picnic tables.
Park Benches
Park benches provide opportunities for people to rest and comfortably enjoy outdoor settings. Park
benches are typically made from concrete, brick, aluminum, steel, wood, or plastic lumber. Benches are
available in a number of different styles and designs, including pedestal benches with a single supporting
leg and standard benches with two supporting legs. They are also available with or without seat backs and
with or without arms. Benches commonly range in length from 4 to 8 feet. Some park benches are
movable; others are set in concrete. Benches made from wood or plastic lumber typically have a frame
made from either steel or aluminum with the slats that make up the seat and/or back of the bench being
commonly attached with bolts.
Picnic Tables
Picnic tables provide opportunities for people to gather and eat in an outdoor environment. Picnic
tables are typically made from wood, concrete, aluminum, or plastic lumber. They are available in a
number of different styles, including standard 6 by 6-foot rectangular tables, hexagonal tables, and
handicapped accessible tables with 8-foot tops. Picnic tables can be movable or set into concrete.
EPA has already designated cement and concrete made with recovered coal fly ash. According to
the Steel Recycling Institute (SRI), all steel contains between 25 and 100 percent recycled material.
Aluminum also usually contains recovered material. There are some indications that reclaimed wood is
beginning to be used in indoor furniture, but EPA was unable to obtain any substantial information on its
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use for outdoor furniture. For these reasons, this section will focus on outdoor furniture made from plastic
lumber, but also presents information on the use of other recovered materials, such as steel, aluminum,
and concrete.
Plastic Lumber
The ASTM draft definition states that plastic lumber is "a manufactured product composed of
more than 50 weight percent resin, and in which the product generally is rectangular in cross-section and
typically supplied in board dimensional lumber sizes, may be filled or unfilled, and may be composed of
single or multiple resin blends." As noted in this definition, plastic lumber is normally produced in
standard dimensional lumber profiles, such as 2 by 4-foot lengths, but it can also be produced in sheets.
Some plastic lumber is available in a variety of colors, while other types come in only one or two different
colors. The Plastic Lumber Trade Association (PLTA) identifies four main technologies used to produce
recycled plastic lumber.
Single-polymer systems made from recycled high density polyethylene (HOPE).
EPA's research noted that most of the manufacturers of 100 percent HDPE plastic lumber
use 100 percent postconsumer HDPE for their products. This HDPE often comes from
sources such as postconsumer milk jugs, water jugs, detergent bottles, and soda bottles.
Mixes of recycled polyethylene and/or other recycled plastics (commingled plastics).
EPA's research identified several different mixtures of resins that fall into this category
including a mixture of HDPE and low-density polyethylene (LDPE); a mixture of
polyethylene (PE) and PP; and a mixture of HDPE, LDPE, linear low-density polyethylene
(LLDPE), and PP. LDPE often comes from sources such as plastic bags and stretch wrap.
The PE/PP mix comes from sources such as detergent bottles (in which the bottle body and
spout/cap are made of PE and PP, respectively). In addition, a few manufacturers were
identified who make lumber from unspecified resins.
Fiberglass reinforced plastic lumber. EPA's research revealed that a few manufacturers
reinforce plastic lumber with fiberglass rods, while others disperse glass fibers into the
plastic lumber to increase its stiffness.
Wood/thermoplastic composites. Some manufacturers blend plastic resin with wood
chips and/or sawdust. A typical blend is 50 percent recovered plastic (usually HDPE) and
50 percent recovered wood.
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When recycled plastic is mixed with wood, fiberglass, or some other material to make lumber, the
end product is generally referred to as "composite lumber." EPA also found references to composite
lumber made by mixing plastic and rubber scrap, and by mixing recycled plastic and recycled paper.
Plastic lumber is generally made in one of two ways: by extrusion into a mold or by continuous extrusion.
For 100 percent HOPE plastic lumber, HDPE is ground up, melted, and mixed with additives. These additives
frequently include ultraviolet (UV) inhibitors and color. A blowing agent can also be added to decrease the density of
the material. The material is then either flowed into a mold (extrusion into a mold) or pulled out of a machine and
shaped using a series of sizing plates, then cooled and cut to the desired length (continuous extrusion).
2. Rationale for Designation
EPA believes park benches and picnic tables containing recovered materials meet the statutory
criteria for selecting items for designation.
a. Impact on Solid Waste
According to one manufacturer, extruding HDPE into a mold requires approximately 6.3 milk jugs
to make one pound of 100 percent HDPE plastic lumber. Another manufacturer said that in their
continuous extrusion process it takes seven milk jugs to make a pound of plastic lumber. A third
manufacturer states that their continuous extrusion process requires approximately nine milk jugs to make
a pound of plastic lumber. Assuming between 6.3 and 9 milk jugs per pound, an average 300-pound picnic
table would use between 1,890 and 2,700 milk jugs. Therefore, if Federal agencies were to buy 10,000
such picnic tables, between 18.9 and 27 million milk jugs would be diverted from the solid waste stream.
Similarly, if Federal agencies were to buy 10,000 park benches of an average weight of 125 pounds, it
would divert between 7.9 million and 11.3 million milk jugs from the waste stream. According to one
aluminum manufacturer, it takes 31 aluminum cans to make 1 pound of recycled aluminum, compared to
4 pounds of mined bauxite per pound to produce virgin material. According to one manufacturer of
aluminum benches and tables, their 6 foot long table weighs 83 pounds and would, therefore, use
approximately 2,573 aluminum cans. Accordingly, if the Federal agencies were to buy 10,000 such picnic
tables, almost 26 million aluminum cans would be diverted from the solid waste stream. The same
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manufacturer sells park benches weighing 35 pounds. Consequently, if Federal agencies were to buy
10,000 such park benches, almost 11 million aluminum cans would be diverted from the solid waste
stream. According to the SRI, when 1 ton of steel is recycled, 2,500 pounds of iron ore, 1,400 pounds of
coal, and 120 pounds of limestone are conserved. SRI also indicated that it takes eight household steel
soup cans to make a pound of steel, and a steel park bench could weigh anywhere from 150 to 300
pounds. Therefore, if Federal agencies were to purchase 10,000 such park benches, between 12,000,000
and 24,000,000 steel cans would be diverted from the waste stream. Appendix I of this document
discusses the generation and recovery of aluminum, steel, wood, and plastic in MSW.
b. Technological Feasibility and Performance
A number of technical and performance issues exist with respect to the different materials used to
make park and recreational furniture. In particular, wood and plastic lumber park and recreational
furniture differ in terms of longevity and durability, the effects of temperature, maintenance, strength,
weight, and other issues. Different kinds of plastic lumber also differ with respect to these issues.
Longevity and Durability
Many manufacturers of plastic furniture indicated that plastic lumber park and recreational furniture
will last two to three times longer than its wooden counterparts. They also noted that plastic lumber is resistant
to rot, termites, and general deterioration. The state of Georgia stated that, although the 100 percent HDPE
plastic lumber picnic tables and park benches it purchases cost 25 to 30 percent more initially, the state believes
that the increased durability and longevity is worth this initial cost. Georgia chose to purchase only 100 percent
HDPE plastic lumber products in part because it was concerned that wood/plastic composite lumber might
deteriorate more quickly than 100 percent plastic. A study conducted at Rutgers University revealed that plastic
lumber exposed to UV radiation disintegrates at a rate of only 2 to 3 thousandths of an inch per year. A
purchaser in the state of Wisconsin, however, stated that a life-cycle analysis comparing wood and plastic
lumber revealed, surprisingly, that standard wooden tables had lasted longer than anticipated; some of the
state's wooden picnic tables have been in service since World War II. As a result, the contact felt the increased
cost of other materials may not be justified. The contact did not provide specific information on the condition of
these tables that had been in service for over 50 years.
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One manufacturer stated that one of its customers, a national park in the U.S. Virgin Islands,
ordered four of their plastic lumber picnic tables a few years ago. After a rough hurricane season, the
park's wooden tables were washed away or sustained heavy damage, whereas the plastic lumber tables
were intact. This national park recently placed an order for 50 new picnic tables. Similarly, two national
parks in Washington, DC, area have used plastic lumber park and recreational furniture for more than 2
years and expressed satisfaction with their performance and durability.
A manufacturer of concrete tables and benches said that concrete is more durable than almost any
other material. At least one other park and recreational furniture manufacturer, however, stated that this
statement is highly dependent on environmental factors, such as temperature, rain, and exposure to other
elements. EPA was unable to confirm this statement or obtain specific figures on durability of concrete.
Steel and aluminum are generally considered more durable than wood.
Heat and Cold
Some plastic lumber has a tendency to expand and contract with changes in temperature. One
manufacturer noted that a 6-foot recycled plastic lumber board may expand or contract a quarter of an
inch with a 50° Fahrenheit temperature fluctuation. At least one manufacturer said that extremes of heat
and cold can cause warping or cracking, but two government purchasers indicated that they had not
witnessed problems with plastic lumber due to temperature changes. One manufacturer's product
literature states that single-resin plastic lumber is better than commingled plastic because different resins
expand and contract at different rates, causing internal stresses that may cause warping. According to an
independent consultant, wood/plastic composite lumber expands and contracts much less than does 100
percent plastic, regardless of resin composition. According to this consultant, incidents of warping in
plastic lumber have declined as manufacturers have improved quality control. The chair of ASTM
Subcommittee D20.20.01 Plastic Lumber and Shapes commented that plastic inherently has a larger
thermal expansion than wood. This tendency to expand and contract based on temperature changes can be
controlled by putting in glass or other reinforcements, and can also be accounted for in the design of park
and recreational furniture.
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A purchaser for the state of Wisconsin mentioned that small table top grills can damage the
appearance of plastic lumber picnic tables. Hot coals from these grills can melt the plastic and leave ugly
scars. According to one government purchaser, in areas prone to vandalism, plastic lumber picnic tables
are better than wooden tables because plastic lumber catches fire less easily. ASTM Subcommittee
D20.20.01, has a task group currently studying combustion and combustibility issues.
In general, plastic takes a relatively long time to heat up, but also takes a fairly long time to cool
down. Heat is a performance issue with regard to steel or aluminum park and recreational furniture. Metal
components absorb heat more quickly than either wood or plastic lumber and retain heat longer. This can
cause some discomfort to users during the summer or where metal furniture has prolonged exposure to
direct sunlight. Wood is generally considered to be a cooler material than 100 percent plastic lumber, but
wood/plastic composite lumber is comparable to wood.
Maintenance Issues
Many manufacturers of plastic lumber park and recreational furniture say that one advantage of
this material is that it is virtually maintenance free. Wood equipment needs to be inspected regularly for
splinters and rotting. It also may need to be painted, stained, or treated on a regular basis. PLTA's 1996
report mentioned that the commercial parks and recreation industry constitutes 50 to 70 percent of the
plastic lumber market in part because of maintenance issues. According to an industry consultant,
aluminum is virtually maintenance-free. Steel, on the other hand, requires frequent painting, as oxidization
can be an issue.
One other difference between plastic lumber park and recreational furniture and wood is its
resistance to graffiti. A purchaser with the state of Wisconsin mentioned that parks and other outdoor
areas particularly vulnerable to graffiti tend to favor plastic lumber benches and tables because they are
difficult to carve into and write on and easier to clean up. If written or painted on, plastic lumber can
either be cleaned with a solvent or sanded. A number of plastic lumber manufacturers state that the
advantage of plastic lumber is that it is the same color all the way through, so that if it is sanded down, it
will not require painting.
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A contact in King County, Washington, mentioned that plastic lumber picnic tables may need to
be washed more frequently than wooden tables, which could add maintenance costs. According to a
purchaser with the state of Wisconsin, the maintenance required for wooden picnic tables does not add
significant costs to park budgets. In a period of declining budgets, however, many states have fewer
employees available for routine maintenance, and these employees could be doing other projects in the
parks if they were not maintaining outdoor furniture.
Strength and Creep Properties
According to an industry consultant, composite lumber has greater tensile strength than 100
percent plastic lumber. Plastic lumber may bend or sag under weight. According to this consultant,
composite lumber resists bending and warping better than 100 percent plastic does.
Creep is a measure of how much a material deforms under load weight. To test for creep, a length
of lumber is suspended between two supports and a weight is placed in the middle. According to one
materials engineer, plastic lumber has more tendency to creep than wood. In the above described situation,
wood may creep less, but it will fracture under a strain of approximately 0.7 percent. By contrast, plastic
lumber made of 100 percent polyethylene requires a strain of 600 to 800 percent before fracturing. In
other words, plastic lumber may bend or sag under weight more than wood, but under strain, it will bend
much more than wood before it breaks.
Weight
Plastic lumber park and recreational furniture can weigh two to three times more than wooden
furniture. In areas where picnic tables are set in concrete, the additional weight of plastic lumber can make
these fixtures more permanent and durable. When picnic tables are free standing, however, weight can be
an issue, making it difficult for people to move picnic tables together to create a group setting. In some
areas, picnic tables need to be moved aside in order for the grass underneath and around them to be
mowed. A plastic lumber picnic table weighs approximately 200 to 300 pounds, which can make it
difficult for maintenance workers to move it. The weight of plastic lumber picnic tables can be a particular
issue in areas with vandalism. If a group of vandals move a table to a new location such as a lake, it can
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be difficult for park staff to move it back. Steel is obviously a heavier material than wood or plastic
lumber, and aluminum is about half the weight of steel. One independent consultant indicated, however,
that manufacturers can circumvent the weight issue with steel through design modifications.
Safety
The safety manager of Rock Creek Park, Washington, DC, stated that the park had recently
purchased a number of plastic lumber picnic tables and benches. He has some reservations about the
tables since the additional weight could cause back injuries when the furniture is moved to accommodate
large gatherings. He noted, however, that one very important benefit of plastic lumber picnic tables in
terms of safety is that the tables do not require painting with paints that release hazardous volatile organic
compounds and require disposal as hazardous wastes.
Steel normally is only used for park and recreational furniture frames and small parts. Because of
its hardness properties, it is generally uncomfortable to sit on and could be unsafe if fallen upon.
Aluminum is a softer metal that may not present the same safety concerns.
Other
One restaurant chain indicted that it no longer purchases plastic lumber park and recreational
furniture because of negative experiences with warping, discoloration, and displacement and because of
the lack of industrywide standards. An independent consultant noted the importance of UV stabilizers and
inhibitors to prevent discoloration. In its product literature, a manufacturer of park and recreational
furniture from single resin plastic lumber claims that single resin lumber is better than mixed plastic
lumber because chemical additives, such as pigments and UV stabilizers, are dispersed unevenly through
the various resins. One manufacturer mentioned that one of the benefits of the wood/plastic composite
lumber is that, unlike 100 percent plastic, it can be painted if desired. Wood is more sensitive to moisture,
and tends to warp or swell when it gets wet.
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c. Availability and Competition
EPA identified and communicated with 19 manufacturers of park and recreational furniture, 15 of
which manufacture products using recovered materials. EPA also identified, but did not communicate
with, 36 additional manufacturers or distributors. The majority of these manufacturers and distributors
sell their products nationally.
d. Economic Feasibility
Plastic lumber outdoor furniture can be up to 50 percent more expensive than its wooden
counterpart. A number of manufacturers state that, over the long term, plastic lumber is more economical
because of reduced maintenance costs and increased longevity and durability. The state of Georgia's
experience indicates that plastic lumber costs 25 to 35 percent more up front, but is economical over the
long term. One independent consultant stated that the cost of plastic lumber has dropped recently and is
now only about 20 percent more than wood. The price of steel is comparable to that of plastic lumber.
Aluminum can be expensive, costing up to 40 percent more than plastic lumber and 60 percent more than
wood.
e. Government Purchasing
The GSA contracting representative for Schedule 781-C Park and Outdoor Recreational Equipment said
that in 1996, GSA-tracked purchases of picnic tables and park benches by government agencies totaled $3,148,996.
This figure includes picnic tables and park benches made from all types of materials; information is not kept on a
material-specific basis. The actual figure for Federal spending is approximately 20 percent larger, since the U.S.
Postal Service (USPS) and the U.S. Department of Defense (DOD) often buy "off schedule."
The National Park Service (NPS) said many national parks do buy picnic tables and park benches,
but that no aggregate figures are available since purchasing is now decentralized. NPS encourages
purchasers to buy items with recycled content. Rock Creek Park recently purchased plastic lumber park
and recreational furniture. The Edwin W. Forestrief National Wildlife Refuge in New Jersey, a U.S. Fish
and Wildlife Service reserve, purchased plastic lumber picnic tables and park benches and is satisfied with
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their performance. The Prince William Forest National Park in Triangle, Virginia, has repeatedly
purchased plastic lumber picnic tables and is so satisfied that it would like to replace all of its old wooden
tables with recycled plastic lumber tables. The Navy stated that naval bases purchase park and
recreational furniture and some of them purchase plastic lumber park and recreational furniture. A
manufacturer mentioned that its main government buyers are military agencies; one of its main clients is
the Department of Defense in the state of Texas.
f. Barriers to Purchasing
The higher cost of plastic lumber picnic tables and benches might represent a barrier if initial cost
is the only factor considered. One state purchaser mentioned that the higher cost might be a barrier to
purchasing as state budgets are predicated on low bid and rarely account for life-cycle costs. NPS
mentioned that some historical parks are reluctant to buy plastic lumber for aesthetic reasons; the parks
prefer to use virgin wood products as they look more historically authentic and match the appearance of
the park. The state of Wisconsin noted that one of the biggest barriers to purchasing plastic lumber
products is the current lack of industrywide standards.
g. Designation
In CPG III, EPA is proposing to designate park benches and picnic tables containing recovered
steel, aluminum, plastic, concrete, or wood. If designated, a procuring agency would not be precluded
from purchasing park benches and picnic tables manufactured from other materials. It would simply
require that a procuring agency, when purchasing steel, aluminum, plastic, concrete, or wood park
benches and picnic tables, purchase these items containing recovered materials when they meet applicable
specifications and performance requirements.
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3. Procurement Recommendations
a. Recovered Materials Content
Plastic lumber used in park and recreational furniture contains varying percentages of
postconsumer and total recovered materials content. All of the manufacturers of 100 percent HDPE
plastic lumber that EPA contacted use 100 postconsumer material from milk jugs, detergent bottles, pop
bottles, and other HDPE products. Total recovered-content percentages for HDPE plastic lumber range
from 20 to 100 percent, including 20 to 100 percent postconsumer HDPE and 10 to 90 percent recovered
material. Wood/plastic composite lumber can be made with 50 percent recovered wood waste and 50
percent postconsumer HDPE. One manufacturer of fiberglass/plastic composite lumber uses 75 percent
postconsumer plastic and 25 percent recovered fiberglass.
Aside from the plastic lumber components, park benches and picnic tables often use steel for
structural elements, and all steel is made with 25 to 100 percent recovered materials. Although steel is
commonly used in structural elements of such furniture, it is not often used for the entire bench or table.
EPA was able to identify only one manufacturer of steel park benches produced from 70 percent
postconsumer steel. One manufacturer makes tables and benches out of 100 percent recovered aluminum,
and another makes park and recreational furniture from 25 percent recovered aluminum. The only
manufacturer found to use concrete to make tables and benches reported that it does not use any recycled
materials. EPA obtained information from 15 manufacturers of park and recreational furniture using
recovered materials. This information is displayed in Table 17.
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Table 17
Recovered Materials Content of Park and Recreational Furniture
Material
HOPE
Plastic
(Unspecified)
Postconsumer Content (%)
Company A: 100
Company B: 100
Company C: 100
Company D: 100
Company E: 100
Company F: 100
Company G: 100
Company H: 100
Company I: 90
Company J: 25
Company K: 100
Company L: 96
Company M: 100
Company N: 0-100
Company O: 90
Company P: 25
Company Q: 90
Company R: 95
Company S: 60
Company T: Unspecified
Company U: 70
Company V: 100
Company W: 100
Total Recovered
Materials Content (%)
100
100
100
100
100
100
100
100
90
25
100
96
100
0-100
90
100
100
100
100
100
70
100
100
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Material
Plastic
(Unspecified)
(cont.)
Mixed Resins (HOPE,
PET, PE, LDPE)
HDPE, Commingled
Plastic (Unspecified
Resins)
Mixed Resins (HDPE,
LDPE, PET, PP)
Mixed Resins (PET,
HDPE, LDPE,
LLDPE, PVC, PS,
and other)
Mixed Resins (PE,
PS, PP)
Mixed Resins (HDPE,
LDPE, LLDPE, PP)
PE, Fiberglass
LDPE, Wood,
Sawdust
LDPE, PP
Steel/Plastic
Postconsumer Content (%)
Company X: 70
Company Y: 50-100
Company Z: 100
Company AA: 100
Company BB: 100
Company CC: 50-100
(comp. plastic/wood/sawdust)
Company DD: 51-75
(comp. plastic/wood/sawdust)
Company EE: Unknown
Company FF: 40-60
Company GG: 30-70
Company HH: 85-90
Company II: 97
Company JJ: 75 (HDPE)
Company KK: 50-100 (HDPE)
Company LL: 0-97
Company MM: 100
Company NN: 10-60
Company OO: 90-95
Company PP: Unknown
Company QQ: 50 (LDPE)/
50 (Wood/Sawdust)
Company RR: Unknown
Company SS: 25 (Steel)/
75 (Plastic)
Total Recovered
Materials Content (%)
70
50-100
100
100
100
50-100
25-49
100
100
30-70
100
97
100
100 (0-50 Recovered
Plastic)
0-97
100
40-90
100
100
100
100
100
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b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 18,
procuring agencies establish minimum content standards for use in purchasing park benches and picnic
tables containing recovered materials.
Table 18
Draft Recovered Materials Content Recommendations for
Park and Recreational Furniture
(Park Benches and Picnic Tables)
Material
Plastics
Plastic composites
Aluminum
Concrete
Steel
Postconsumer Content (%)
90-100
50-100
25
~
16-25
Total Recovered
Materials Content (%)
100
100
25
15-40
100
Notes: "Plastics" includes both single and mixed plastic resins. Picnic tables and park benches made with recovered plastics
may also contain other recovered materials such as sawdust, wood, or fiberglass. The percentage of these materials contained
in the product would also count toward the recovered materials content level of the item.
c.
Specifications
EPA was unable to locate any ASTM specifications specifically addressing the use of steel or
aluminum (either recycled or virgin) in park benches or picnic tables. One manufacturer of steel benches
and tables verified this finding, citing as a reason the established history usage and well known
performance of the materials in such applications.
PLTA has been working with ASTM's Subcommittee D-20.20.01 to develop several test methods
for plastic lumber. One hundred percent recycled plastic lumber cannot be tested using the same tests
already developed for virgin plastic. Tests on virgin plastic are performed on small cross-sections of the
material. This is an accurate indicator of how the plastic will perform, as it is a homogeneous material.
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Plastic lumber, however, is not always homogeneous in its construction, so tests on a cross section of this
material do not accurately predict how a length of lumber will perform in certain circumstances. For this
reason, new test methods have been developed for lengths of lumber. These test methods apply to all types
of plastic lumber or equivalent materials that are not homogeneous at the cross-section. These test
methods were recently finalized and are scheduled to be available as of early 1998. These test methods are
as follows:
P D 6108-97 Standard Test Method for Compressive Properties of Plastic Lumber.
P D 6109-97 Standard Test Method for Flexural Properties of Unreinforced and Reinforced
Plastic Lumber.
P D 6111-97 Standard Test Method for Bulk Density and Specific Gravity of Plastic
Lumber and Shapes by Displacement.
P D 6112-97 Standard Test Method for Compressive and Flexural Creep and Creep
Rupture of Plastic Lumber and Shapes.
P D 6117-97 Standard Test Method for Mechanical Fasteners in Plastic Lumber and
Shapes.
A draft test method is also under review for shear properties. In addition, a task group of the
ASTM Subcommittee is developing performance specifications for plastic lumber and shapes. These
specifications will be divided based on the modulus of the material; modulus is a measure of the products'
stiffness.
An industry consultant recommends that purchasers only buy from manufacturers who willingly
provide the results of physical and mechanical product testing done by an outside testing lab. This contact
believes that independent testing is essential because the quality of plastic lumber products currently
varies tremendously.
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B. Playground Equipment
1. Item Description
Playground equipment is found in parks, schools, child care facilities, institutions, multiple family
dwellings, restaurants, resort and recreational developments, and other public use areas. Major types of
playground equipment include slides, swings, climbing equipment, merry-go-rounds, seesaws, and spring
rocking equipment. Other playground components include stairways and ladders, rungs and other
handgripping components, handrails, protective barriers, and platforms. Playground equipment is usually
designed to be age appropriate and is often divided into equipment for 2- to 5-year-olds and 5- to 12-year-
olds.
Playground equipment can be made with a number of different materials. Many playgrounds have
railings and structural support pieces made out of one material, fittings made out of another, and decks
and platforms made of a third material. Galvanized steel is often used for railings and structural support,
but these items can also be made with aluminum. Fittings, such as the bolts that hold chains to swings, are
usually made from stainless steel or aluminum. Decks, platforms, and slides can be made from steel,
aluminum, plastic, wood, and plastic lumber. Much information is already available about the
performance of steel, aluminum, and wood, so this product description will focus on playground
equipment made with plastic lumber.
Plastic Lumber
The ASTM draft definition states that plastic lumber is "a manufactured product composed of
more than 50 weight percent resin, and in which the product generally is rectangular in cross-section and
typically supplied in board dimensional lumber sizes, may be filled or unfilled, and may be composed of
single or multiple resin blends." (Note: 50 weight percent resin means that 50 percent of the product by
weight consists of a plastic resin.) As noted in this definition, plastic lumber is normally produced in
standard dimensional lumber profiles, such as 2 by 4-foot lengths, but it can also be produced in sheets.
Some plastic lumber is available in a variety of colors, while other types come in only one or two different
shades. PLTA identifies four main technologies used to produce recycled plastic lumber.
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P Single-polymer systems made from recycled HOPE. EPA's research noted that most of
the manufacturers of 100 percent HDPE plastic lumber use 100 percent postconsumer
HDPE for their products. This HDPE often comes from sources such as used milk jugs,
water jugs, detergent bottles, and soda bottles.
P Mixes of recycled PE and/or other recycled plastics (commingled plastics). EPA's
research identified several different mixtures of resins that fall into this category, including
HDPE and LDPE; PE and PP; and HDPE, LDPE, LLDPE, and PP. In addition, a few
manufacturers were identified who make lumber from unspecified resins.
P Fiberglass reinforced polyethylene. EPA's research revealed that a few manufacturers
reinforce plastic lumber with fiberglass rods, while others disperse fiberglass into the
plastic lumber to increase its stiffness.
P Wood/thermoplastic composites. Some manufacturers blend plastic resin with wood
chips and/or sawdust. A typical blend is 50 percent recovered plastic (usually HDPE) and
50 percent recovered wood.
When recycled plastic is mixed with wood, fiberglass, or some other material to make lumber, the
end product is generally referred to as "composite lumber."
Plastic lumber is generally made in one of two ways: by extrusion into a mold, or by continuous
extrusion. For 100 percent HDPE plastic lumber, the HDPE is ground up, melted, and mixed with
additives. These additives frequently include UV inhibitors and color. A blowing agent can also be added
to decrease the density of the material. The material is then either flowed into a mold (extrusion into a
mold) or pulled out of a machine and shaped using a series of sizing plates, then cooled and cut to the
desired length (continuous extrusion).
2. Rationale for Designation
EPA believes that playground equipment containing recovered materials meets the statutory criteria
for selecting items for designation.
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a. Impact on Solid Waste
Playground equipment can be made with recovered wood, steel, aluminum, HDPE, LDPE,
LLDPE, PP, and other resins.
According to one manufacturer, extruding HDPE into a mold requires approximately 6.3 milk and
water jugs to make one pound of 100 percent HDPE plastic lumber. Another manufacturer said that in
their continuous extrusion process, it takes seven milk jugs to make a pound of plastic lumber. A third
manufacturer stated that their continuous extrusion process requires approximately nine milk jugs to make
a pound of plastic lumber. This manufacturer said that the most common lumber profiles used in
playground equipment are 4 by 6-foot and 6 by 6-foot lengths. A 4 by 6-foot lumber profile weighs
approximately 5 pounds per foot, and a 6 by 6-foot lumber profile weighs approximately 7 pounds.
Assuming 6.3 to 9 milk jugs per pound, 1 foot of a 4 by 6-foot lumber profile would use approximately
31.5 to 45 milk and water jugs (HDPE). Therefore, if a Federal agency were to buy 1,000 linear feet of 4
by 6-foot dimensional lumber used in playground equipment, it would divert between 31,500 and 45,000
milk jugs from the MSW stream. Similarly, if a Federal agency were to buy 1,000 linear board feet of 6
by 6-foot dimensional lumber, it would divert between 44,100 to 63,000 milk and water jugs from the
MSW stream. EPA measured a standard set of playground equipment and found it to contain between 300
and 500 square feet of lumber. Therefore, a standard playground can contain between 31,500 and 63,000
milk and water jugs.
There are many different configurations for playground equipment using varying amounts of
plastic lumber. One private purchaser of 100 percent HDPE plastic lumber playground equipment notes
that the playground set they purchased, which includes three slides, used 86,000 milk jugs.
A standard set of playground equipment sold by one manufacturer, including four slides, climbing
equipment, and a number of platforms, uses 10,000 pounds of recycled plastic, 1,500 pounds of
aluminum, and 2,000 pounds of recycled steel. Appendix I of this document discusses the generation and
recovery of aluminum, steel, wood, and plastic in MSW.
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b. Technical Feasibility and Performance
A number of technical and performance issues exist with respect to the different materials used to
make playground equipment. In particular, wood and plastic lumber playground equipment differ in terms
of their longevity and durability, the effects of temperature, maintenance, strength, weight, and other
issues. Different kinds of plastic lumber also differ with respect to these technical considerations.
Longevity and Durability
Several manufacturers say plastic lumber playground equipment will last two to three times longer
than its wooden counterpart. They also note that plastic lumber is resistant to rot, termites, and
deterioration.
Heat and Cold
Some plastic lumber has a tendency to expand and contract with changes in temperature. One
manufacturer noted that a 6-foot recycled plastic lumber board may expand or contract one-quarter inch
with a 50°F temperature fluctuation. Extremes of heat and cold can cause warping or cracking. One
manufacturer's product literature states that single-resin plastic lumber is belter than commingled plastic,
because different resins expand and contract at different rates, causing internal stresses that may cause
warping. According to an independent consultant, wood/plastic composite lumber expands and contracts
much less than does 100 percent plastic. The chair of ASTM Subcommittee D20.20.01, Plastic Lumber
and Shapes, commented that plastic inherently has a larger thermal expansion than wood. This tendency
to expand and contract based on temperature changes can be controlled by putting in glass or other
reinforcements. This tendency can also be accounted for in the design of playground equipment.
One manufacturer of 100 percent plastic lumber commented that their plastic lumber can heat up
more quickly than wood, and that, for customers in hot climates, they recommend light-colored material.
Heat is also a performance issue with regard to steel or aluminum playground equipment, such as slides.
These metal components can heat up more quickly than either wood or plastic and retain heat longer.
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Maintenance Issues
Manufacturers of plastic lumber playground equipment say one advantage of this material is that it
is virtually maintenance-free. Wood equipment needs to be inspected for splinters and rotting. It also needs
to be painted, stained, or treated on a regular basis. Plastic lumber playground equipment, by contrast, is
usually the same color all the way through and does not need to be painted. One private purchaser noted
that wooden playground equipment requires a lot of maintenance, including treating to prevent rotting and
damage from UV rays. By contrast, with plastic lumber playground equipment, the only maintenance
required is tightening the bolts.
One other advantage of plastic lumber playground equipment over wood is its resistance to graffiti.
Plastic lumber is more difficult to carve into. If written or painted on, it can either be cleaned with a
solvent or sanded down. Plastic lumber manufacturers say the advantage of plastic lumber is that it is the
same color all the way through, so that if it is sanded down, it will not require painting. One private
purchaser confirmed that this solid coloring is an advantage, since wooden playground equipment requires
touch-up painting for nicks and scratches.
Strength and Creep Properties
According to an industry consultant, composite plastic lumber has greater tensile strength than 100 percent
plastic lumber. Plastic lumber may bend or sag under weight. According to this consultant, composite lumber resists
bending and warping belter than 100 percent plastic does. Plastic lumber of both types has greater tensile strength
than virgin wood. In other words, plastic lumber is much less likely to break under strain.
Creep is a measure of how much a material deforms under load weight. To test for creep, a length
of lumber is suspended between two supports and a weight is placed in the middle. Plastic lumber has
more tendency to creep than wood. According to an industry consultant, 100 percent plastic lumber can be
used in playground equipment but has demonstrated a problem when bolted or nailed and used in spans of
more than 4 feet (for instance, above a swing). According to a manufacturer, this tendency to creep can be
compensated for by increasing the centers of support (e.g., from 18 inches apart to 12 inches under decks).
Composites do not experience similar problems due to the presence of wood fiber. In the above described
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situation, wood may creep less, but it will fracture under a strain of approximately 0.7 percent. By
contrast, plastic lumber made of 100 percent polyethylene requires a strain of 600 to 800 percent before
fracturing. In other words, plastic lumber may bend or sag under weight more than wood, but under strain,
it will bend much more before it breaks than wood. This tendency to bend rather than break under weight
makes plastic lumber potentially safer than wood in playground applications.
Safety
Safety is a key issue with playground equipment. In 1990, the U.S. Consumer Products Safety
Commission (CPSC) estimated that about 150,000 victims were treated in U.S. hospital emergency rooms
for injuries associated with public playground equipment.
One private purchaser of plastic lumber playground equipment noted a few reasons why plastic
lumber is better from a safety perspective. It does not rot or splinter, and it does not require treatment with
potentially hazardous chemicals. Wood used in playground equipment is commonly treated with
"inorganic arsenicals," and special care must be taken to ensure that the level of dislodgeable arsenic is
minimal. In fact, CPSC urges purchasers to "obtain documentation from the manufacturer that the
preservatives or other treatments applied to the equipment would not present a hazard to the consumer."
CPSC also notes that wood playground equipment should be inspected regularly for rot and splinters.
In addition, CPSC recommends that "to avoid the risk of contact burn injury in geographical
regions where intense sunlight can be expected, bare or painted metal surfaces on platforms and slide beds
should be avoided unless they can be located out of the direct rays of the sun."
In short, plastic lumber playground equipment has potential safety benefits when compared to
playground equipment made with other materials. It conducts less heat than metal equipment. It is more
resistant to rot, splintering, and breaking than wooden equipment. And unlike wood, it does not need to be
treated with potentially hazardous chemicals.
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Other
In its product literature, a manufacturer of single-resin plastic lumber claims that single-resin
lumber is better than mixed plastics, because chemical additives such as pigments and UV stabilizers are
dispersed unevenly through resins with different properties.
c. Availability and Competition
EPA identified and communicated with nine manufacturers of playground equipment, eight of
which use recovered materials in their products. The majority of these manufacturers sell at the national
level. EPA also identified, but did not communicate with, nine additional manufacturers.
d. Economic Feasibility
Playground equipment made with plastic lumber can cost up to 50 percent more than its wooden
counterpart. Manufacturers state that over the long term, plastic lumber saves money due primarily to
longevity and lower maintenance costs. One private purchaser said the plastic lumber playground equipment he
bought was cost competitive with wooden equipment. This purchaser noted that when the lack of maintenance
costs were figured in, this playground equipment was less expensive over the long term.
e. Government Purchasing
The GSA contracting representative for Schedule 781-C, Park and Outdoor Recreation
Equipment, said that, in 1996, GSA-tracked purchasing of playground equipment totaled $4,118,035.
This figure included playground equipment made from all types of materials; the contact was unable to
provide specific information on the materials used. The contact estimates that the actual figure for Federal
spending is approximately 20 percent higher since USPS and DOD often buy "off schedule."
EPA contacted HUD, NPS, the U.S. Department of the Interior, and FHWA. HUD said that
purchasing of playground equipment is done by individual housing projects. NPS said that, in general,
national parks do not purchase playground equipment because of liability issues. Purchasers of
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playground equipment include the U.S. Army and other branches of the Armed Services and the GSA
child care facilities. The U.S. Navy said that no aggregate figures for purchasing of playground equipment
are available as purchasing is decentralized. The states of Georgia, Wisconsin, and Washington said they
did not have statewide policies for procurement of playground equipment. One distributor mentioned
recent sales to Langley Air Force Base and Fort Smith Naval Base, among other U.S. military purchases.
f. Barriers to Purchasing
Playground equipment made with plastic lumber can cost up to 50 percent more than wooden
playground equipment. Greater longevity and reduced maintenance costs may make plastic lumber cost
competitive over the long term. Two purchasers mentioned the lack of industry-wide standards as a barrier
to buying plastic lumber products, partly because of the liability issues related to playground equipment.
One company said they buy playground equipment made from plastic as opposed to plastic lumber. The
contact noted that the company prefers plastic, because it has been tested more extensively and has more
established standards than plastic lumber.
g. Designation
In CPG III, EPA is proposing to designate playground equipment containing recovered plastic,
steel, wood, or aluminum. If designated, a procuring agency would not be precluded from purchasing
playground equipment manufactured from other materials. It would simply require that a procuring
agency, when purchasing playground equipment made from plastic, steel, wood, or aluminum, purchase
these items with recovered materials when these items meet applicable specifications and performance
requirements.
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3.
Procurement Recommendations
a.
Recovered Materials Content
Playground equipment often uses steel for structural pieces, and all steel has recycled content of 25
to 100 percent. One manufacturer makes posts and other structural pieces out of 100 percent recovered
aluminum.
Plastic lumber used in playground equipment contains varying percentages of postconsumer and
total recovered materials. Total recovered materials content for HDPE plastic lumber ranges from 5 to
100 percent, consisting of 5 to 100 percent postconsumer HDPE. Wood/plastic composite lumber can be
made with 50 percent recovered wood waste and 50 percent postconsumer HDPE. One manufacturer of
fiberglass/plastic composite lumber uses 75 percent postconsumer plastic and 20 percent recovered
fiberglass. Information obtained from manufacturers on recovered materials content is displayed in Table
19.
Table 19
Recovered Materials Content of Playground Equipment (Non-Structural Pieces)
Material
HDPE
Postconsumer Content (%)
Company A: 100
Company B: 50
Company C: 0-100
Company D: 60
Company E: 100
Company F: 20
Company G: 100
Company H: 100
Company I: 96
Company J: 98.9
Total Recovered
Materials Cnntpnt (%\
100
100
0-100
85-90
100
30-90
100
100
96
98.9
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Material
Postconsumer Content (%)
Total Recovered
Materials Content (%\
HOPE, LDPE, LLDPE, and
PP
Plastic (Unspecified Resins)
Composite Plastic/Fiberglass
Steel
Company K: 90-95
Company L: 90-95
Company M: 95
Company N: Unspecified
Company O: 75 (Plastic)
Company P: 25-100
100
100
100
Unspecified
20 (Fiberglass)/95 (Total)
25-100
b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 20,
procuring agencies establish minimum content standards for use in purchasing playground equipment.
Table 20
Draft Recovered Materials Content Recommendations for
Playground Equipment
Material
Plastic
Plastic composites
Steel
Aluminum
Postconsumer Content (%)
90-100
50-75
25 - 100
25
Total Recovered
Materials Content (%)
100
95 - 100
25 - 100
25
Notes: "Plastics" includes both single and mixed plastic resins. Playground equipment made with recovered plastics may also
contain other recovered materials such as wood or fiberglass. The percentage of these materials contained in the product
would also count toward the recovered materials content level of the item.
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c. Specifications
Playground equipment is subject to CPSC guidelines and ASTM standard F-1487-95, Safety
Performance Specification for Playground Equipment for Public Use. Both of these standards note that
playground equipment should be "manufactured and constructed only of materials which have a
demonstrated record of durability in the playground or similar outdoor setting." The CPSC guidelines do
not preclude the use of recovered materials. The ASTM standards note that "any new materials shall be
documented or tested accordingly for durability by the playground equipment manufacturer."
Both CPSC and ASTM note issues with regard to the metal fittings and structural pieces used in
playground equipment. ASTM states that "metals subject to structural degradation such as rust and
corrosion shall be painted, galvanized, or otherwise treated." Similarly, CPSC notes that "ferrous metals
should be painted, galvanized, or otherwise treated to prevent rust."
One private purchaser mentioned that, in addition to ASTM and CPSC standards, playground
equipment must also meet state and local codes and standards as well as Federal child safety laws.
PLTA has been working with ASTM's Subcommittee D-20.20.01 to develop several test methods
for plastic lumber. One hundred percent recycled plastic lumber cannot be tested using the same tests
already developed for virgin plastic. Tests on virgin plastic are performed on small cross-sections of the
material. While this is an accurate indicator of how the virgin plastic will perform, as it is a homogeneous
material, some plastic lumber is not homogeneous in its construction, so tests on a cross-section of this
material do not accurately predict how a length of lumber will perform in certain circumstances. For this
reason, new test methods have been developed for lengths of lumber. These test methods apply to all types
of plastic lumber or equivalent materials that are not homogeneous at the cross-section. These test
methods were recently finalized and are scheduled to be available as of early 1998. These test methods are
as follows:
P D 6108-97 Standard Test Method for Compressive Properties of Plastic Lumber.
P D 6109-97 Standard Test Method for Flexural Properties of Unreinforced and Reinforced
Plastic Lumber.
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P D 6111 -97 Standard Test Method for Bulk Density and Specific Gravity of Plastic
Lumber and Shapes by Displacement.
P D 6112-97 Standard Test Method for Compressive and Flexural Creep and Creep
Rupture of Plastic Lumber and Shapes.
P D 6117-97 Standard Test Method for Mechanical Fasteners in Plastic Lumber and
Shapes.
A draft test method is also under review for shear properties. In addition, a task group of the
ASTM subcommittee, working with Batelle Laboratory, is developing performance specifications for
plastic lumber and shapes. These specifications will be divided based on the modulus of the material, a
measure of the product's stiffness.
An industry consultant recommends that purchasers only buy from manufacturers who willingly
provide the results of physical and mechanical product testing done by an outside testing lab. This contact
believes that independent testing is essential, because the quality of plastic lumber products currently
varies tremendously.
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VII. LANDSCAPING PRODUCTS
A. Plastic Lumber Landscaping Timbers and Posts
1. Item Description
Landscaping timbers and posts are used to enhance the appearance of and control erosion in parks,
highways, housing developments, urban plazas, zoos, and the exteriors of office buildings, military
facilities, schools, and other public use areas. Timbers and posts are used in a number of landscaping
applications, such as raised beds, retaining walls, and terracing. Timbers are generally used in horizontal
applications, whereas posts are generally used in vertical applications.
Permanent raised beds are generally built with a frame of rocks, bricks, concrete blocks, railroad
ties, or landscaping timbers. This frame also serves to keep lawn grass and weeds from invading the bed.
Retaining walls are used to retain soil and control erosion. Terraces can turn a steep slope into flat,
usable garden space. Terraces are often made up of a series of retaining walls and resemble a series of
elongated steps. One option for terracing is to hold landscape ties in place behind posts driven into the
ground. Stone, pressure treated wood, used railroad ties, and plastic lumber can all be used to make these
walls.
Landscaping timbers can also be used to frame walkways. Landscaping posts can form the upright
portions of trellises used for climbing flowers.
Landscaping timbers and posts can be used in similar applications to lawn and garden edging
(designated and described in CPGII). They can provide a border between lawns and flower beds. Timbers
and posts differ from lawn and garden edging, however, because they are composed of stiff pieces of
lumber as opposed to thin strips or rolls of material.
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For many landscaping projects, dimensional lumber, such as 4 by 4-foot lengths, is purchased
directly from manufacturers or distributors and is fit together to make the landscaping structures. Some
companies sell kits for landscaping applications, such as retaining walls and raised beds.
Railroad ties are often reused as landscaping timbers and posts. Construction remnants can also be
reused for landscaping applications, but this is not common. The two other materials commonly used in
these landscaping applications are pressure treated virgin lumber or plastic lumber. This product
description focuses on plastic lumber landscaping timbers and posts.
Plastic Lumber
ASTM's draft definition states that plastic lumber is "a manufactured product composed of more
than 50 weight percent resin, and in which the product generally is rectangular in cross-section and
typically supplied in board dimensional lumber sizes, may be filled or unfilled, and may be composed of
single or multiple resin blends." As noted in this definition, plastic lumber is normally produced in
standard dimensional lumber profiles such as 2 by 4-foot lengths, but it can also be produced in sheets.
Some plastic lumber is available in a variety of colors, while other types come in only one or two different
shades. PLTA identifies four main technologies used to produce recycled plastic lumber.
P Single-polymer systems made from recycled HOPE. EPA's research noted that most of
the manufacturers of 100 percent HDPE plastic lumber use 100 percent postconsumer
HDPE for their products. This HDPE often comes from sources such as used milk jugs,
water jugs, detergent bottles, and soda bottles.
P Mixes of recycled polyethylene and/or other recycled plastics (commingled plastics).
EPA's research identified several different mixtures of resins that fall into this category
including a mixture of HDPE and LDPE; PE and PP; and HDPE, LDPE, LLDPE, and PP.
In addition, a few manufacturers were identified who make lumber from unspecified resins.
P Fiberglass reinforced polyethylene. EPA's research revealed that a few manufacturers
reinforce plastic lumber with fiberglass rods, while others disperse fiberglass into the
plastic lumber to increase its stiffness.
P Wood/thermoplastic composites. Some manufacturers blend plastic resin with wood
chips and/or sawdust. A typical blend is 50 percent recovered plastic (usually HDPE) and
50 percent recovered wood.
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When recycled plastic is mixed with wood, fiberglass, or some other material to make lumber, the
end product is generally referred to as "composite lumber." Composite lumber also can be made by
mixing plastic and rubber scrap.
Plastic lumber is generally made in one of two ways: by extrusion into a mold, or by continuous
extrusion. For 100-percent HDPE plastic lumber, the HDPE is ground up, melted, and mixed with
additives. These additives frequently include UV inhibitors and coloring agents. A blowing agent can also
be added to decrease the density of the material. The plastic is then either flowed into a mold (extrusion
into a mold) or pulled out of a machine, shaped using a series of sizing plates, cooled, and cut to the
desired length (continuous extrusion).
The Plastic Lumber Industry
The PLTA report, The State of the Recycled Plastic Lumber Industry: 1996, estimates that the
1996 sales volume for plastic lumber products was between $40 and $60 million. The report also
estimates that the industry has been growing at an annual growth rate of 30 to 40 percent. PLTA has
identified 27 manufacturers of recycled plastic lumber, including both 100 percent plastic and composite
types. The report lists figures for percentages of plastic lumber sales for the park and recreation industry
(50 to 70 percent), residential decking (5 percent), marine and waterfront use (5 to 15 percent), material
handling (less than 5 percent), and miscellaneous (20 to 30 percent), but does not specifically mention
lumber used for landscaping applications.
Three lumber trade associations and a landscaping trade association were unable to provide figures
on the volume of virgin wood used for landscaping applications. The landscaping association commented,
"in general, there is a lack of sound marketplace data for landscaping."
2. Rationale for Designation
EPA believes that plastic lumber landscaping timbers and posts containing recovered materials
meet the statutory criteria for selecting items for designation.
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a. Impact on Solid Waste
Landscaping timbers and posts can be made with recovered wood (sawdust and wood chips used in
composite lumber), HOPE, LDPE, PE, PET, PP, PS, PVC, and other plastic resins. Appendix I of this
document discusses the generation and recovery of wood and plastic in MSW.
According to one manufacturer, extruding HDPE into a mold requires approximately 6.3 milk and
water jugs to make 1 pound of 100 percent HDPE plastic lumber. Another manufacturer said their
continuous extrusion process requires seven milk jugs to make 1 pound of plastic lumber. A third
manufacturer stated that their continuous extrusion process requires approximately nine milk jugs to make
a pound of plastic lumber. This manufacturer said the most common lumber profiles used in landscaping
applications are 4 by 6-foot and 6 by 6-foot lengths. A 4 by 6-foot lumber profile weighs approximately 5
pounds per foot and a 6 by 6-foot lumber profile weighs approximately 7 pounds. Assuming 6.3 to 9 milk
jugs per pound, 1 foot of a 4 by 6-foot lumber profile would use approximately 31.5 to 45 milk jugs.
Therefore, if a Federal agency were to buy 1,000 linear feet of 4 by 6-foot dimensional lumber, between
31,500 and 45,000 milk jugs would be diverted from the municipal solid waste stream. Similarly, if a
Federal agency were to buy 1,000 linear feet of 6 by 6 dimensional lumber, between 44,100 to 63,000
milk jugs would be diverted from the municipal solid waste stream.
One manufacturer of wood/plastic composite lumber made from recovered sawdust and postconsumer
LDPE estimates that between 25 and 100 plastic grocery bags are used to make one foot of lumber, depending
on the dimensions of this lumber (i.e. 2 by 6-feet, 4 by 4-feet, 6 by 6-feet). If the government were to buy 1,000
linear feet of this lumber, it would divert 25,000 to 100,000 plastic (LDPE) grocery bags from the municipal
solid waste stream. This manufacturer also estimates that, in 1996, the company used 50 million pounds of
FIDPE, LDPE, and LLDPE and 70 million pounds of sawdust to produce their products. They were unable to
provide figures regarding the percentage of their products used for landscaping applications.
A manufacturer of mixed resin plastic lumber said it would be too difficult to estimate the amount of
recovered materials used in their products, since they use varying amounts of so many different kinds of
materials. Their plastic lumber consists of 100 percent postconsumer plastic including PET, FIDPE, LDPE,
LLDPE, PVC, and PS.
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The amount of lumber used in landscaping varies greatly depending on the specific application.
One manufacturer estimates that a typical commercial landscaping job might use 50 4 by 4 foot boards.
b. Technological Feasibility and Performance
A number of technical and performance issues exist with respect to the different materials used to
make landscaping timbers and posts. In particular, wood and plastic lumber landscaping timbers and posts
differ in terms of longevity and durability, the effects of temperature, maintenance, strength, weight, and
other issues. Different kinds of plastic lumber also differ with respect to these performance issues.
Longevity and Durability
Manufacturers say plastic lumber timbers and posts will last two to three times longer than their
wooden counterparts. They note that plastic lumber is resistant to rot, termites, and deterioration. One
manufacturer of wood/plastic composite lumber said that they have performed a special test simulating the
extreme conditions of the Florida Everglades (e.g. high amounts of rain and UV exposure). Although the
manufacturer declined to provide the results of this test, they guarantee their products for 10 years. Two
manufacturers of 100 percent HDPE plastic lumber offer 20 and 25 year warrantees respectively. One
government purchaser mentioned that after using plastic lumber for 7 years in a number of applications,
including landscape retaining walls, he is convinced that claims about the product's longevity,
serviceability, and durability are accurate.
Maintenance Issues
Manufacturers of plastic lumber posts and timbers say one advantage of this material is that it is
virtually maintenance-free. Wood timbers need to be painted, stained, or treated on a regular basis. One
government purchaser of 6 by 6 foot plastic lumber profiles used in retaining walls confirmed that the
plastic lumber is virtually maintenance-free.
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Strength and Creep Properties
Terraces and retaining walls built with landscaping timbers must be able to withstand considerable
pressure from wet soil. According to an industry consultant, wood/plastic composite lumber has greater
tensile strength than 100 percent plastic lumber. Plastic lumber may bend or sag under weight. According
to this consultant, composite lumber resists bending and warping better than 100 percent plastic. Plastic
lumber of both types has greater tensile strength than virgin wood. In other words, plastic lumber is much
less likely to break under strain.
Creep is a measure of how much a material deforms under load weight. To test for creep, a length of
lumber is suspended between two supports, and a weight is placed in the middle.
Plastic lumber has a tendency to creep more than wood. In the above described situation, wood may creep less,
but it will fracture under a strain of approximately 0.7 percent. By contrast, plastic lumber made of 100 percent
PE requires a strain of 600 to 800 percent before fracturing. In other words, plastic lumber may bend or sag
under weight more than wood, but under strain, it will bend much more than wood before it breaks.
Heat and Cold
Some plastic lumber has a tendency to expand and contract with changes in temperature. One
manufacturer noted that an 8-foot recycled plastic lumber board may expand or contract one quarter inch
with a 50° temperature fluctuation. Extremes of heat and cold can cause warping or cracking. One
manufacturer's product literature states that single-resin plastic lumber is better than commingled plastic,
because different resins expand and contract at different rates, causing internal stresses that may cause
warping. According to an independent consultant, wood/plastic composite lumber expands and contracts
much less than 100 percent plastic. The chair of ASTM Subcommittee D-20.20.01, Plastic Lumber and
Shapes, commented that plastic inherently has a larger thermal expansion than wood. This tendency to
expand and contract based on temperature changes can be controlled by adding glass or other
reinforcements. One government purchaser of plastic lumber used for seven consecutive years in boat
docks noted that the lumber has been exposed to temperatures ranging from -38° to 112° with no
problems. Another government purchaser of plastic lumber used in landscape retaining walls for 6 years
said the product has been exposed to temperatures ranging from 27° to 110° without problems.
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Weight
Plastic lumber timbers can weigh two to three times more than wood. Some manufacturers make
hollow profile dimensional lumber as well as solid dimensional lumber to compensate for this weight
difference. The weight of the plastic lumber may provide an advantage for landscaping timbers and posts
used in structural applications by contributing added strength and stability.
Leaching
One environmental organization, reporting on the chemicals used to preserve pressure-treated or
creosote-treated lumber, noted, "Studies on the movement of wood preservatives from poles have found
that they move from poles into soil and from the soil into aquatic ecosystems." Some states, such as
California, have banned the use of creosote. Plastic lumber does not need to be treated with chemicals and
so does not have the same potential for leaching.
Other
A plastics consultant noted the importance of UV stabilizers and inhibitors to prevent
discoloration. One manufacturer's product literature states that single resin plastic lumber is better than
mixed plastics lumber because chemical additives, such as pigments and UV stabilizers, are dispersed
unevenly through resins with different properties. One manufacturer mentioned that one of the benefits of
wood/plastic composite lumber is that, unlike 100 percent plastic, it can be painted if desired.
c. Availability and Competition
EPA contacted 11 companies who manufacture either specialized landscaping timbers and posts
made out of plastic lumber or plastic lumber profiles that can be used for landscaping. EPA also identified
50 manufacturers and/or distributors of plastic lumber. The majority of these companies sell on a national
level.
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d. Economic Feasibility
Plastic lumber can cost up to 50 percent more than its wooden counterpart. Manufacturers say its
longevity, durability, and low maintenance costs make it cost competitive to wood in the long term.
e. Government Purchasing
Materials for landscaping are purchased by all levels of government but the quantity or dollar
value is not known. EPA contacted the U.S. Department of Interior, HUD, NPS, FHWA, and the Chief of
Naval Operations office. Some U.S. Navy bases purchase landscaping timbers, but the Navy did not have
figures on the recovered materials used in these products. Within NPS, a number of parks purchase
landscaping timbers and posts, and there are currently 14 proposed landscaping projects that plan to use
plastic lumber. The specifications and standards used in these proposed projects were unavailable. The
states of Georgia, Washington, and Wisconsin are purchasing landscaping timbers, but could not provide
any aggregate figures, because purchasing is decentralized. The Recreation and Park District of the City
of Carmichael, California, has purchased dimensional plastic lumber for landscaping applications.
f. Barriers to Purchasing
Plastic lumber can cost up to 50 percent more than wood, which can be a barrier if initial cost is
the only criterion considered. One state purchaser noted that one of the biggest barriers to purchasing
plastic lumber products is the current lack of industry-wide standards that would ensure consistent
product quality.
g. Designation
In CPG III, EPA is proposing to designate plastic lumber landscaping timbers and posts containing
recovered materials. A final designation would not preclude a procuring agency from purchasing
landscaping timbers and posts manufactured from another material, such as wood. It simply
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requires that a procuring agency, when purchasing landscaping timbers and posts made from plastic
lumber, purchase them with recovered materials when they meet applicable specifications and
performance standards.
3. Procurement Recommendations
a. Recovered Materials Content
Plastic lumber used for landscaping contains varying percentages of postconsumer and total
recovered materials content. For 100-percent HDPE plastic lumber, postconsumer content ranges from 20
to 100 percent and total recovered materials content ranges from 20 to 100 percent. Wood/plastic
composite lumber can be made with 50 percent recovered wood waste and 50 percent postconsumer
HDPE. One manufacturer of wood/plastic composite lumber uses 50 percent "post-industrial" sawdust
recovered from furniture, flooring, and other plants, and 50 percent postconsumer mixed polyethylene
(LDPE, HDPE and LLDPE), primarily consisting of LDPE grocery bags and plastic wrap. A
manufacturer of mixed-resin plastic lumber uses a 100 percent postconsumer blend of resins including
LDPE, LLDPE, HDPE, polystyrene (PS), polyethylene tetraphthalate (PET) and PVC, from materials
such as plastic wrap, yogurt cups, and bottle caps. One manufacturer of fiberglass/plastic composite
lumber uses 75 percent postconsumer plastic and 20 percent recovered fiberglass. Table 21 details the
postconsumer and recovered materials content of the lumber produced by manufacturers contacted by
EPA, listed in the Recycled Products Guide, or listed on the Internet.
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Table 21
Recovered Materials Content of Landscaping Timbers and Posts
Material
HOPE
LDPE, HOPE,
LLDPE/Sawdust
HOPE, Fiberglass
HOPE, LDPE
HDPE, Commingled Plastic
(unspecified resins)
Postconsumer Content (%)
Company A: 25-90
Company B: 0-100
Company C: 75-100
Company D: 100
Company E: 50
Company F: 0-100
Company G: 100
Company H: 100
Company I: 100
Company J: 100
Company K: 100
Company L: 80
Company M: 25
Company N: 95
Company O: 100
Company P: 0-100
Company Q: 96
Company R: 80-100
Company S: 30-50
Company T: 95
Company U: 85-95
Company V: 100
Company W: 50
Company X: 75 HDPE
Company Y: 90
Company Z: 50-100
Total Recovered
Materials Content (%)
25-90
0-100
75-100
100
100
0-100
100
100
100
100
100
80
100
100
100
0-100
96
80-100
100
100
85-95
100
100
95 (20 recovered fiberglass)
100
100 (0-50 recovered plastic)
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Material
LDPE, PP
Mixed Resins (PET, HOPE,
LDPE, LLDPE, PVC, PS,
Other)
Mixed Resins (HOPE, LDPE,
LLDPE, PP)
Mixed Resins (HOPE, LDPE,
PET, PP)
Mixed Resins (HOPE, PP,
PET)
Mixed Resins (HOPE, PET,
PE, LDPE)
Plastic
(unspecified)/Wood/Sawdust
Plastic (unspecified)
Postconsumer Content (%)
Company AA: 100
Company BB: 100
Company CC: 90-95
Company DD: 80
Company EE: 100
Company FF: 97
Company GG: 100
Company HH: 100
Company II: 50-100
Company JJ: 95
Company KK: 100
Company LL: 0-100
Company MM: 100
Company NN: 80
Company OO: 95
Company PP: 50
Company QQ: 40-60
Company RR: 80-100
Company SS: varies
Company TT: varies
Company UU: 90
Company VV: 30-50
Company WW: 50
Company XX: 100
Total Recovered
Materials Content (%)
100
100
95-100
100
100
97
100
100
50-100
100
100
0-100
100
100
100
100
100
80-100
96
100
100
100
100
100
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Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
Plastic (unspecified)/Rubber
tires
PE
Company AAA: 100
Company BBB: 60
Company CCC: 97
100
100
97
b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 22,
procuring agencies establish minimum content standards for use in purchasing landscaping timbers and
posts.
Table 22
Draft Recovered Materials Content Recommendations
for Landscaping Timbers and Posts
Material
HOPE
Mixed plastics/sawdust
HDPE/Fiberglass
Other mixed resins
Postconsumer Content (%)
25 - 100
50
75
50- 100
Total Recovered
Materials Content (%)
75 - 100
100
95
95 - 100
Note: EPA's recommendations do not preclude a procuring agency from purchasing wooden landscaping timbers and posts.
They simply require that procuring agencies, when purchasing plastic landscaping timbers and posts purchase these items
made with recovered materials when the items meet applicable specifications and performance requirements.
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c. Specifications
PLTA has been working with ASTM's Subcommittee D-20.20.01 to develop several test methods
for plastic lumber. One hundred percent recycled plastic lumber cannot be tested using the same tests
already developed for virgin plastic. Tests on virgin plastic are performed on small cross-sections of the
material. This is an accurate indicator of how the virgin plastic will perform as it is a homogeneous
material. Plastic lumber, however, is not homogeneous in its construction, so tests on a cross-section of
this material do not accurately predict how a length of lumber will perform in certain circumstances. For
this reason, new test methods have been developed for lengths of lumber. These test methods apply to all
types of plastic lumber or equivalent materials that are not homogeneous at the cross-section. These test
methods were recently finalized and are scheduled to be available as of early 1998. These test methods are
as follows:
P D 6108-97 Standard Test Method for Compressive Properties of Plastic Lumber.
P D 6109-97 Standard Test Method for Flexural Properties of Unreinforced and Reinforced
Plastic Lumber.
P D 6111 -97 Standard Test Method for Bulk Density and Specific Gravity of Plastic
Lumber and Shapes by Displacement.
P D 6112-97 Standard Test Method for Compressive and Flexural Creep and Creep
Rupture of Plastic Lumber and Shapes.
P D 6117-97 Standard Test Method for Mechanical Fasteners in Plastic Lumber and
Shapes.
A draft test method is also under review for shear properties. In addition, a task group of the
ASTM subcommittee, working with Batelle Laboratory, is developing performance specifications for
plastic lumber and shapes. These specifications will be divided based on the modulus of the material, a
measure of the product's stiffness.
An industry consultant recommends that purchasers only buy from manufacturers who willingly
provide the results of physical and mechanical product testing done by an outside testing lab. This contact
believes that independent testing is essential, because the quality of plastic lumber products currently
varies tremendously.
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B. Food Waste Compost
1. Item Description
In May 1995, EPA designated yard trimmings compost in the CPG. At that time, most food waste
composting programs were still pilot projects and few large-scale programs existed. The number of
composters incorporating food waste grew from 58 to 214 between 1995 and 1997, however, and the
market continues to expand. In light of this growth, this product description focuses on food waste
composting as a specific sector of the composting industry.
The Composting Council and most compost facility operators contacted support the designation of
compost that meets state standards, with no specifications about the specific organic wastes comprising its
content. Although EPA has no separate standards for compost, many states use Chapter 40 of CFR Part
503 criteria for "sewage sludge used in land applications" for compost usage. The 40 CFR Part 503
criteria outline maximum pollutant levels, such as heavy metal and chemical levels, and provide standards
for other chemicals, such as nitrogen.
EPA's research suggests that it is difficult to talk about "food waste compost" as a completely
separate item, since most food waste composting programs add other available organic materials such as
wood chips, sawdust, manure, or yard trimmings to their mixes. Different types of compost are better
suited to different applications, making information about the composition of the compost feedstocks
important to purchasers. Thus, there is no consensus among compost experts about how compost made
with a significant amount of food waste should be classified. There is agreement, however, that all types
of mature compost have great value due to humus and micro-organism content as soil amendments and
fertilizer.
Composting is the controlled biological process of decomposition of organic matter in the presence
of air to form a humus-rich material which provides organic matter and nutrients to the soil. Mature
compost (in which the composting process is completed) is composed of small brown particles, resembles
soil, and is free of pathogens and weed seeds. The Composting Council defines mature compost as
follows:
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Compost is the stabilized and sanitized product of composting; compost is largely
decomposed material and is in the process ofhumification (curing). Compost has little
resemblance in physical form to the original material from which it was made. Compost
is a soil amendment, to improve soils. Compost is not a complete fertilizer unless amended,
although composts contain fertilizer properties, e.g., nitrogen, phosphorus, and potassium,
that must be included in calculations for fertilizer application.
Compost added to soil improves the ability of the soil to support plant growth. The organic matter
in compost is particularly beneficial to soil with poor infrastructure. Adding compost to clay soil, for
example, reduces soil density and compaction, increases aeration, and increases soil porosity and drainage.
These soil changes make plants less susceptible to root rot disease. Compost added to sandy soil increases
its ability to retain water and nutrients and increases its resistance to drought and erosion.
Compost can be used in a wide range of applications. It can be used as a substitute for peat moss,
potting soil, topsoil, or other organic materials in agriculture, horticulture, silviculture (growing of trees),
and in landscaping. In landscaping, compost is used as a soil conditioner, soil amendment, lawn top
dressing, potting soil mixture, rooting medium, and mulch for shrubs and trees, and for restoration and
maintenance of golf course turf and other sports turf. Compost also can be used for bioremediation of
contaminated soils, treatment of contaminated stormwater runoff, volatile organic compound (VOC)
emission reduction, and reclamation of mining sites.
2. Rationale for Designation
EPA believes that food waste compost containing recovered organic materials meets the statutory
criteria for selecting items for designation.
a. Impact on Solid Waste
Composting serves as a method of managing organics that would otherwise be landfilled or
disposed of in some other manner. Up to 60 percent of municipal solid waste is potentially compostable
(including food, paper, and yard trimmings). Appendix I of this document discusses the generation and
recovery of food waste in MSW. Although food wastes represent nearly 7 percent of MSW, at present, a
small percentage (4.1 percent) of food waste is recovered. Food waste is often composted with yard
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wastes which comprise more than 14 percent of MSW. Composting provides a unique opportunity to
manage large quantities of food wastes and other organic components of MSW and produce a product that
has many beneficial uses.
b. Technological Feasibility and Performance
Currently, food waste composting is primarily being done by large corporations, because economic
and permitting issues discourage widespread curbside food waste collection programs. Due to health code
regulations regarding food waste's potential to contain pathogenic bacteria, compost facilities must obtain
permits to accept food waste for composting. Currently, waste haulers are reluctant to haul food waste,
because of the permits needed, its weight and odor problems, its potential to soil trucks, and its potential
to contain pathogens. During the composting process, however, these pathogens are terminated so that the
compost product does not pose a threat to public health or the environment.
Many composters have had difficulty obtaining the necessary equipment to manage the actual
composting of food waste, since food scraps generate leachate and odors and are difficult to handle due to
their high moisture content.
Benefits
The nutrient and organic carbon content of compost serves as a food source for micro-organisms in
soil, thus increasing the availability of the soil's organic and nutrient content to plants and aiding faster
recycling of nutrients within the system. In addition to returning organic materials and nutrients to the soil,
other advantages of amending soil with compost include:
# Moderates soil temperature, so that plant roots are warmed in winter and, through water
retention, cooled in dry, hot conditions.
# Suppresses some plant diseases, such as wilt and root rot, reducing the need for chemical
pesticides and fungicides. Compost has been shown to be important in controlling wilt
disease in certain flowers commonly grown for indoor use. Specifically, compost prevents
fusarium wilt disease on cyclamens, a disease that is not otherwise treatable.
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# Replaces part or, in some cases, all of the fumigants and fungicides used on food crops or
landscape projects, according to research conducted at Ohio State University and verified
by researchers in Florida, Pennsylvania, and Alabama.
# Releases nutrients in organic form, such as nitrogen, into the soil slowly overtime. This
property of compost allows for a significant reduction in fertilizer use and is compatible
with the rate of plant root uptake.
# Reduces nonpoint source runoff by preventing siltation and by degrading pollutants in the
runoff.
# Restores contaminated, eroded, or compacted soil.
Compost's fine organic composition increases the soil's water-holding capacity. Compost also
increases water infiltration into the soil. Compost helps to reduce soil compaction and increase soil
friability, thus decreasing the erodability of soil. Finally, compost prevents the crusting of soil surfaces,
which can otherwise inhibit seedling growth.
c. Availability and Competition
The first nationwide survey of composting projects to include food waste was conducted in 1995.
At that time, there were 58 projects in operation or in a demonstration phase. By 1997, that number had
risen to 214 operational composting projects in 36 states. The number of food composting projects is
expected to rise, as more food processors begin composting the byproducts of food production and with
the increased availability of technologies and equipment to make onsite composting viable.
According to some sources, food waste composting is only available on a regional basis. In Maine,
for example, food waste programs have grown steadily, but are still operating on a small scale. The state
has a 50 percent recycling goal by 2000, and, according to one contact, the seafood, blueberry, and potato
industries have begun to look at composting to help meet that goal. At this time, Maine food waste
composters could not supply enough product for a large highway project, but could provide compost for
smaller landscaping projects such as flower gardens and borders in public parks. The largest growth in
food waste composting appears to be in areas of the country with high tipping fees and a high demand for
the end product. In particular, continued growth is expected in New Jersey, Florida, and on the west coast.
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Nationwide, the number of food waste composting programs is increasing, but it is still a developing
industry that faces logistical problems such as transportation. In general, continued growth is expected as
more programs are incorporated into existing yard trimmings composting programs.
d. Economic Feasibility
Compost industry experts have demonstrated that mature compost exceeds the performance of peat
moss, potting soil, or topsoil in function, since mature compost provides nutrients and acts as a fertilizer,
mulch, and potting soil. In an economic comparison, however, experts indicate that peat moss, potting
soil, and topsoil are compost's closest competitors. Compost prices are usually comparable to or less than
those for peat moss, potting soil, and topsoil. Some specially designed composts are more expensive,
however, than traditional potting soil mixes alone. In these cases, the compost is able to substitute not only
for potting soil, but also for fertilizers and pesticides, since compost naturally provides extra nutrients and
retards diseases and pests.
According to several contacts, curbside food waste collection projects are not currently cost-
effective, though there are about 15 to 20 such programs in operation in the country. It is still cheaper to
landfill household food waste, due to transportation issues and permit requirements.
Companies that operate large food production facilities have found food waste composting to be
economically attractive. While initially only avoiding disposal costs, one such company expects to profit
from its operation within the next 2 years through increased revenues from the sale of compost, tipping fee
revenues from yard trimmings brought to the site, and improved efficiency of the overall operation.
The same company transports materials, including spent coffee grounds, tea leaves, pasta, and
bread dough, from four of its food production plants (one in New Jersey, one in New York, and two in
Connecticut) to its compost facility in New Milford, Connecticut. The company sells the finished product
to a distributor which then sells the compost in bulk. It uses an aerated windrow system in a closed
building for more than 85 percent of the material. The remaining material is processed in one of three open
bay compost agitators utilizing specialized equipment. Due to recurring maintenance problems with the
equipment, the company plans to eventually process all of its compost using the windrow system. In
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fact, the majority of operating composting facilities utilize the windrow composting method. The company
sells the finished product to a distributor, which sells the compost in bulk for $2 to $16 per yard,
depending upon market fluctuations.
Another large company would not discuss the economics of its operation in detail, but revealed that
it sends liquor from cleaning operations, liquid drained out of grains, cattle feed, and bottle cleaning
wastes to the city of Merrimack, New Hampshire. Merrimack mixes this waste with municipal sewage
waste, composts the mix, and sells the compost locally and to a company that markets the product to more
distant markets, including New York City's Central Park.
Institutions with large cafeterias, such as universities, hospitals, and prisons, constitute one of the
fastest growing sectors in the food composting arena. Grocery stores and restaurants are also sources of
food waste compost. One grocery store's food waste composting program was one of the first in the
country. The Seattle-based chain conducted a pilot project with a yard waste composter in 1991 and 1992
that showed its food waste could be efficiently collected, transported, and composted. The store's
composting program and recycling program saved them $40,000 in 1993.
Of the 70 correctional facilities in New York State, 48 compost food waste. In fiscal year 1996, these
institutions diverted approximately 8,300 tons of food waste for a savings of more than $1 million. These
savings included avoided disposal costs, hauling fees, and equipment maintenance and storage costs.
e. Government Purchasing
Military installations alone contain about 20 million acres of land that need to be maintained. The
potential compost usage (at 40 cubic yards per acre) for even a portion of this acreage would be
significant. A Marine Corps base in Camp Lejeune, North Carolina, for example, has been composting
food waste for more than 2 years. The operation mixes food waste from mess halls on the base with
shredded paper, cardboard and yard and wood waste. The facility accepts an average of 10 tons of food
waste per week, generating more than 2,400 tons of yard trimmings and food waste compost per year for
use on the base's more than 150,000 acres. Compost is used on landscaping projects and made available
to contractors for use in construction projects.
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As part of a 1-year demonstration project, the DOD District Depot in New Cumberland, Pennsylvania,
partnered with a nearby state correctional facility to compost its food waste. The depot mixed the food waste
with scrap wood from its pallet reclamation operation in two aerated static piles. The finished product was used
onsite for landscaping projects and made available to project partners, including the local townships. In
addition, Whiteman Air Force Base in Missouri generated 42 tons of food waste compost through a pilot
program in the fall of 1995. Using an invessel system, the base mixed yard trimmings with the food waste
generated at a recycling conference in Kansas City. They have used the compost on the base and given at least
40 cubic yards to the local solid waste district for a local land improvement program. By the fall of 1998, the
base plans to establish a permanent invessel food waste composting operation.
Other Federal markets for compost made with food waste could be substantial. As of 1997, the
U.S. Forest Service and Park Service maintain 500,000 miles of roadsides and embankments and millions
of acres of land. The U.S. Forest Service manages more than 190 million acres of land at 156 national
forests, while the U.S. Park Service manages more than 83 million acres and 369 national parks. At John
Muir National Historic Site, for example, fruit residuals from the 8 acres of orchards and vineyards are
composted with wood chips, yard trimmings and paper waste. The site composts approximately 6 tons per
year in three 20-cubic yard containers. In addition, universities, hospitals, and prisons may be using
appropriated Federal funds for their composting operations and purchases.
To assist in the development of Federal markets for compost, President Clinton issued a
memorandum entitled, "Environmentally and Economically Beneficial Practices on Federal Landscaped
Ground" on April 26, 1994. Agencies are encouraged to develop practical and cost-effective landscaping
methods that preserve and enhance the local environment. This memorandum requires the use of mulches
and compost by Federal agencies and in Federally funded projects.
f. Barriers to Purchasing
Potting soil, top soil, and peat moss have long-established markets that make it difficult for compost to
compete for increased market share. One other barrier identified is that the infrastructure especially
transportationneeded to allow food waste composting programs to flourish is not well established. Waste
haulers are currently reluctant to agree to haul food waste, because of its weight, odor, potential to soil
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trucks, and potential to contain pathogens. Most food waste operations must contract out for hauling, but
finding economical transport is difficult at this stage in market development.
Permitting issues present similar barriers to the implementation of food waste composting
programs. Obtaining a solid waste permit can be an expensive and time consuming process. In general,
however, state regulations are much less stringent for sites taking only preconsumer vegetative materials
such as produce trimmings and spoiled fruits and vegetables from grocery stores, produce terminals,
restaurants, and salad processors, as opposed to leftover food from restaurants, institutions, and homes.
Also, some states have recognized the potential of composting to increase recycling rates and have tried to
streamline regulations to accommodate increased composting of food waste. As a result, according to an
industry observer, these states have helped foster much more composting of commercial, institutional, and
industrial wastes.
g. Designation
EPA is proposing to revise the yard trimmings compost designation to include compost made from
food waste or commingled food waste and yard trimmings.
3. Procurement Recommendations
a. Recovered Materials Content
Food waste compost contains 100 percent recovered materials. Institutions such as prisons,
universities, and hospitals are excellent sources of food waste for large-scale or regional composting
projects. Commercial establishments, such as grocery stores, restaurants, and cafeterias, also provide
materials for use in commercial composting. In addition, a few curbside programs provide food waste to
community-based composting programs. Fruit and vegetable trimmings are the most common feedstock
composted, followed by kitchen preparation residuals, which can include overcooked pasta, stale rolls, and
soups. Most food waste compost programs mix other organic materials, such as sawdust, wood chips,
yard trimmings, or manure, with food wastes to produce compost. These other added materials vary
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depending upon what is available to the program, and what nutrients or bulking agents are needed to make
a high quality compost. Yard trimmings are the most popular amendment to food waste compost, followed
by wood chips and sawdust.
Because compost is often tailor-made or designed for specific uses, the recovered materials used
can vary. Whether the ingredients are food wastes, manure, biosolids, yard waste, wood chips, or mixed
municipal waste, compost may be formulated to fit a particular end use, such as landscaping or land
reclamation. A company in Maine that composts ground mussel waste and sawdust, for example, needed
additional nitrogen to facilitate the composting process and to decrease odors. Chicken manure, a readily
available source of nitrogen in the area, was added to the mix. The additional nitrogen accelerated the
composting process, decreased odors, and provided the company with a higher quality end product.
b. Preference Program
EPA recommends that procuring agencies purchase or use compost made from yard trimmings,
leaves, grass clippings and/or food wastes in such applications as landscaping, seeding of grass or other
plants on roadsides and embankments, as nutritious mulch under trees and shrubs, and in erosion control
and soil reclamation.
EPA further recommends that those procuring agencies that have an adequate volume of yard
trimmings, leaves, grass clippings, and/or food wastes, as well as sufficient space for composting, should
implement a composting system to produce compost from these materials to meet their landscaping and
other needs.
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c. Specifications
The Composting Council is helping to define and develop industrywide standards for composts
made from various combinations of materials, including food wastes. The Composting Council publishes
these standards in an operating guide for composting facilities. The guide also provides standards for the
suitability of different types of composts made for different applications, depending on the compost mix
(59 FR 18878). As stated previously, many states have adopted EPA's 40 CFR Part 503 criteria for
"sewage sludge used in land applications" for compost usage. Also, in DOT's Standard Specifications for
Construction of Roads and Bridges on Federal Highway Projects 1996, the agency specifies mature
compost for use in road construction and does not specifically preclude the use of food waste in its
required composition of compost.
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VIII. NON-PAPER OFFICE PRODUCTS
A. Plastic Binders, Clipboards, File Folders, Clip Portfolios, and Presentation Folders
1. Item Description
Plastic binders, clipboards, file folders, clip portfolios, and presentation folders are commonly used
office products made from a variety of materials, such as paper, plastics, paperboard, and wood fiber. The
EPA has previously designated paper file folders, pressboard binders, and plastic-covered chipboard or
paperboard binders. The Agency recently learned, however, that these office products also can be made of
solid plastic containing recovered materials. As shown in Table 23, the types of recovered plastic used in
these products include HDPE, PE, PET, PS, and an unspecified plastic from recovered circuit boards,
telephones, and vacuum cleaners.
Table 23
Materials Used in Solid Plastic Binders, Clipboards, File Folders,
Clip Portfolios, and Presentation Folders
Product
Binders
Clipboards
File folders
Clip portfolios
Presentation folders
Type of Recovered Plastic Used
HDPE, PE,
HDPE, PS,
telephones,
PET, and recovered circuit boards
and unspecific plastic from recovered circuit boards,
and vacuum cleaners
HDPE
HDPE
HDPE
2. Rationale for Designation
EPA believes that solid plastic binders, plasic clipboards, plastic file folders, plastic clip portfolios,
and plastic presentation folders meet the statutory criteria for selecting items for designation.
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a. Impact on Solid Waste
Recovered-content plastic binders, clipboards, file folders, clip portfolios, and presentation folders
are made of postconsumer HDPE, PE, PET, PS, and an unspecified plastic from recovered circuit boards,
telephones, and vacuum cleaners. Appendix I of this document discusses the generation and recovery of
plastics in MSW.
According to a distributor of recovered-content HDPE binders, each binder is made from
approximately eight plastic bottles collected from residential curbside collection programs. For every 500
binders ordered, therefore, 4,000 HDPE bottles would be diverted from the waste stream.
b. Technological Feasibility and Performance
According to a product distributor, recovered-content HDPE binders, clipboards, file folders, clip
portfolios, and presentation folders perform as well as their virgin counterparts. In addition, two
government users of these products indicated that the products performed well.
A user of recovered-content PE binders stated that the binders performed well and were less
expensive than binders made of virgin materials because of the quantity purchased. In addition, a user of
recovered-content PS clipboards stated that the clipboards performed well.
c. Availability and Competition
Recovered-content solid plastic binders, clipboards, file folders, clip portfolios, and presentation
folders are available from a number of sources nationwide.
EPA identified one processor of the recovered-content HDPE (minimum 90 percent postconsumer
content) used in binders, file folders, clipboards, clip portfolios, and presentation folders. EPA identified
at least five distributors that use this recovered material in the products they distribute. The HDPE
binders, clipboards, and presentation folders are also available through an additional distributor as a New
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Item Introductory Schedule on GSA's Federal Supply Schedule. (The specification numbers are 7510 for
binders, 7520 for clipboards, and 7530 for presentation folders.) That distributor's contract with GSA is
effective as of November 1, 1996, and runs through October 31, 1999.
EPA also identified five manufacturers and distributors of recovered-content plastic binders,
clipboards, and file folders made from other kinds of plastic, including PE, PS, PET, and unspecified
plastics.
d. Economic Feasibility
Distributors indicated that the recovered-content HDPE binders, clipboards, file folders, clip
portfolios, and presentation folders are priced competitively with their virgin counterparts. Two contacts
EPA spoke with stated that the recovered-content HDPE binders were slightly higher in cost than their
virgin counterparts. One user stated that he was able to purchase the recovered-content binders despite
their higher cost due to a price preference for recovered-content items. This user reported a price
differential of 30 cents (Canadian) per binder, making the recycled-content binder 8 percent more
expensive than the binder made of virgin materials. A user of recovered-content PE binders stated that
they were less expensive than binders made of virgin materials, because of the quantity purchased. A
manufacturer of recycled-content PS clipboards and PE binders indicated that its products are cost-
competitive to their virgin counterparts. A user of recovered-content PS clipboards did not know whether
the clipboards were priced competitively to virgin clipboards.
e. Government Purchasing
The vendor on GSA's Federal Supply Schedule for the recovered-content HDPE binders, clipboards,
and presentation folders has received numerous requests for quotes from government purchasers. The company
is in the process of responding to these inquires. EPA was unable to identify any Federal government agencies
that have already purchased the HDPE products. EPA learned that the Ontario Ministry of Transportation in
Ontario, Canada, has purchased recovered-content HDPE binders and is pleased with their performance. The
contact stated that the HDPE binders were slightly more expensive than virgin material-content solid plastic
binders. According to another source, this price differential results from the slightly higher costs of recycled
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resin used in manufacturing binders. This same source stated that higher prices for HDPE binders can also
result from consumers' willingness to pay higher costs for items with recycled materials. However, this
assessment is not shared by the industry as a whole. Another manufacturer stated that there was no
difference in price between their recovered and virgin content HDPE binders. EPA also learned that the
school board of Broward County, Florida, has purchased recovered-content HDPE binders; the Missouri
Department of Conservation has purchased recovered-content PE binders; and the Recycling and Litter
Prevention Division of Fairfield County, Ohio, has purchased recovered-content PS clipboards.
f. Barriers to Purchasing
The slightly higher price of recovered-content solid plastic binders, clipboards, file folders, clip
portfolios, and presentation folders may be a purchasing barrier. Although manufacturers indicated that
their products were priced competitively to binders made of virgin materials, two users indicated that they
were more expensive. One of these users reported a price differential of 30 cents (Canadian) per binder,
making the recycled-content binder 8 percent more expensive than the binder made of virgin materials.
EPA was unable to determine if the higher price is due to regional differences, but one source indicated
that volume purchasing can make recycled-content binders less expensive than those made of virgin
materials.
g. Designation
EPA proposes to amend the existing designation of binders to include solid plastic binders
containing recovered plastic. EPA proposes to designate plastic clipboards, plastic file folders, plastic clip
portfolios, and plastic presentation folders containing recovered plastic. A final designation would not
preclude a procuring agency from purchasing these items manufactured from another material. It simply
requires that a procuring agency, when purchasing plastic binders, clipboards, file folders, clip portfolios,
and presentation folders, purchase these items made with recovered plastic when these items meet
applicable specifications and performance requirements.
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3.
Procurement Recommendations
a.
Recovered Materials Content
Solid plastic binders, clipboards, file folders, clip portfolios, and presentation folders made from
HDPE contain a minimum of 90 percent recovered HDPE, all of which is postconsumer. PE binders
contain 30 to 50 percent postconsumer PE, and PET binders contain 100 percent postconsumer PET. PS
clipboards contain 50 percent postconsumer PS. Clipboards made from an unspecified plastic from
recovered telephones and vacuum cleaners contain 15 percent postconsumer plastic. Binders and
clipboards made from recovered circuit boards consist of 80 percent of the unspecified recovered plastic.
Table 24 presents information provided by manufacturers of plastic binders, clipboards, file
folders, clip portfolios, and presentation folders on recovered content availability.
Table 24
Recovered Materials Content of
Plastic Binders, Clipboards, File Folders, Clip Portfolios, and Presentation Folders
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
HDPE
PE
Plastic (unspecified)
PS
PET
Company A: 100
Company B: 100
Company C: 90
Company D: 100
Company E: 50
Company F: 30
Company G: Unknown
Company H: 15
Company F: 50
Company D: 100
100
100
Unknown
100
Unknown
Unknown
80
Unknown
Unknown
100
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b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 25,
procuring agencies establish minimum content standards for use in purchasing plastic binders, clipboards,
file folders, clip portfolios, and presentation folders.
Table 25
Draft Recovered Materials Content Recommendations for
Plastic Binders, Clipboards, File Folders, Clip Portfolios, and Presentation Folders
Product
Solid plastic binders
Plastic clipboards
Plastic file folders
Plastic clip portfolios
Plastic presentation
folders
Material
HOPE
PE
PET
Misc. Plastics
HOPE
PS
Misc. Plastics
HOPE
HOPE
HOPE
Postconsumer
Content (%)
90
30-50
100
80
90
50
15
90
90
90
Total Recovered
Materials Content
90
30-50
100
80
90
50
15-80
90
90
90
Note: EPA's recommendations do not preclude a procuring agency from purchasing binders, clipboards, file folders, clip
portfolios, or presentation folders made from another material, such as paper. They simply require that procuring agencies,
when purchasing these items made from solid plastic, purchase them made with recovered plastics when these items meet
applicable specifications and performance requirements. For EPA's recommendations for purchasing pressboard binders and
paper file folders containing recovered materials, see table A-lc in the Paper Products RMAN (61 FR 26986, May 29, 1996).
See Table G-3 in RMAN I for EPA's recommendations for purchasing plastic-covered binders containing recovered materials.
c.
Specifications
EPA did not identify any specific specifications or standards regarding plastic binders, clipboards,
file folders, clip portfolios, and presentation folders.
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IX. MISCELLANEOUS PRODUCTS
A. Absorbents and Adsorbents
1. Item Description
Absorbents and adsorbents are used in a diverse number of environmental, industrial, agricultural,
medical, and scientific applications to retain liquids and gases. While absorbents and adsorbents are often
used in the same applications, they perform fundamentally different functions. Absorption is "the
incorporation of a substance throughout the body of the absorbing material," whereas adsorption is the
"gathering of substances over the surface of the adsorbing material." Since absorbent and adsorbent
products are used interchangeably in many applications, and are to almost universally called "absorbents,"
EPA has chosen to use the term sorbent(s) to describe all materials and products discussed in this section.
Sorbents are most often used to clean up industrial and environmental oil and solvent spills. They
are also used in wastewater treatment, odor control, food processing, septic system maintenance, resource
recovery, dust and erosion control, photography, hazardous waste remediation, precious metal recovery,
chemical processing, and leachate control of phosphates and nitrates from fertilizers. In addition, sorbents
are used in packaging materials, animal bedding, cat litter, protective clothing, gas masks, and personal
hygiene products. After reviewing the government procurement of sorbent products, EPA determined that
oil and solvent spill cleanup and animal bedding are some of the most common applications for sorbents.
These products are purchased with appropriated Federal funds and are commercially available with
recovered materials content. This summary, therefore, focuses on these types of sorbents.
Types of Sorbents
As shown in Table 26, sorbent products are manufactured from a variety of organic, inorganic, and
synthetic materials, or combinations thereof:
# Organic sorbents can be manufactured from virgin materials, but most commercially
available sorbents are made from organic materials recovered from municipal and
industrial solid waste streams.
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# Inorganic sorbents are generally mined virgin materials, such as perlite or vermiculite.
Most inorganic materials can also be recovered and used again through a laundering
process (see Section 2b, Technological Feasibility and Performance).
# Synthetic sorbents are made from either virgin synthetic materials or synthetics recovered
from the municipal and industrial solid waste streams.
Table 26
Sorbent Materials
Organics
Cork
Corn cobs and stalks
Cotton
Ground pecan shells
Paper and paperboard
Peat
Rice hulls
Straw
Wool
Wood
Yard trimmings
Inorganics
Clay
Diatomaceous earth
Perlite
Pumice
Salt
Sand
Sodium bicarbonate
Soil
Synthetics
Activated carbon
Polymers
Resins
Styrenes
Silica gel
Industry OverviewSorbents Used for Oil and Solvent Spills
According to industry estimates, the size of the sorbent products market for the types used to clean
up oil and solvent spills is $400 to $500 million per year, with an annual growth rate of 30 percent. EPA
was unable to determine the market share for each category of sorbent materials. Government agencies and
trade organizations all indicated, however, that products made from clays and polymers are the most
popular. According to EPA's research, of the three largest sorbent manufacturers, only one sells products
made from recovered materials.
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The sorbent spill cleanup industry can be divided into the following two categories:
# Environmental spills that generally occur as a result of liquid hydrocarbons, such as gas
or oil, being accidentally released into the natural environment. These spills can occur on
both land and water.
# Industrial spills that occur as a result of industrial or maintenance operations, involving
the use of hydrocarbons, chemicals, and other liquids.
One major producer estimates that the market share of sorbents for environmental spills and
industrial spills is 20 percent and 80 percent respectively. The industrial spill market can be subdivided into
two categories: routine spills, and leaks and emergency spill response, with the former representing about
90 percent of sales.
Industry OverviewSorbents Used for Animal Bedding
EPA was unable to determine the size of the animal bedding industry. For animal bedding used for
both large (e.g., cattle and horses) and small animals (e.g., pets and laboratory animals), however, one
manufacturer estimates that the industry is extremely largepossibly a$10to$ll billion per year industry
in the New England states alone. According to this same representative, animal bedding products are
always manufactured from organic materials. Sorbents used for animal bedding generally come in
particulate (e.g., sawdust) or pelletized form.
Animal bedding consists of primarily byproducts from lumber production. Lumber production
byproducts provide the material used in many absorbents. Saw mills that contribute their byproducts range
from large central producers to small operators. More than half of the saw mills in the industry are large
operations, however, due to the fact that most companies need to operate in greater volume to stay in
business.
Forms of Sorbent Products
Sorbents used in spill applications come in many different forms, which determine how they are
used and collected after use. Sorbent materials may be either continuous, particulate, or loose fill or bulk
form. Continuous materials are those that can be handled as a unit, such as pads, rolls, mops and booms.
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Participates are fine materials that must be spread over a spill area. These materials are often spread over
spills on land and then removed by scraping, raking, or using vacuum units. The loose fill or bulk form is
typified by wood puff balls rather than granular particulate. These materials are also spread over the spill
and then recovered by some mechanical means. A discussion of which form of sorbent is best for a
particular application is presented in more detail in Section 2b, "Technological Feasibility and
Performance," under the subheading, Criteria for Choosing Sorbent Materials.
2. Rationale for Designation
EPA believes that sorbents used for oil/solvent cleanups and animal bedding containing recovered
materials meet the statutory criteria for selecting items for designation.
a. Impact on Solid Waste
MSW
Sorbents are currently being made from mixed office paper, newspaper, paperboard, plastic,
rubber, textiles, wood, and yard trimmings recovered from the MSW stream. EPA was unable to determine
the total amount of recovered materials being diverted from the MSW stream into the production of sorbent
products. One company estimates that it diverts about 2,400 pounds of postconsumer newspapers from the
MSW stream each year. Appendix I of this document discusses the generation and recovery of materials in
MSW currently used to manufacture sorbent products.
Industrial Waste
Sorbent products also are being manufactured from waste recovered from industrial processes,
including the manufacture of lumber, paper, and textiles. Although EPA was unable to determine the total
amount of waste generated and recovered from these industries, the following are examples of how much of
these wastes are being diverted for the manufacture of other products, including sorbents:
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# Lumber Mill WasteAccording to one lumber producer, and as previously noted,
recovered sawdust is commonly used for sorbent products, particularly for animal bedding.
If the recovered sawdust were not used in sorbent products, however, it would generally be
burned or disposed of in landfills. The contact admitted, however, that it is rare for wood
waste to be disposed of in landfills. Another company estimates it diverts between 600 and
1,000 tons of wood waste from the lumber industry each year.
# Paper Mill WasteOne company stated that it diverts approximately 8,000 tons of fines
recovered from paper mill sludge each year. Another company indicated it also diverts an
estimated 8,000 pounds of sludge fines from the pulp and paper industry each year.
# Textile WasteA representative of the Textile Fibers and By-Products Association said
the textile industry has been diverting textile fines from sludges into the production of
sorbent products for years. In fact, only some textile waste is being disposed of in landfills.
C&D Waste
Some C&D wastes are used for sorbents. Gypsum (calcium sulfate) from construction wallboard trimmings
is a component of C&D wastes, although the sorbent manufactured from this waste currently is available only from
one regional company in Michigan.
A comprehensive list of C&D debris recovery programs is not available but published reports indicate that
programs exist in all parts of the United States and that it is technologically and economically feasible to recover wood
for use in products and as industrial boiler fuel, landscaping and hydraulic mulch, sludge bulking media, and animal
bedding. According to one article, C&D wood waste generation was about 33.2 million tons in 1996, of which 14.1
million tons were potentially available for recovery; and 19.1 million tons were already recovered, combusted, or were
not usable (McKeever, "Wood Residual Quantities in the United States," BioCycle, January 1998).
b. Technological Feasibility and Performance
Criteria for Choosing Sorbent Products Used for Spills
The type of sorbents used for spill applications generally depends on the type of substance being sorbed,
where the spill occurs, and worker health and safety issues. The type of material(s) used to manufacture sorbents is
very important to consider when choosing a sorbent product. Sorbents made from materials that are
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incompatible with the substance being sorbed can potentially disintegrate, create a fire hazard, or pose
problems for worker safety. Organic sorbents, for example, are incompatible with and should not be used
to clean up substances such as inorganic acids, caustics, or hydrazines and hydrazides. Sorbents made from
organic materials can, however, be used to clean up most oils and fuels (e.g. mineral oil, gasoline, and
hydraulic fluid), coolants (e.g., antifreeze), transformer oils (including polychlorinated biphenyls), paints
(e.g., latex based, lacquers, and thinner), alcohols, solvents, toxins (e.g., cyanides, sulfamides, and battery
acid), and insecticides and herbicides.
According to one manufacturer, using products made with recovered materials can pose some
potential problems. Postconsumer wastes are often contaminated with residuals that are incompatible with
aggressive materials (e.g., highly flammable jet fuels). The contact also indicated that products used to
absorb some types of jet fuel need to have specific nonstatic characteristics.
Where the spill occurs will also affect the type of sorbent that is used. To clean up spills on water,
for example, the sorbent used should be hydrophobic, or water resistant, so it will float on water. Sorbents
that are not hydrophobic (i.e., hydrophillic) are generally not used for spills on water, as they will sink,
causing problems when removing the product from the waterbody. Thus, for spills on water,
polypropyleneand a small number of organic sorbent products that are treated to make them
hydrophobicare the most commonly used. According to the World Catalog of Oil Spill Response
Products, particulate and loose sorbents are also not recommended for use on open water because they too
"may absorb water and sink or be lost to recovery because of winds, waves, and currents."
End users also must consider how a sorbent product may affect the environment, particularly when
cleaning up spills in environmentally sensitive areas (e.g., salt marshes and wildlife refuges). According to
an EPA contractor, a spill response team must choose a product that will not negatively impact wildlife or
the environment. In costal areas where sea turtles are present, for example, contractors will generally not
use sorbents made from plastics. Sorbents made from plastics can resemble jellyfish, a sea turtle's main
food source. If ingested by sea turtles, plastics can cause severe digestive problems or even death.
Entanglement is also an issue when choosing a sorbent product for areas where sea turtles, manatees, or
otters may be present. In these areas, sorbent snares (i.e., sorbents made from thin strands of polypropylene
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fibers) should not be used. In such cases, the contractor suggests that organic particulate sorbents (i.e.,
sweeps) could be used to prevent entanglement. The contact suggested that in cases where wildlife and
habitat protection are an issue, organic sorbents would work best.
Worker health and safety issues also can play a role in the selection of sorbent products. A contact
from the U.S. Army Corps of Engineers, for example, suggested that sorbent mats, pads, and rolls (made
from virgin PP) are the products best suited for the routine spills that occur during machine maintenance
operations. These products are easier to handle because they lie flat and keep walking surfaces safe for
workers. Particulate sorbent materials, on the other hand, are difficult to clean up and may cause workers to
slip. While sorbent mats also are available with recovered material content, the contact suggests that,
because they are thicker than mats made from virgin materials, they may compromise the comfort and
safety of workers' walking surfaces.
According to a representative of the Coalition for Organic Absorbent Producers (COAP), using
clay and diatomaceous earth products can be detrimental to worker health. These products produce airborne
crystalline silica, which has been linked to silicosis, a progressive and sometimes fatal lung disease, and
cancer. In fact, in some states, such as California, manufacturers of clay sorbent products are now required
by law to put warning labels on their products. According to the COAP representative, the Occupational
Safety and Health Administration (OSHA) regulates worker exposure levels to silica dust and these
regulations are currently being revisited. OSHA has a Permissible Exposure Limit, which is the maximum
amount of airborne crystalline silica that an employee may be exposed to during a work shift. OSHA is still
revising the ruling on the regulation of these products.
Pollution Prevention Considerations
Under certain conditions, some sorbent materials can be reused or recycled. Some manufacturers of
synthetic sorbents, for example, market products that can be reused up to 100 times. Under pressure, synthetic
sorbents will release the sorbed substance, allowing it to be recovered and the sorbent to be reused.
Manufacturers of organic sorbents, on the other hand, claim their sorbents can be incinerated for energy recovery
and that this process leaves very little ash residue. In addition, clay sorbents can be put through a "laundering"
process through which the sorbed substance and clay can both be reclaimed for reuse.
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Sorbent Products Made from Recovered Materials
According to industry representatives, it is technically difficult and costly to manufacture melt-
blown sorbent mats, pads, and rolls from recovered postconsumer PP because the material must be first
processed into pellets and then "fiberized." In addition, some industry representatives believe that recovered
PP does not produce a fine enough fiber to meet the same performance standards as those for a sorbent
made from virgin PP. Contamination of recovered materials may also limit their use for cleaning up acidic
or caustic materials, because trace elements of certain contaminates could potentially pose a fire hazards.
Contaminates can also damage machinery designed to manufacturer products from virgin materials.
Sorbents also can be manufactured from other types of recovered polymers. For example, one
company distributes two types of sorbent mats made from recovered textile waste, including wool, cotton,
and PP fibers. These fibers can be woven, needle punched, or layered and subjected to heat to produce
sorbent mats. These products can be used effectively for most spill applications, except when the spilled
substance is of an unknown origin or known to be caustic or acidic. In such cases, using sorbents made
from recovered textile waste could pose a problem because of their organic content (e.g., wood and cotton).
In addition, mixtures of various textile fibers do not always provide for consistent performance and
generally do not have the same affinity for oil as virgin PP. According to a representative of the company,
mats made from recovered materials are recommended for use where small amounts of oil need to be
cleaned up, whereas PP works best on heavy drips and splashes.
c. Availability and Competition
Manufacturers and distributors of recovered content sorbents are located throughout the United
States, supplying both domestic and international markets. GSA currently has supply contracts with several
companies that manufacture or distribute recovered content sorbents. One manufacturer suggested,
however, that there are fewer suppliers of sorbents made from organic (i.e., recovered) materials.
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d. Economic Feasibility
Manufacturers of recovered content sorbent products claim that their products are cost-competitive
with virgin counterparts. While this seems to be true in most cases, NFS prefers clay sorbents because they
are the least expensive sorbents available. In addition, a U.S. Army Corps of Engineers representative
claims that the recovered content product it uses for emergency spills is very expensive. The cost of
transporting sorbent products should also be figured into the cost of sorbent products. Sorbents made from
clay tend to cost more to ship than those made from synthetics or organics because clay weighs more. The
cost of disposal can also have an impact on the type of sorbent an end user chooses when dealing with
hazardous or potentially hazardous waste spills. The cost of recycling, reusing, incinerating, or disposing of
sorbents considered to be hazardous can vary from state to state. An EPA contractor, for example,
explained that it cost $400 per ton to dispose of clay sorbents in a hazardous waste landfill, whereas it only
costs $65 per drum to treat (launder) the clay, which can then be reused.
e. Government Purchasing
Government agencies procure sorbent products through GSA's stock contracts and the Multiple
Award Federal Supply Schedule. GSA stock contractors must meet GSA's Commercial Item Description
specification for Absorbent Materials, Oil and Water (For Floors and Decks). Thus, when purchasing
sorbent products from GSA, government agencies are limited to purchasing sorbents made from silicate
minerals. When ordering sorbent products directly from a multiple award contractor, however, there are no
procurement specifications. Instead, government agencies rely on the manufacturers specifications, and a
full range of sorbent products (e.g., organic, inorganic, and synthetic) are available for purchase.
A number of Federal and state agencies purchase a variety of sorbent products, as listed below.
Sorbents Used for Spills
# The U.S. Coast Guard's Marine Safety and Environmental Protection Division
typically uses PP sorbents to clean up spills on water, and paper or cellulosic sorbents to
clean up spills on land (i.e., spills that occur during maintenance of vehicles and boats).
The contact did not know, however, if the absorbents made from paper are made from
recovered materials.
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# NFS purchases a variety of sorbent products used to clean up routine and emergency spills
on water, and for spills that occur during fleet (i.e., vehicles and boats) maintenance.
Although they do not track the purchase of absorbent products, a contact for the NFS
claims they spend well over $10,000 on sorbent products each year. EPA does not
purchase sorbent product. Emergency spill response tasks are handled by EPA contractors,
who purchase sorbents for their cleanup activities. One such contractor claims that they
mainly use products made from virgin PP . These products come in several different forms,
including pads, blankets, sweeps, and 5- and 8-inch booms. These products are used for
"light" oils only. For heavy or viscose oils (e.g., #6, bunker-c, and crude oils), the
contractor uses a product called OilSnare which is made from a recovered PP ribbon
material. According to the manufacturer, this product is made from materials recovered
from a company that manufactures carpet backing. After the backing has been cut to size,
the seconds are sold to companies that manufacture products such as OilSnare. The
seconds are either first run scraps or reground material. This recovered PP ribbon material
can also come from manufacturing seconds from plastic packaging companies.
# The U.S. Army Corps of Engineers at Dworshak Dam in Idaho are using Sea Sweep, a
product made from 100 percent recovered wood waste from the lumber industry, for
emergency spill response activities. The supplier of wood waste for Sea Sweep however,
said that fiber would not necessarily be disposed of in landfills because the company would
simply sell the wood waste as animal bedding.
Sorbents Used for Animal Bedding
# The National Institutes of Health (NIH) purchases more than $10,000 of animal bedding
a year, including products made from recovered paper.
# The U.S. Department of Energy and one of its contractors purchase a sorbent product
made from recovered paper pulp waste. The contractor recently spent more than $100,000
on supplies of the sorbent.
f. Barriers to Purchasing
EPA identified some barriers for procurement of recovered content sorbent products, including
government specifications that in some way preclude the use of recovered materials and misconceptions
regarding the effectiveness of sorbents made from recovered materials.
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A significant barrier appears to be the fact that GSA's stock item specification for sorbents
precludes procurement of sorbent products that are not made from silicate minerals. In a November 8,
1995, letter the commissioner of GSA stated:
At this time, a stock contract for organic sorbents is not practicable. Such procurement
would require a technical description covering the varying needs of the Government.
Because the industry is still evolving and there are numerous products lacking
standardization, it is not feasible to draft and adequate technical document. The Multiple
Award Schedule method of procurement is generally used in these circumstances.
According to recent conversations with GSA representatives, it is apparent that the specification
will not be changed in the near future. One representative claims that because there are so many different
types of sorbent products now available, it would be impossible to stock the warehouses with hundreds of
different types of products. Another GSA representative stated that sorbent products are simply "too bulky"
to consider stocking different kinds of sorbent products and that it did not make "good economic sense" to
do so. This contact also suggested that the customers (i.e., government agencies) have grown to expect
mineral sorbents to be available through GSA and that there is no indication from these customers that they
want other products made available. If clay sorbents are discontinued as a stock item, as another contact
stated, a variety of sorbent products would be available through a multiple award schedule.
Also noted above, NIH's specification for Laboratory Animal Bedding, Softwood, could be a
possible barrier for procurement of recovered content animal bedding, although NIH does not believe that
this specification prevents purchase of animal bedding from recovered materials.
Barriers also stem from attitudes reflecting preconceived judgements regarding the performance of
recovered content products. Users prefer to use products they are familiar with and most are used to using
sorbents made from PP.
g. Designation
In CPG III, EPA is proposing to designate sorbents containing recovered materials for use in oil
and solvent clean-ups and as animal bedding. A final designation would not preclude a procuring agency
from purchasing sorbents made from other materials.
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3.
Procurement Recommendations
a.
Recovered Materials Content
EPA contacted 14 companies and identified more than 40 others that manufacture sorbent products
from recovered materials. Information obtained from these manufacturers is displayed in Table 27.
Table 27
Recovered Materials Content of Sorbents
Material
Paper
Textiles
Postconsumer Content (%)
Company A: Unknown
Company B: 10
Company C: 100
Company D: 95-100
Company E: 30
Company F: 10
Company G: 100
Company H: 90-98
Company I: 100
Company J: 95
Company K: 100
Company L: 95
Company M: 100
Company N: 100
Company O: 100
Company P: 98
Company Q: 100
Company R: 100
Company S: 100
Company T: 95-100
Company U: 100
Company V:
Company W: 95-100
Company X:
Company Y: 100
Company Z: 100
Total Recovered
Materials Content (%)
Unknown
100
100
95-100
100
100
100
90-98
100
95
100
100
100
100
100
98
100
100
100
95-100
100
95
95-100
65-100
100
100
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Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
PP
Gypsum
Wood
Other Organics
Multi-material
PVC
Company AA: Unknown
Company BB: Unknown
Company CC: Unknown
Company DD: 100
Company EE:
Company FF:
Companies GG through TT:
Company UU:
Company VV:
Company WW:
Company XX:
Company YY: 50
100
25
100
100
100
Unknown
100
Unspecified
100 (peanut hulls)
100 (corn stover)
100 (polymer and cellulose
fiber)
50
Sorbents Used in Spill Applications
Representatives from the Spill Control Association of America (SCAA) and a particular supplier
of sorbent products estimate that between 50 to 80 percent of the sorbent products currently available are
made from some type of recovered material. However, based on the fact that the two largest manufacturers
of sorbents do not manufacture their products from recovered materials, this range appears high.
Sorbents used in spill applications are manufactured from a variety of recovered materials,
including 100 percent postconsumer newspapers, tires, yard trimmings, and C&D debris, such as wood
waste and gypsum. Sorbent products also are made with 100 percent recovered material from the plastics,
textile, lumber, and pulp and paper industries. Waste from these processes (usually the unusable short
fibers or fines) are sold to companies producing sorbents. These materials are processed and made into
various types and forms of sorbent products. The following are just a few of the examples of sorbent
products EPA identified that contain 100 percent recovered materials:
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# A sorbent manufacturer in Norwalk, Ohio, produces sorbent socks from 100 percent
recovered materials from the textile industry. The company purchases textile trimmings
(approximately 95 percent polyester and 5 percent cotton fiber dust) from textile
manufacturers.
# A company in Everett, Washington, manufactures a product made from 100 percent
recovered materials70 percent from fines recovered from paper manufacturing and 30
percent newspapers recovered from the municipal solid waste stream. The product is sold
in particulate form.
# A manufacturer in Denver, Colorado, makes a 100 percent recovered content sorbent from
sawdust or "pin-chips" recovered from the lumber industry. The sawdust is subject to a
heating processes that removes residual water and natural oils, making the wood fiber
particularly sorbent. The product is sold in particulate form.
# A manufacturer and distributor in Tipton, Pennsylvania, sells a sorbent sock product made
from 100 percent recovered materials from textile manufacturing waste. While the
percentage of the types of fibers in this product may vary, the material is generally a
mixture of wool, cotton, and polypropylene fiber.
Due to the wide range of recovered materials used to manufacture sorbents for oil and solvent
spills, EPA was unable to identify which type of recovered content sorbent product is most common.
Sorbents Used for Animal Bedding
According to one manufacturer, nearly all animal bedding is made from recovered wood or other
cellulosic fiber. For large animals, the contact estimates that straw and other organic wastes recovered from
agricultural production comprises between 40 to 50 percent of the market, with the other 50 to 60 percent
being manufactured from cellulose fiber sources, such as recovered wood waste, paper and other paper
products. The contact also estimates that 99 percent of the animal bedding used for pets and laboratory
animals is made from wood residue recovered from the lumber industry. The other 1 percent is made from a
variety of recovered organic materials, including rice hulls, ground pecan shells, corn stalks, and straw.
Animal bedding for pets and laboratory animals is also made from materials recovered from the MSW
stream, such as paper, newspaper, kraft paper, and corrugated boxes.
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b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 28,
procuring agencies establish minimum content standards for use in purchasing absorbents and adsorbents.
Table 28
Draft Recovered Materials Content Recommendations
for Sorbents
Material
Paper
Textiles
Plastics
Wood
Other Organics/Multi-Materials
Postconsumer Content (%)
90 - 100
95 - 100
~
~
~
Total Recovered
Materials Content (%)
100
95 - 100
25 - 100
100
100
Notes: "Wood" includes materials such as sawdust and lumber mill trimmings. Examples of other organics include, but are not
limited to, peanut hulls and corn stover. An example of multi-material sorbents would include, but not be limited to, a polymer
and cellulose fiber combination.
c.
Specifications
EPA identified two Federal specifications containing language that precludes the use of organic
sorbents in applications where the type of sorbent material is not an issue. GSA's specification for
Absorbent Material, Oil and Water (For Floors and Decks), for example, states that "the absorbent
material shall consist of a uniform mixture of minerals of the silicate type."
According to a commodity management specialist with GSA's Chemicals and Paint Division,
GSA's financial analysts rejected a recommendation that clay sorbents be discontinued from stock and
consolidated with those sorbents on the multiple awards schedule. The analysts cited the more than $1
million a year in sales as a sign that GSA should still make the item available as a stock item. The contact
believes, however, that the demand for this stock item is diminishing due to increased purchases from the
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multiple awards schedule and directly from manufacturers. When sorbents are purchased through the
multiple awards schedule or directly from manufacturers, agencies are not required to use the GSA
purchasing specification for Absorbent Material, Oil and Water (For Floors and Decks).
The NIH specification for Laboratory Animal Bedding, Softwood, precludes the use of recovered
material. The specification states that sorbents used for "contact bedding for animals ... shall be from
unused white pine (or related species of low resin soft pine) lumber."
ASTM has test methods for both absorbents and adsorbents used to remove oils and other
compatible fluids from water. These are Standard Methods of Testing Sorbent Performance of Absorbents
(F716-82) and Standard Method of Testing Sorbent Performance of Adsorbents (F716-81). Neither of
them mention any exceptions or differences for testing of sorbents made from recovered materials, however.
The Federal government does not regulate the use of sorbent materials in spill cleanup activities.
According to Title 40 of CFR Part 300, National Oil and Hazardous Substances Pollution Contingency
Plan, Proposed Rule:
EPA believes the use of sorbents does not create deleterious effects to the environment
because these materials are essentially inert and insoluble in water and because the basic
components of sorbents are nontoxic.
EPA provides some oversight for the use of inorganic particulate sorbents and sorbents mixed with
chemicals to improve sorption. In such cases, EPA reviews company product tests to determine that the
product is not deleterious to the environment. If EPA finds that the product may not perform appropriately
for a specific application (e.g., on open water), it will send a letter the company expressing these concerns.
While EPA does not regulate sorbent use, the Agency does regulate the disposal of sorbents when
they are determined to be hazardous waste after they are used. According to a contact at EPA, regulations
regarding the disposal of used sorbent products are listed in the 40 CFR Part 300, Subpart J. Sorbents that
are determined to be hazardous waste must be reused, recycled, incinerated for waste-to-energy, or disposed
of in a hazardous waste landfill.
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B. Industrial Drums
1. Item Description
An industrial drum is a cylindrical container used for shipping and storing liquid or solid materials.
They are typically manufactured in 5-, 15-, 30-, and 55-gallon sizes, although other sizes are available.
Containers under 7 gallons are known throughout the industry as pails.
Industrial drums are manufactured from a variety of materials, including steel, plastic, and pressed
fiberboard. The Steel Shipping Container Institute estimates that 35 million new steel drums were
manufactured in 1995 and, according to the Plastic Drum Institute (PDI), between 12 and 15 million plastic
drums are manufactured annually. The International Fiber Drum Institute was unable to provide an
estimate for the number of fiber drums manufactured.
Drums are manufactured from different materials, each of which provides slightly different
performance or cost benefits. Fiber drums, for example, are the lightest and least expensive, but are not as
durable as steel or plastic drums. Plastic drums are more durable than fiber drums and lighter and less
expensive than steel drums, but are not traditionally used for certain materials, such as petroleum products,
because of the costs involved with treating the plastic to prevent adverse reactions. Steel drums are used
more widely than plastic or fiber drums but are heavier and dent and rust with use.
While drums can be used to ship a very large variety of materials, most drums are used to ship
chemical and petroleum products. A 1996 Steel Shipping Container Institute (SSCI) study determined that
39 percent of drums are used for chemicals, 15 percent for petroleum products, 11 percent for paints and
coatings, 6 percent for food products, and 29 percent for other unspecified uses. The study also estimated
that over 40 percent of drums (in the 30- to 55-gallon range) are used for transporting and storing
hazardous materials. SSCI estimates that up to 70 percent of the drums purchased for use by the Federal
government may be used for hazardous materials, based on the nature of the products typically stored and
transported by the Federal government.
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Drums can be divided into two categories: closed head and open head. Closed head drums have a
permanently affixed lid with two scalable openings on top, a 2-inch and a 3/4-inch opening. They are
usually used to hold oils, solvents, and flowable resins, which can be pumped in or out through the openings
in the top of the drum. Open head drums have a completely removable lid and are typically used to hold
more viscous materials than closed head drums, such as petrochemicals and adhesives, or to contain dry
goods.
Drums used to transport or store hazardous materials are rated by one of three markings (X, Y, or
Z), which correspond with DOT hazardous material packing group classifications. DOT classifies
regulated materials into three packing groups Type I, II, and III. The Type I packing group includes the
most hazardous materials, and Type III includes the least hazardous.
2. Rationale for Designation
EPA believes that industrial drums containing recovered materials meet the statutory criteria for
selecting items for designation.
a. Impact on Solid Waste
Industrial drums are made with recovered and postconsumer steel, HOPE, and paperboard.
Appendix I of this document discusses the generation and recovery of these materials in MSW.
b. Technological Feasibility and Performance
DOT classifies regulated materials into three packing groups: Type I, II, and III. The Type I
packing group includes the most hazardous materials, and Type III includes the least hazardous. DOT
specifies drum performance criteria for Type I, II, and III materials based on drop, stacking, hydrostatic,
leak, and vibration tests. Drums that meet DOT hazardous materials packing group specifications are
identified by an X, Y, or Z. Drums with an X rating are capable of passing the most stringent DOT
standards and can be used to transport and store materials from all three packing groups (Type I, II, and
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III). Drums with a Y rating can be used for Type II and Type III packing groups, while drums with a Z
rating can be used only for Type III packing group materials. Drums rated X, Y, or Z can also be used for
nonhazardous materials. Table 29 provides a listing of drum packaging groups.
Table 29
DOT Drum Packaging Groups
DOT Drum Rating
X
Y
Z
Unrated
Approved for:
DOT packing groups Type I,
materials
DOT packing groups Type II
materials
DOT packing group Type III
II, and III and all nonhazardous
and III and all nonhazardous
and all nonhazardous materials
All nonhazardous materials
According to one manufacturer of both virgin and recovered materials content drums, drums
manufactured from recovered materials perform as well as drums manufactured from virgin materials for
some, but not all, applications. There are no performance concerns with drums manufactured with
recovered content steel because all steel drums contain at least 25 percent postconsumer recovered
materials. Recovered content fiber and plastic drums, however, have more limited applications than their
virgin counterparts. One manufacturer of virgin and recovered content fiber drums explained that recovered
content fiber drums perform differently than virgin fiber drums. They are stronger in compression tests but
weaker in impact tests. As a result, the manufacturer does not recommend using recovered content fiber
drums for liquids or for loads over 60 kg (132.6 Ibs.). He also explained that virgin and recovered content
open-head fiber drums do not meet DOT performance criteria for Type I, II, or III liquid hazardous
materials and can not be used to store or transport them.
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PDI claims that there are no performance issues associated with recovered content plastic drums.
DOT, however, currently requires virgin plastic for drums that will be used to transport or store hazardous
materials because plastic absorbs small quantities of some materials. DOT is concerned that if a drum
made from recovered plastic is used for transporting hazardous materials, the hazardous materials may
react with materials previously absorbed by the plastic.
At least one manufacturer produces a multilayer plastic drum with a recovered content middle
layer that is surrounded by two virgin plastic layers. The recovered plastic is obtained from postconsumer
industrial drums. DOT granted the company an exemption under 49 CFR 107.107 that allows the
manufacturer's drums to be used for transporting Type II or III packing group materials. The exemption
does not allow the drums to be used to transport the more hazardous Type I materials.
c. Availability and Competition
According to SSCI, there are 26 new steel drum manufacturers producing 34.6 million drums and
86.5 million pails annually. PDI reports that there are at least 10 manufacturers of plastic drums
manufacturing 12 to 15 million new drums annually. According to the Fiber Drum Institute, there are
approximately eight fiber drum manufacturers producing an unknown quantity of drums. In addition,
according to the Association of Container Reconditioners (ACR), there are over 100 drum reconditioners.
EPA identified two plastic drum manufacturers and one fiber drum manufacturer producing
recovered content drums. The manufacturers declined to identify the number of drums produced, citing
reasons of confidentiality. The recovered content fiber drum manufacturer stated that approximately half of
the drums they manufacture contain recovered materials. One of the recovered content plastic drum
manufacturers stated that they have the capacity to make as many as 400,000 recovered content drums a
year.
Every steel drum manufacturer produces recovered content steel drums.
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d. Economic Feasibility
According to several plastic and fiber drum manufacturers, plastic and fiber drums made from
recovered materials are generally less expensive than their virgin counterparts.
The ACR explained that reconditioned drums are approximately one-third less expensive than new
drums.
e. Government Purchasing
A 1994 survey of 28 Department of Energy (DOE) facilities revealed that the facilities procured
77,731 drums for waste management, 85 percent of which were steel. The drums were generally procured
by contractors and not directly by DOE.
Although EPA believes that DOD procures significant quantities of industrial drums, the Agency
was unable to confirm quantities because there is not a central office that tracks drum purchases. In fact,
EPA's research found that most drums are purchased in quantities small enough for individual facilities to
purchase them with government credit cards.
Steel drums are reused routinely within DOD, but EPA was unable to determine to what extent
they are refurbished. Any DOD drum that has not contained hazardous materials can be triple rinsed and
reused. In addition, the Defense Reutilization Marketing Office (DRMO), part of the Defense Logistics
Agency (DLA) tasked with redistributing excess materials among government facilities for reuse, frequently
provides triple-rinsed steel drums free of charge to defense facilities that need them. DRMO stockpiles
excess drums when consolidating nonhazardous materials from drums shipped to DRMO for redistribution.
The drums are triple rinsed and made available to any facility that requests them.
A Steel Shipping Container representative suggested that the Government Printing Office (GPO)
and the Bureau of Printing and Engraving both purchase large quantities of ink in 55-gallon drums. EPA
was unable to contact representatives from these government agencies to determine if their specifications
include the means by which the inks are delivered.
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f. Barriers to Purchasing
According to PDI, one of the biggest barriers to increasing Federal procurement of drums
containing recovered materials is DOT's prohibition against the use of recovered content plastic drums
when transporting or storing hazardous materials. Although at least one plastic drum manufacturer has
successfully obtained a DOT exemption allowing it to use recovered plastic, many manufacturers are
reluctant to pursue exemptions because of the time and expense involved and concerns about negative
customer reactions.
Plastic drum manufacturers are also concerned that if EPA designates recovered content drums and
DOT does not change its requirements, government purchasing agents could decide to purchase steel drums
to avoid having to order different drums for different applications.
g. Designation
In CPG III, EPA is proposing to designate industrial drums containing recovered steel, plastic, or
paper. A final designation would not preclude a procuring agency from purchasing industrial drums
manufactured from another material. It simply requires that a procuring agency, when purchasing industrial
drums made from steel, plastic, or pressed fiberboard, purchase these items made with recovered materials
when these items meet applicable specifications and performance requirements.
3. Procurement Recommendations
a. Recovered Materials Content
Steel, plastic, and fiber drums are manufactured with recovered material content. All steel drums
contain at least 25 percent recovered materials due to the nature of the steel manufacturing process. Almost
all of the sheet steel used to manufacture drums is produced in blast oxygen furnaces, which produce steel
with 25 to 28 percent postconsumer content. Steel produced in electric arc furnaces contains close to 100
percent postconsumer recovered materials, but is not used to produce drums.
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DOE is using recovered radioactive steel from decommissioned DOE facilities to manufacture steel
drums for containing low-level radioactive and hazardous wastes. Recovering radioactive steel to
manufacture industrial drums reduces the volume of radioactive steel that DOE must dispose of by reducing
the need to procure additional drums or other containers to encase the radioactive steel. According to the
Trade Association of Radioactive Metals, it is not economically feasible to decontaminate the steel
recovered from DOE facilities for unrestricted use, but it does make economic sense to use the steel
available onsite or from other DOE facilities.
Plastic drums are manufactured with up to 100 percent postconsumer HOPE. At least one
manufacturer is also producing a multilayer drum that includes a 100 percent postconsumer recovered
HOPE layer sandwiched between two virgin layers with a total recovered material content of 30 to 35
percent. Due to differences in molecular weight, the recovered HOPE used in plastic drums is obtained
from postconsumer plastic drums collected by the manufacturer and not from curbside recycling programs.
The HOPE available from curbside collection programs mainly consists of discarded milk jugs, which use a
relatively porous, lower molecular weight plastic than is used in industrial drums.
Fiber drums are manufactured from postconsumer recovered corrugated boxes and other sources of
paperboard, and contain up to 100 percent postconsumer recovered materials. Many fiber drums have steel
rims around the top and bottom to help maintain drum integrity. Some fiber drums also contain an interior
plastic lining to make the drum waterproof. According to one manufacturer, the plastic liners do not contain
recovered materials, and many manufacturers have stopped making plastic lined drums due to competition
from the plastic drum industry.
Drum Reconditioning and Reuse
In addition to recycled content, steel, plastic, and fiber drums can also be reused within a controlled
distribution chain, or they can be reconditioned and reused. If an undamaged drum remains in a shipper's
control, it can be reused to ship or store the same material. Most shippers do not clean the drums before
refilling them because the same material is being transported and there is little risk of contamination.
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Damaged or discarded drums can be reconditioned and reused. There are over 100 drum
reconditioners in the United States. According to ACR, between 35 and 40 million steel drums and
approximately 3 million plastic drums are reconditioned each year. A small number of fiber drums are
reconditioned, but because fiber drums are less likely to be reconditioned, ACR does not track them.
Plastic and steel drums are reconditioned in three basic stages: the drum is thoroughly cleaned,
worn gaskets and seals are replaced, and the drum is tested for leaks. Plastic drums are generally triple
rinsed with high pressure neutralizing detergents. Steel drums are typically cleaned by exposing them to an
intense flame that burns away any residue from the previous shipment. Steel drums undergo two additional
steps to remove the dents and dings from normal use and to repaint the drum to help protect it from the
elements.
An ACR report, The Energy Requirements of Steel Drum Manufacturing and Reconditioning,
concludes that it takes approximately 10 times as much energy to manufacture a steel drum as it does to
recondition it. ACR also estimates that it takes six times more energy to recycle than to recondition a steel
drum.
According to a fiber drum manufacturer, fiber drums can be reconditioned by cutting a damaged
drum to remove the damaged area. For example, if a fiber drum is damaged, the steel rim can be removed;
the drum can then be cut in half, below the damage, parallel with the bottom of the drum; the steel rim can
be replaced; and the newly refurbished, smaller-volume drum can be reused.
Table 30 displays recovered content information on industrial drums made by manufacturers
contacted by EPA.
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Table 30
Recovered Materials Content of Industrial Drums
Material
Plastic
Steel
Fiber
Postconsumer Content (%)
Company A: 100
Company B: Unknown
Company C: Unknown
Company D: 100
Total Recovered
Materials Content (%)
100
30-35
25-100
100
b. Preference Program
EPA recommends that, based on the recovered content levels shown in Table 31, procuring
agencies establish minimum content standards for use in purchasing steel, plastic, or fiber industrial drums
containing recovered materials. EPA further recommends that procuring agencies reuse drums, purchase or
use reconditioned drums, or procure drum reconditioning services, whenever feasible.
Table 31
Draft Recovered Materials Content Recommendations for
Industrial Drums
Product
Steel drums
Plastic drums
Fiber drums
Material
Steel
HOPE
Paper
Postconsumer
Content (%)
16
30-100
100
Total Recovered Materials
Content (%)
20-30
30-100
100
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c. Specifications
The International Confederation of Drum Reconditioners, PDI, and several other plastic trade
associations are working with DOT and the United Nations (UN) to demonstrate that there are no adverse
performance issues associated with the use of recovered plastics in hazardous materials packaging. In July
1996, the UN Subcommittee of Experts on the Transport of Dangerous Goods passed a proposal to allow
the use of recovered plastics in plastic drums that will be used to transport or store hazardous materials.
The proposal was also passed at the full UN Committee of Experts meeting in December 1996 and will be
published in the 10th revised edition of the UN's Recommendations on the Transport of Dangerous
Goods.
The UN recommendations state:
Recycled plastics material means material recovered from used industrial packagings that
has been cleaned and prepared for processing into new packagings. The specific properties
of the recycled material used for production of new packagings should be assured and
documented regularly as part of a quality assurance programme recognized by the
competent authority. The quality assurance programme should include a record of proper
pre-sorting and verification that each batch or recycled plastics materials has the proper
melt flow rate, density, and tensile yield strength, consistent with that of the design type
manufactured from such recycled material. This necessarily includes knowledge about the
packaging material from which the recycled plastics have been derived, as well as
awareness of the prior contents of those packagings if those prior contents might reduce
the capability of new packagings produced using that material. . .Packagings
manufactured with such recycled plastics material should be marked "REC."
DOT will await formal publication of the UN recommendations before beginning an official
evaluation. Based on past precedent, it is likely that DOT will approve the UN recommendations for the
United States.1 DOT tentatively anticipates a proposed rulemaking regarding the use of recovered plastics
in industrial drums in 1998. After reviewing public comments, DOT anticipates the modified regulations
1 On December 19, 1990, DOT adopted UN standards for the packaging and shipping of hazardous
materials. DOT modified its regulations again on December 29, 1994, to reflect additional changes in UN
specifications. It can take DOT 6 months to 5 years to adopt UN recommendations.
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going into effect in January 1999. Until that time, DOT will continue to make exemptions (as described in
49 CFR 107.107) for manufacturers who demonstrate that their use of recovered plastics does not present a
cross contamination concern. As of March 30, 1998, the UN recommendations were still under
consideration by DOT, but not yet adopted.
The National Motor Freight Traffic Association also develops performance specifications for
containers that will be used to transport goods via truck. Their specifications do not specify materials and
do not prohibit the use of recovered materials.
C. Awards and Plaques
1. Item Description
EPA conducted preliminary research to ascertain the supply of, and government demand for
awards and plaques made from recovered materials. To this end, EPA contacted the Promotional Products
Association (PPA), four manufacturers of recovered content products, and four Federal agencies. For the
purpose of this report the term "awards " refers to free-standing statues, while "plaques" refers to boardlike
products generally used as wall-hangings.
2. Rationale for Designation
EPA believes that awards and plaques containing recovered materials meet the statutory criteria for
selecting items for designation.
a. Impact on Solid Waste
According to one manufacturer, a standard 8 by 10-inch plaque diverts approximately 1 pound of material
from the waste stream. Thus, if the Federal government were to purchase exclusively recovered content plaques, about
160 tons of waste material (e.g., sawdust and newspaper) would be diverted from the solid waste stream (based on the
current Federal purchasing level of $12 million over 3 years at an average cost of $33.60 per plaque). Appendix I of
this document discusses the generation and recovery of glass, wood, and paper in MSW.
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b. Technological Feasibility and Performance
Awards and plaques are sold by manufacturers and distributors of promotional products.
According to a 1995 survey, there are approximately 13,000 such distributors and manufacturers in the
United States. EPA identified six companies that manufacture or distribute awards and plaques made from
recovered materials. According to four of the companies contacted, recovered content awards are generally
made from blown glass, while plaques are made from various materials, including compressed newsprint
and sawdust.
c. Availability and Competition
As mentioned above, there are approximately 13,000 distributors and manufacturers of
promotional products in the United States. EPA identified six companies that manufacture or distribute
awards and plaques made from recovered materials. According to the four companies EPA contacted,
recovered content awards are generally made from blown glass, while plaques are made from various
materials, including compressed newsprint and sawdust. Awards and plaques made from recovered
materials are generally identified as "recycled" only on the back or bottom of the product.
d. Economic Feasibility
The promotional products industry has grown from $5 billion a year in 1990 to more than $8
billion in 1995. A PPA survey estimates that awards and plaques account for almost 8 percent, or
approximately $62 million, of promotional product sales. No discrete data are available on the percentage
of awards and plaques manufactured with recovered materials. Distributors of awards made from recovered
glass indicate these products are manufactured only on an as-needed basis. Three manufacturers of plaques
made from recovered materials, on the other hand, state that their products are produced on a regular basis,
but not in large volumes.
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e. Government Purchasing
Government agencies purchase awards and plaques through GSA's Federal Supply Service
Multiple Awards Contract (MAC) for Trophies, Awards, Plaques, Plaques with Clocks, Pins, Ribbons,
Medals, Pen Sets, and Plates/Bowls Suitable for Engraving. GSA does not track the number of awards or
plaques purchased under this contract, but does know that government agencies purchased approximately
$10 million worth of products under the subcategory "awards, plaques, trophies, plaques with clocks, pins,
ribbon, and medals" between 1990 and 1993. Between 1993 and 1996 $12 million worth of products were
purchased. While unable to provide specific information on purchasing volume, the GSA contracting officer
for this MAC claims that awards and plaques are the most popular items within the category.
Government agencies purchase awards and plaques directly from the 55 manufacturers and
distributors listed in the MAC. Of the four manufacturers of recovered content awards and plaques
contacted, only one is currently on contract to GSA. According to a representative of this company, Federal
agencies are not currently purchasing large quantities of its products, however. Indeed, EPA research
indicated that individual government agency annual purchases are generally less than the $10,000 minimum
threshold set by RCRA for CPG applicability. The largest single purchase of awards identified by EPA was
the Energy Star Program, which spent $7,000 on awards in 1996.
According to a U.S. Air Force (USAF) contact, however, it is likely that DOD purchases awards
and plaques in amounts well over $10,000. The decentralized nature of these purchases, however, makes it
difficult, if not impossible, to determine the total dollar amount of awards and plaques purchased by DOD
each year.
f. Barriers to Purchasing
The decentralized nature of award and plaque purchases, and the fact that GSA does not track
these purchases, makes it difficult to identify individuals within government agencies who are responsible
for purchasing these items. In addition, it appears that these purchases now often are made through the use
of a Federally issued credit card.
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g. Designation
In CPG III, EPA is proposing to designate awards and plaques containing recovered glass, wood,
paper, or plastic. A final designation would not preclude a procuring agency from purchasing awards and
plaques manufactured from other materials. It simply requires that a procuring agency, when purchasing
glass, wood, paper, or plastic awards and plaques, purchase these items containing recovered materials
when the item meets applicable specifications and performance requirements.
3.
Procurement Recommendations
a. Recovered Material Content
Table 32 displays the recovered and postconsumer content levels of awards and plaques produced
by various manufacturers.
Table 32
Recovered Materials Content of Awards and Plaques
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
Glass
Wood
Paper
Plastic
Plastic/Wood
Company A: 75-100
Company B: Unknown
Company A: Unknown
Company C: Unknown
Company C: 0-100
Company D: 50-95
Company D: 50 (plastic)
Unknown
100
100
100
40-100
Unknown
50 (Wood/Sawdust)/!00 (Total)
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b. Preference Program
EPA recommends that, based on the recovered materials content level shown in Table 33,
procuring agencies establish minimum content standards for use in purchasing awards and plaques
containing recovered materials.
Table 33
Draft Recovered Materials Content Recommendations
for Awards and Plaques
Material
Glass
Wood
Paper
Plastic and Plastic/Wood
Composite
Postconsumer Content (%)
75 - 100
~
40 - 100
50- 100
Total Recovered
Materials Content (%)
100
100
40 - 100
95 - 100
c.
Specifications
EPA did not identify any specifications or standards regarding awards and plaques.
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D. Mats
1. Item Description
Mats are temporary or semipermanent protective floor coverings used for numerous applications.
They are used to protect carpeting by reducing wear and tear in heavy traffic areas and by removing
moisture, dirt, and grime from people's shoes. They are used to protect car and truck floor boards from dirt
or accidental spills, and office carpeting from wheel damage caused by swivel chairs. Mats are used to
provide traction on stairs, ship decks, docks, around pools, or on marble or tile floors; to reduce worker
fatigue in occupational work areas that require excessive standing; and to reduce the risk of injury during
athletic events. Mats are also used for many specialty applications, such as protecting truck beds and the
teeing areas of golf driving ranges.
Mats are manufactured in a wide variety of designs and from numerous materials. Some of the
most common materials used include aluminum, cocoa fiber, HDPE, LDPE, nylon, PET, polycarbonate,
PP, PVC, rubber, steel, tempered hardboard, and wood. Multiple materials may be used in a single mat.
Vinyl or rubber "links," for example, are often joined together with steel rods.
Manufacturers may use the same material in mats designed for various applications. The only
difference, for example, between a rubber entrance mat and a rubber truck bed mat may be the dimensions
of the mat. Mats can also be easily customized by modifying the production process for an existing product
to adjust the thickness, size, texture, or color. Other mats are designed as interlocking tiles that allow the
end user to create mats as large or as small as needed.
2. Rationale for Designation
EPA believes that mats containing recovered materials meet the statutory criteria for selecting
items for designation.
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a. Impact on Solid Waste
Mats are made with recovered and postconsumer rubber, PVC, HDPE, LDPE, PET, and PP. In
addition, many mats contain steel or aluminum links or frames, which contain recovered metal. Appendix I
of this document discusses the generation and recovery of these materials in MSW.
EPA did not identify any trade organizations specifically representing mat manufacturers, which
makes it difficult to quantify the volume of materials diverted from the waste stream due to the use of
recovered content materials in mats. One manufacturer, however, uses approximately 1 million pounds of
recovered PVC to produce 50,000 to 60,000 PVC mat tiles a year. Another manufacturer uses over 45,000
nonradial truck tires to produce an unspecified quantity of rubber mats.
b. Technological Feasibility and Performance
Manufacturers estimate that between 75 and 95 percent of all mats manufactured in the United
States are made with some percentage of postconsumer material content. According to all of the
manufacturers contacted by EPA, recovered content mats perform as effectively as their virgin
counterparts, although virgin materials are sometimes added to provide color or product consistency.
According to one manufacturer using postconsumer material, PVC, in particular, has inherent limits as to
how, and in what form, it may be recycled. PVC contains plasticizer, which gives it softness and flexibility. Each time
the material is heated to be reformed, less plasticizer remains. PVC pipe, for instance, starts out with much less
plasticizer, and being less malleable, it is more difficult to make into a new recycled product. New products are made
from the more rigid PVC recovered products, but additional plasticizer is typically added during reprocessing.
c. Availability and Competition
EPA identified 44 manufacturers, distributors, or suppliers of recovered content mats. They are located
throughout the United States and supply both domestic and international markets. EPA contacted five mat
manufacturers who estimated that between 75 and 95 percent of all mats manufactured in the United States are
manufactured with postconsumer recovered material content.
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d. Economic Feasibility
According to several manufacturers throughout the mat industry, recovered content mats are
generally less expensive than their virgin counterparts.
e. Government Purchasing
EPA has been unable to determine how many mats are procured by Federal agencies. A contact
with USPS explained that, although each of the 40,000 USPS facilities probably uses antifatigue mats,
USPS does not track their use or procurement because post offices are not required to obtain headquarters'
permission for expenditures under $10,000 a year.
The GSA Supply Catalog lists 36 products in 9 mat categories, including chair, door, deck, dental
floor, porch floor, antifatigue, insulating, ribbed floor, and stair tread mats. The GSA catalog only
identifies two of the 36 products as containing recovered materials, both of which are door mats containing
100 percent postconsumer recovered rubber. The number of categories and products suggests that there is a
sizable government market for mats. Most Federal buildings, for example, contain numerous entrance,
floor, and chair mats. DOD procures a variety of mats, including antislip mats for boat and ship decks and
docks, helicopter landing mats, and truck bed mats. Despite repeated attempts, EPA was unable to obtain
information quantifying Federal procurement of mats.
f. Barriers to Purchasing
Mats containing postconsumer recovered materials are commercially available throughout the
United States, but only two of the 36 mats listed in the GSA catalog are identified as containing recovered
materials. All seven of the chair mats and all five door mats included in the GSA catalog are also listed as
UNICOR/NIB/NISH mandatory source items.2 The Federal government has established a preferential
procurement program for UNICOR, NIB, and NISH products, which states that if a UNICOR/NIB/NISH
2 The UNICOR, NIB, and NISH programs are designed to provide employment for Federal prisoners,
people with severe visual impairments, and other physically challenged individuals.
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product meets ordering requirements, it cannot be procured from an alternative source. None of the
mandatory source chair mats and only two of the five door mats (both made from 100 percent
postconsumer rubber) are identified as containing recovered materials. UNICOR could not identify the
sources for recycled rubber, however.
A NISH manufacturer producing 400,000 to 500,000 vinyl chair mats a year explained that it did
not know if their products contain any recovered materials. It purchases the vinyl used in its manufacturing
process based on the price and quality of the vinyl. This NISH manufacturer explained that its vinyl
supplier buys back scrap vinyl from its production process that would normally be discarded. The scrap
vinyl is reground and reprocessed. The supplier is paid enough for the vinyl scraps to cover the cost of
shipping them back to the vinyl manufacturer.
EPA contacted the vinyl supplier for the NISH manufacturer and learned that it occasionally buys
back scrap vinyl, but does so primarily to maintain good customer relations rather than to recover the vinyl
for reprocessing. This contact could not provide an estimate on the percentage of postindustrial scrap that is
reground, but believes it is very small.
g. Designation
In CPG III, EPA is proposing to designate mats containing recovered rubber and/or plastic. A final
designation would not preclude a procuring agency from purchasing mats manufactured from other materials. It
simply requires that a procuring agency, when purchasing mats made from rubber and/or plastic, purchase these
items with recovered materials when they meet applicable specifications and performance requirements.
3. Procurement Recommendations
a. Recovered Materials Content
Mats are available containing up to 100 percent postconsumer recovered materials. According to
manufacturers contacted by EPA, most mats contain at least some postconsumer materials. EPA identified
over 25 manufacturers that produce rubber mats from at least 90 percent postconsumer tires. Several
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manufacturers also produce mats that contain 100 percent postconsumer PVC, 100 percent postconsumer
mixtures of HDPE and PP, 100 percent postconsumer mixtures of rubber and PVC, and up to 97 percent
postconsumer HDPE, LDPE, PET, and PP. Many mats also have steel or aluminum links or frames, which
contain recovered metal.
Manufacturers are using postconsumer materials from a variety of sources in addition to curbside
collection programs. One manufacturer, for example, is using postconsumer PVC recovered from used
swimming pool liners, empty hospital intravenous bags, and water park rafts. For example, Typhoon
Lagoon, located in Walt Disney World, Florida, disposed of 5,000 rafts a year until the manufacturer
started collecting them to manufacture mats. The manufacturer explained that over 200 smaller scale water
parks in the United States are still disposing of their rafts. Other manufacturers are producing mats from
recovered tires, X-ray film, and industrial scraps from the roofing and automotive industries.
Table 34 displays recovered content information obtained by EPA from manufacturers of
recovered content mats.
Table 34
Recovered Materials Content of Mats
Material
Rubber
Postconsumer Content (%)
Company A: 92
Company B:
Company C: 100
Company D: 30
Company E: 92-98
Company F: 90
Company G: 40-92
Company H: 100
Company I: 75-95
Company J: 75-95
Company K: 100
Company L: 100
Company M: 90
Total Recovered
Materials Content (%)
92
60
100
30
92-98
90
40-92
100
75-95
75-95
100
100
90
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Material
Rubber (cont.)
Plastic
Mixed (Plastic/Rubber)
Postconsumer Content (%)
Company N: 98
Company 0: 98
Company P: 85-100
Company Q: 95
Company R: 98
Company S: 90-100
Company T: 95
Company U: 100
Company V: 60
Company W: 90
Company X: 100
Company Y: 95
Company Z: 75
Company AA: 100
Company BB: 90
Company CC: 100
Company DD: 66
Company EE: 80
Company FF: 96
Company GG: 90
Company HH: 98
Company II: 100
Company JJ: 85
Company KK: 55-85
Company M:
Company N:
Company V:
Company KK: 15
Company LL:
Company MM: 10
Company NN: 50
Company OO: 100
Company PP: 50
Company QQ: 50 (Plastic)/
50 (Rubber)
Company RR: 60 (Plastic)/
40 (Rubber)
Total Recovered
Materials Content (%)
98
98
85-100
95
98
90-100
95
100
60
90
100
95
75
100
100
100
66
80
96
90
98
100
85
55-85
100
100
100
100
100
100
50
100
50
100
100
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b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 35,
procuring agencies establish minimum content standards for use in purchasing mats containing recovered
materials.
Table 35
Draft Recovered Materials Content Recommendations for Mats
Material
Rubber
Plastic
Rubber/Plastic Composite
Postconsumer Content (%)
75 - 100
10- 100
100
Total Recovered
Materials Content (%)
85 - 100
100
100
c.
Specifications
With the exception of competition wrestling mats, there are no industry, government, or
independent specifications for mats. ASTM developed a wrestling mat specification for mats used in high
schools and colleges. The specification addresses the construction of closed-cell foam cores with PVC,
PVC coatings, or both; foam cores, either open- or closed-cell enclosed in sewn, loose covers; and molded
open-cell PVC foam with a dense skin on one surface that is an integral part of the mat. The ASTM
specification does not preclude the use of recovered content materials.
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E. Signage
1. Item Description
Signs made from recovered materials are used for public roads and highways, and inside and
outside office buildings, museums, parks, and other public places. The Federal government procures four
types of signs: (1) conventional road signs, (2) expressway signs, (3) freeway signs, and (4) miscellaneous
nonroad signs (DOT, 1988). This summary includes information on sign posts and supports, as well as sign
blanks (the area of the sign that contains the actual information).
Highway and other road signs are purchased by state and local governments primarily with funds
from the Federal government earmarked for transportation. Nonroad signs are procured at the Federal and
state levels on an as needed basis.
Road Signs
There are three types of road signs: conventional road signs, expressway signs, and freeway signs.
Conventional Road Signs
Conventional road signs are guide signs used to direct vehicle operators along streets and highways;
inform them of interesting routes; direct them to cities, towns, villages, or other important destinations; identify
nearby rivers and streams, parks, forests, and historical sites; and provide information to help them along their
way in the most simple, direct manner possible. These signs are generally relatively small.
Expressway Signs
Expressways are divided arterial, urban highways for through traffic. Most expressways have
partial control of access and grade separation at major intersections. Because of increased driving speeds,
expressways require large, high-impact signs. Expressway signs provide drivers with directions, furnish
advance notice of the approach to intersections or interchanges, direct drivers into appropriate lanes for
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exits or merges, and provide other useful information. Expressway signs are designed to be legible to
drivers moving at moderate speeds (30 to 50 miles per hour). This usually means high visibility, large
lettering and symbols, and short legends for quick comprehension.
Freeway Signs
Freeway signs provide information to drivers on high-volume, high-speed motor vehicle corridors.
These signs are primarily for the benefit and direction of drivers who are not familiar with the route or area.
The signs must quickly furnish drivers with clear instructions for orderly progress to their destinations.
While almost any rigid material can be used for any type of road sign, most states use aluminum
because it has a high strength-to-weight ratio, costs less than other materials, and withstands extreme
temperatures. Aluminum's strength-to-weight ratio is an important consideration. Road signs are usually
more than 3 feet wide, so they must be strong but lightweight. States occasionally use smaller road signs,
which could be made of a weaker material, but they prefer to use the same material for all signs to achieve
economies of scale. States also prefer aluminum because it resists environmental damage. Plywood is also
occasionally used for road signs, but one contact believed its use has declined in recent years.
Road signs are normally constructed of several extruded aluminum planks, formed into flat-
bottomed U-shapes and placed side by side. Tape is used to smooth the joints, and braces are extended
across the back to stabilize the sign. A reflective polymer is applied to the front to create lettering and
symbols. Sign blanks are typically comprised of either aluminum sheeting or an exterior grade plywood.
Several grades of aluminum are used in road signs. Although most aluminum products contain
recovered materials, products made from lower grade aluminum usually contain higher percentages of
recovered materials. A contact at the Connecticut Department of Transportation said that most states use a
mid-level grade of aluminum (Grade 5051) for road signs. The Ohio Department of Transportation uses a
higher grade (Grade 6061) but has recently approved the use of two lower grades (Grade 5051 and 3038)
as well. According to the National Aluminum Association, common alloy sheet aluminum, from which sign
blanks are made, consistently contains fairly high levels of recovered content regardless of grade, although
the association could not provide an average percentage.
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Miscellaneous Nonroad Signs
These signs are used in Federally owned or managed areas other than roadways, such as national
parks, historic sites, monuments, and other places of public interest. Nonroad signs are often smaller than
standard roadway signs. As a result, they can be made of materials with lower strength-to-weight ratios,
such as wood and plastics such as HDPE and PP, although they are also often made with aluminum. There
are two types of plastic signs: a simple, paintable sheet and a triple-ply, two-color sheet that is meant to be
routed (or etched) to expose the interior color. Plastic is better suited to smaller signs, as large plastic signs
can be extremely heavy.
Sign Supports and Posts
Sign post and supports can be made from a variety of materials, including steel, fiberglass
reinforced plastic, thin-wall steel tubing, steel U-post or flanged channel, and standard schedule 40 steel
pipe. Other materials being used in small sign supports include wood and other types of plastic. The
number and type of supports selected for use at a given site depends on sign blank area and buyer
preference. A period of 15 to 20 years is the maximum life expectancy for most sign posts and supports,
regardless of the type of material.
2. Rationale for Designation
EPA believes that signage containing recovered materials meets the statutory criteria for selecting
items for designation.
a. Impact on Solid Waste
Sign blanks, posts, and supports are manufactured using recovered aluminum; postconsumer or
recovered wood; and recovered plastic, including HDPE, LDPE, PET, PP, and polycarbonate. The
following information is based on information obtained from a number of sources and is based on
commonly used sign measurements.
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# HOPE: If the Federal government purchased 1,000 64-pound HOPE National Park
trailhead signs (4 by 4 inches at 4 pounds per square foot), up to 64,000 pounds of HDPE
could be diverted from the waste stream.
# PET: If the Federal government purchased 1,000 128-pound "Welcome" signs (4 by 8 feet
at 4 pounds per square foot), up to 128,000 pounds of PET could be diverted from the
waste stream.
# Polycarbonate: If the Federal government purchased 1,000 127.5-pound map signs (5 by
5 feet at 5.1 pounds per square foot), up to 127,500 pounds could be diverted from the
waste stream.
# PP: If the Federal government purchased 1,000 24-pound men's room signs (2 by 4 feet at
3 pounds per square foot), up to 24,000 pounds could be diverted from the waste stream.
# Aluminum (common alloy sheeting, grade 3015): If the Federal government purchased
1,000 160-pound expressway signs (8 by 10 inches at 2 pounds per square foot), up to
64,000 pounds of aluminum could be diverted from the waste stream.
# Particleboard/plywood: If the Federal government purchased 1,000 36.8-pound
informational signs (4 by 4 inches at 2.3 pounds per square foot), up to 36,800 pounds of
wood materials could be diverted from the waste stream.
Appendix I of this document discusses the generation and recovery of these materials in MSW.
b. Technological Feasibility and Performance
Plastic Road Signs
Conventional road signs can be manufactured from 3/8- to 3/4-inch thick HDPE or PET recycled-
content sheeting, which can be heavy when used in large sheets. Because conventional road signs rarely
reach more than 36 inches wide or long, however, the thickness of the sheeting does not usually pose a
weight problem.
Conventional road signs are normally used in applications where people have easy access to them.
As a result, they are frequently vandalized, according to a plastic sign manufacturer. According to this
manufacturer, plastic signs withstand such vandalism better than traditional wood or metal signage. A
contact at the Grand Teton National Park confirmed that spray paint, for example, can be easily removed
from HDPE (a wax-based polymer). This same contact said that bullet holes are nearly unnoticeable on
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plastic signs, whereas on wood or aluminum they may practically destroy the sign. The plastic sign
manufacturer said that while plastic signs with recycled content may cost up to double the price of a comparably
sized aluminum sign, they have double the life expectancy because of durability. The Grand Teton National Park
contact said that plastic signs have been in use in his park for more than 7 years without significant signs of
wear. Wood signs typically last about 3 years before maintenance such as repainting is needed, while aluminum
signs last a bit longerfrom 5 to 7 years before they are reused or recycled, although in hot climates the vinyl
letters used on aluminum signs tends to degrade more quickly. Some manufacturers estimate that plastic signs
can last at least twice as long as aluminum20 years or more.
According to a contact at the state of Connecticut, plastic is not commonly used in road signs
because it can soften in heat and shatter in cold. The contact pointed out that aluminum, on the other hand,
withstands extreme temperature fluctuations. In addition, a manufacturer of plastic signs in Colorado said
that reflective coatings do not adhere well to recycled content plastic signs because trace amounts of waxes
and polymers begin to emerge from the plastic after a year or two. This source suggested that aluminum
signs hold reflective surfaces much better. The state of Ohio experienced similar minor performance
problems in testing polycarbonate plastic road signs. In this case, the tester surmised that the dark plastic
material absorbed heat from the sun, causing the heat-applied coating to bubble. UV inhibitors, however,
can be added to the plastic to minimize bubbling, brittleness, and fading caused by long-term exposure to
the sun. Polycarbonate is a thermoplastic used in car headlights and eyeglass lenses, known for its
resistance to deformation and breakage. The plastic is relatively lightweight and can be used in large signs,
whereas less-engineered plastics (such as HDPE and PET) cannot be used in large sign applications
because they would have to be excessively thick and heavy to be strong enough. EPA identified one
manufacturer that currently manufactures signs from recovered polycarbonate (International Plastics
Company).
The Florida and Oklahoma Departments of Transportation also tested plastic road signs containing
recovered materials and experienced performance problems such as warping, tearing, and bubbling. A few
companies, however, manufacture fiberglass and plastic-reinforced postconsumer plastic signs to prevent
warping, but these companies do not have any government customers at this time. One manufacturer offers
a cast acrylic, shatterproof sign blank that is three times as rigid as polycarbonate, but this durable material
does not currently contain recovered materials. To the best of EPA's knowledge, no states have tested these
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reinforced signs. In 1980, the Texas Department of Transportation (TxDOT) tested several types of
fiberglass roadsigns and found that pure fiberglass was too brittle and did not stand up to moderate wind
gusts. Currently, TxDOT is experimenting with incorporating rubber recovered from automobile tires into
plastic signs.
TxDOT, in cooperation with Texas A&M University, is studying the use of recovered material
content in road signs but has not yet reached any conclusions. (A report on this research will be available to
the public.)
Aluminum Road Signs
After an aluminum road sign has served its purpose, or when it becomes illegible or obsolete, it can
be reused by replacing the old reflective polymer with new reflective polymers. The departments of
transportation in Ohio, Connecticut, Oregon, Texas, and other states, for example, reuse their aluminum
signs by grinding off the old surfacing and replacing it. This is a common practice nationwide, although
aluminum signs can only be reused an average of two times using this technique because each sanding
removes a layer of the aluminum with the reflective coating. When the sign blank becomes too thin to reuse,
it is normally sent to a metal recycler for reprocessing.
Nonroad Signs
EPA contacted an official at Grand Teton National Park about plastic nonroad signs (maps,
welcome signs, trail signs, etc.) containing recovered materials. The signs are HOPE, and have 50 to 80
percent postconsumer recovered materials content. The colors on the signs have held up well over time
(some of the signs have been in place for nearly 8 years), and the contact believed that the extra initial
expense of purchasing plastic as opposed to aluminum or wood has been recouped over the years in avoided
maintenance costs, although he could not directly quantify that assumption. After just a few years, for
example, most wood signs exposed to the elements require repainting, while a plastic sign can withstand the
elements almost indefinitely. The contact said that the National Park Service sign manual is being rewritten
to include information on signs containing, or made with recovered and other alternative materials, such as
acrylic and foam board. The new manual, which will be available in 1998, will encourage the use of
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recovered materials in signs by providing pertinent information (without specifying the types of materials to
be used). This could spur other agencies to explore the use of signs containing recovered materials.
On the other hand, nonroad plastic signs containing recovered materials do have some minor
shortcomings. In extreme climates, the plastic can contract and expand, causing some very minor distortion
of sign design and wording. In addition, the plastic signs cannot be painted and cannot hold reflective
material. One contact also had to create special sign supports for the plastic, which did not hold well with
bolts because the plastic strips easily and the bolts become loose. Instead of using bolts, the crew designed a
slotted channel frame, which has worked well.
Sign Posts and Supports
Recovered materials are commonly used in the manufacture of sign posts and supports. Sometimes
signposts are made by wrapping a shell of recovered HDPE or LDPE around a steel core. Plastics used
include postconsumer HDPE, LDPE, PP, and commingled resins. Other recovered materials used include
fiberglass, old (postconsumer) tires, and wood fibers. According to a plastic lumber manufacturer, plastic
posts are more durable than wood, and are safer than steel in the case of accidental impact. The steel
supports contain at least 25 percent recovered materials. EPA was not able to obtain information on
recovered content in wood sign posts and supports.
c. Availability and Competition
EPA identified two distributors that market aluminum sign blanks containing postconsumer
recovered materials, although, as noted earlier, most aluminum products already contain recovered
materials. Plastic road and nonroad signs with recovered content are manufactured or distributed by at least
15 companies that sell their products nationally. Recovered content plastic posts are manufactured by
several companies.
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d. Economic Feasibility
Road Signs
For recovered plastic materials to be used in large road sign applications, the plastic must be an
engineered material, such as a polycarbonate, in order to meet strength requirements. Polycarbonate blanks
are significantly more expensive than aluminum blanks, but can last twice as long or longer.
Smaller roadway and nonroad signs can be made of a nonengineered plastic, including some
recovered resins. The use of nonengineered plastics in signs, however, would require manufacturing
capabilities that most state road sign shops or contractors do not currently posses (because they
manufacture mostly aluminum signs). According to a contact at the National Aluminum Association,
providing plastic signs would require significant expenditures for retooling and manufacturing equipment
on behalf of those shops and contractors that currently supply only aluminum sign blanks. The association
contact said that retooling costs may vary from between $2,500 to $50,000 per shop. Depending on the size
of the shop, retooling may be cost-prohibitive. Consequently, using plastics for roadway sign applications
may not be economically feasible for some sign manufacturers at this time.
Also, states that refurbish their aluminum signs save one-third of the cost of new blanks.
Refurbishing costs $1 less per square foot than a new aluminum sign, even after taking into account the
extra labor needed for refurbishment.
A new high-intensity reflective sheeting (now required in some states for safety purposes) is
difficult to remove, and can make reuse impractical and cost-prohibitive. The old reflective sheeting used to
be sanded cleanly off the sign substrates in order to reuse the base sign blank. The new reflective material,
however, gums up the sanding belts. To help ensure its durability, the new reflective sheeting bonds almost
permanently with the sign substrate. In Texas, for example, the percentage of aluminum signs able to be
reused has dropped from 25 percent to less than 5 percent as a result of using the new reflective sheeting.
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Nonroad Signs
Signs used for informational purposes can be made with aluminum or other metals, wood, or
plastic. As previously noted, contacts at NFS have observed that plastic signs are more resistant to
vandalism and environmental damage and, therefore, incur much lower maintenance and replacement costs.
Heavy-weight HDPE or PET can be used in this application instead of the more expensive engineered
plastics; thus, using recovered plastic in informational signs appears to be economically feasible. Plastic
signs are, in most cases, cost competitive with routed redwood, but can be more expensive than the
aluminum and plywood signs most often used in nonroad applications. Both contacts at NPS, however,
have found that in their parks, the initial extra expenditure for plastic signs is recovered over the long run
through reduced maintenance costs.
Sign Posts and Supports
Nonreinforced plastic sign posts cost approximately two and a half times that of wood, while steel-
reinforced sign posts cost approximately three times that of wood. Plastic posts last at least two times
longer than wood, however.
e. Government Purchasing
Road Signs
Most states purchase aluminum sign blanks made from common alloy sheet aluminum, which
usually contains recovered materials. The number of states purchasing recovered plastic road signs is
currently small, but that number is expected to grow as plastic sign technology matures. EPA was able to
identify only two agencies (the NPS and the Forest Service) currently purchasing nonroad plastic signs
containing recovered materials.
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Nonroad Signs
EPA contacted purchasers of routed plastic informational signs at NFS who stated that plastic
containing recovered materials is a viable alternative for nonroad signs in all national parks and national
forests. Overall, they were pleased with the performance of the signs in their parks. Some of the signs have
been in place for up to 8 years. A vendor that sells primarily recovered-content HDPE signs indicated an
increase in demand for these signs over the past three years.
The following is a list of 24 Federal and state agencies that have purchased nonroad signs
containing recovered materials:
ARIZONA
Glen Canyon National Recreation Area
Grand Canyon National Park
CALIFORNIA
U.S. Forest Service, San Demis Technical Development and Research Center
COLORADO
Gunnison National Forest
National Park Service, CurreCanti Recreation Area
FLORIDA
Naval Air Station, Pensacola
Naval Air Station, Whiting Field, Milton
GEORGIA
Chattahoochee-Oconee National Forest, Gainesville
KENTUCKY
Daniel Boone National Forest, Winchester
MICHIGAN
Isle Royale National Park, Houghton
Michigan Department of Transportation, Southfield
MONTANA
U.S. Forest Service, Northern Region, Missoula
NEVADA
Lake Tahoe Nevada State Park, Incline Village
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OHIO
Cleveland Lake Front State Park
Ohio Department of Natural Resources, Columbus
OREGON
Wallowa-Whitman National Forest, Roseburg
SOUTH CAROLINA
Francis Marion National Forest, Columbia
TENNESSEE
Sycamore Shoals State Historic Area, Elizabathton
TEXAS
Unicor Federal Prison Industries, Fort Worth
UTAH
Intermountain U.S. Forest Service Region, Ogden
VERMONT
Green Mountain National Forest, Rutland
VIRGINIA
U.S. Coast Guard, Alexandria
WASHINGTON
U.S. Navy, Whidbey Island
DISTRICT OF COLUMBIA
U.S. Naval District
Sign Posts and Supports
Sign posts and supports are usually procured along with signs. As a result, EPA was unable to find
purchasing information geared specifically toward these sign components. Government agencies do
purchase them, however, in significant quantities.
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f. Barriers to Purchasing
Aluminum
While the Manual on Uniform Traffic Control Devices published by FHWA does not specify the
types of materials to be used in manufacturing signs, most states do specify grades and types of materials
for signs. In the case of aluminum signs, most states specify that only grades 5052 (pure alloy) or 6061,
which do not contain recovered materials, can be used for the manufacture of signs. A lower, less-expensive
grade, 3015, does contain recovered content but, in most states, can only be used in the manufacture of
temporary signs. Yet, according to one manufacturer, grades 5052 and 3015 are so similar that it is
difficult to tell them apart by sight alone. In terms of performance, the manufacturer said that they are
"virtually the same" and that some manufacturers knowingly (illegally) use 3105 when 5052 is specified
because it is difficult to tell them apart without extensive testing. Grade 5052 is significantly more
expensive, however, costing $.06 to $.08 more per pound than grade 3015. On the other hand, an official at
AASHTO said that performance of the lower grade alloy (3015) is more dependent on thickness
specifications. In other words, the thinner the aluminum, the more likely 3015 is to fail flatness
specifications after manufacturing or to bend and contort in the wind once the sign is posted. This same
official said that only the higher grades of aluminum consistently meet these flatness and strength
specifications, and that is why the states specify the higher grades. Grade 3015 can meet these
specifications, however, if properly manufactured. EPA is not aware of any testing that has been done to
determine if lower grade aluminum can meet flatness and strength specifications.
Plastic
EPA also identified a possible barrier to purchasing plastic signs, which can cost two to three times (on
average) more than a comparably-sized aluminum sign. Plastic signs, however, have an estimated life expectancy that
is at least double that of aluminum signs. Because government agencies do not factor life-cycle aspects into many
purchasing decisions, the cost of recovered content plastic signs may be viewed by some as cost-prohibitive. One
manufacturer, however, claimed that his nonroad, postconsumer content HDPE signs are 10 percent less expensive
than comparable aluminum signs. It is likely that the cost of postconsumer content plastic signs, while partially
dependent on the recyclables market, will drop as technologies for processing recovered plastics mature.
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g. Designation
In CPG III, EPA is proposing to designate non-road signs containing recovered plastic or
aluminum and roadway signs containing recovered aluminum. In addition, this proposed designation
includes sign supports and posts made from recovered plastic or steel. A final designation would not
preclude a procuring agency from purchasing signage or supports/posts manufactured from other materials.
It simply requires that a procuring agency, when purchasing plastic or aluminum signs for specific
applications, purchase these items made with recovered materials when they meet applicable specifications
and performance requirements. This designation pertains to plastic signs (and any associated plastic or steel
supports/posts) used for non-road applications and aluminum roadway signs (and any associated steel
supports/posts).
3. Procurement Recommendations
a. Recovered Materials Content
Recovered materials content signs are made with the following materials:
# HOPE: up to 100 percent total recovered materials, of which up to 100 percent is
postconsumer materials.
# PET: 80 to 100 percent postconsumer materials.
# Polycarbonate: up to 100 percent total recovered materials, of which up to 90 percent is
postconsumer content.
# PP: up to 100 percent total recovered materials, of which 0 to 40 percent is postconsumer
content.
# Aluminum (common alloy sheeting, grade 3015): Up to 40 percent recovered materials, of
which 0 to 25 percent is postconsumer materials, but highly variable depending on the
grade specified.
# Particleboard/plywood: up to 100 percent recovered materials.
Table 36 displays recovered content information obtained by EPA from manufacturers on signage.
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Table 36
Recovered Materials Content of Signage
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
HOPE
PET
Polycarbonate
Polyethylene, polycarbonate,
polypropylene
Aluminum
Company A: 99
Company B: Unknown
Company C: Up to 80
Company D: 100
Company E: Up to 100
Company F: 85-90
Company G: 25-100
Company H: Unspecified
Company I: Unspecified
99
40-50
Up to 80
100
Up to 100
100
25-100
Unspecified
Unspecified
b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 37,
procuring agencies establish minimum content standards for use in purchasing plastic signs for non-road
applications (e.g., welcome signs, trail signs) and aluminum signs for roadway or non-roadway applications
containing recovered materials.
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Table 37
Draft Recovered Materials Content Recommendations for Signage
Item/Material
Plastic signs
Aluminum signs
Plastic sign posts
Steel sign posts
Postconsumer Content (%)
80 - 100
25
80 - 100
25 - 100
Total Recovered
Materials Content (%)
80 - 100
25
80 - 100
25 - 100
Notes: Plastic signs and sign posts are recommended for nonroad applications only such as, but not limited to, trailway signs in
parks and directional/informational signs in buildings.
c. Specifications
EPA did not identify any material specifications for signs. For the most part, states simply test new
materials and decide whether they are appropriate for sign use. Standard specifications for road sign size,
lettering, color, strength, and other design and performance requirements can be found in the Manual on
Uniform Traffic Control Devices published by FHWA. The Manual, which is used by all states as the
main source of roadway device specifications, states the following about materials for road signs:
A variety of materials can be used effectively. However, it is recognized that technological
progress may develop new and satisfactory or superior materials for highway signs, particularly in
the fields of illumination and reflectorization. Nothing in this Manual should be interpreted to
exclude any new material that meets the standard requirements for color and legibility, both by day
and by night.
It should be noted that this passage refers primarily to reflective coatings, but also pertains to the
"substrate" (sign blank material).
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F. Strapping and Stretch Wrap
1. Item Description
The term "strapping" refers to actual straps of material used with transport packaging to hold
products in place on pallets or in other methods of commercial, bulk shipment. Strapping can also prevent
tampering and pilferage during shipping. EPA has included information on "stretch wrap," which serves a
similar transport packaging function. Stretch wrap is a thin, semiadhesive plastic film that is sometimes
used in conjunction with strapping to hold products or materials on a pallet.
In response to its September 20, 1995, request for information, EPA received one comment on the inclusion
of strapping materials in the CPG from a company in Massachusetts. The company stated that strapping with
recovered material content is available in commercial quantities at competitive prices from at least one company.
Five basic types of strapping are available in the marketplacesteel, PP, polyester, nylon, and
polyester cord. Nylon is currently a small, declining percentage of the strapping market. PP strapping is the
most commonly used and least expensive of all strapping materials. Polyester strapping is one of the most
rigid strapping materials. It is frequently used to ship heavy duty loads, such as lumber, and can contain
postconsumer recovered PET from recovered soda bottles. (Strapping containing PET is often referred to as
"polyester strapping" in the industry.) Cord (nonflat) strapping, available in both polyester and rayon, is
used only in manual applications. Because it offers excellent resistance to moisture, cord is often used in
outdoor applications, such as agriculture (e.g., the bracing of fruit trees) and the boating industry. Steel is
the strongest of all strapping materials. Like nylon, the market for steel strapping is also declining, but there
are numerous applications in which steel will continue to be the preferred material, such as heavy
construction material shipping. Based on comments from several manufacturers, polyester and PP
constitute the majority of sales in the strapping industry, with steel and rayon placing a distant third and
fourth respectively in terms of sales volume.
As mentioned above, stretch wrap is often used in conjunction with strapping, especially for palletizing
applications. It is used by product manufacturers and distributors to bind shipping cartons to pallets going to
warehouses and distribution centers, or from distributors to outlets and customers.
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2. Rationale for Designation
EPA believes that manual-grade strapping containing recovered materials meets the statutory
criteria for selecting items for designation.
a. Impact on Solid Waste
Strapping products can be manufactured from recovered and postconsumer PP, PET, and steel.
Stretch wrap can incorporate postconsumer PET from recovered green soda bottles and postconsumer
polyethylene from recovered stretch wrap. Because carpet manufacturers (the largest user of recovered
PET) shy away from green PET soda bottles because of color issues, green PET soda bottles are an ideal
feedstock for PET strapping and stretch wrap.
Although EPA was not able to find official statistics on the manufacturing and recycling of
strapping and stretch wrap in the United States, several contacts indicated that the volume of recovered
materials incorporated into strapping products varies greatly depending on the type of strapping, the
materials being used (PET can be incorporated at higher volumes than PP, for example), and the company's
ability to incorporate recovered materials, which, especially in the case of PET, depends in part on
specialized equipment.
A 3,600 foot coil of 0.5 inch hand-grade PP strapping weighs, on average, 15 pounds. Since PP
strapping can contain up to 100 percent recovered materials and 50 percent postconsumer materials, the
weight of recovered materials in an average coil of recovered-content PP strapping is between 1 to 15
pounds, with postconsumer materials accounting for as much as 7.5 pounds per coil.
A 3,600 foot coil of 0.5 inch hand-grade PET strapping weighs, on average, 22 pounds. Since PET
strapping can contain up to 100 percent recovered materials and 75 percent postconsumer materials, the
weight of recovered materials in an average coil of recovered-content PET strapping is between 1 and 22
pounds, with postconsumer materials accounting for as much as 16.5 pounds per coil.
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A 500 foot coil of flat, 0.5 inch hand-grade steel strapping, weighs, on average, 90 pounds. Since
steel strapping can contain 25 to 100 percent recovered materials and 10 to 15 percent postconsumer
materials, the weight of recovered materials in an average coil of steel strapping is between 23 and 90
pounds, with postconsumer materials accounting for as much as 13.5 pounds per coil. Appendix I of this
document discusses the generation and recovery of plastic and steel in MSW.
b. Technological Feasibility and Performance
In terms of manufacturing strapping from recovered materials, one contact stated that additional
equipment is needed, especially when it comes to incorporating PET into strapping products. The contact
said that it is not a simple matter of substituting recovered materials for virgin ones. Recovered PET is
usually received in the form of chopped or shredded bottles, and this material needs to be thoroughly dried
before beginning the manufacturing process because of condensation and leftover product on the bottles.
Consequently, this company invested nearly $1 million in additional drying equipment. The contact said
that this figure was high because of the high volume of strapping they produce (20 million pounds in 1996),
and that the costs for additional drying capacity could be lower for a smaller operation. With PP, drying is
not normally necessary when incorporating recovered materials into the manufacturing process, but some
minor adjustments in equipment may be necessary. With steel, no additional equipment is required to
incorporate recovered materials. In any case, the equipment necessary for incorporating recovered materials
into PET and PP strapping products is readily available through several companies in the United States.
Strapping is normally delivered in rolls of several hundred to several thousand feet, which can then
be applied by hand or placed on a machine for automated application. All plastic strapping, including
machine grade, can be applied manually and sealed with buckles or seals. Manual application is ideal for
low and moderate volume users and requires little or no investment in tooling. In addition, manually applied
strapping usually contains a higher percentage of recovered materials because performance requirements
are less stringent.
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By contrast, when applying strapping with automatic or semiautomatic machines, machine grade
strapping must be used. It is manufactured under stricter tolerances and must have minimal camber (arch or
curve) as specified by ASTM standards D3950, Standard Specification for Strapping, Nonmetallic and
D3953, Standard Specification for Strapping, Flat Steel and Seals.
Despite these technical issues, machine grade strapping with recovered material content does exist
and is in use, although it has only become available in the past few years. Manufacturers contacted
expressed different opinions about the feasibility of manufacturing strapping with recovered content. One
manufacturer claimed that the use of recovered materials can result in variations, making it difficult to
consistently achieve precise strength and camber requirements necessary for machine grade products.
Another manufacturer said that some performance characteristics are best achieved with virgin materials.
For example, machine-applied strapping is usually heat-sealed, and thus consistent melt-flow indices (the
temperature at which a material melts) and inherent viscosity (IV) are extremely important when
manufacturing machine grade strapping. According to this manufacturer, recovered materials can alter
these indexes. Because of this variability, many strapping manufacturers view recovered materials as less
reliable, and are unwilling to incorporate them into their machine grade strapping products. As a result,
machine grade strapping is more often manufactured without recovered material content.
Another manufacturer said that except for the most high-end, critical applications (such as
transporting heavy equipment), polyester strapping can incorporate recovered PET and meet most
specifications. In other words, according to this contact, most strapping products can, with the right
equipment and technical knowledge, incorporate recovered materials and still meet all ASTM specifications
and other important characteristics, such as consistent heat flow indices and IV. PET is a flexible polymer
whose molecular structure can be recoupled under special conditions (high temperatures) without losing
strength. Based on discussions with several manufacturers with extensive knowledge of the industry, 10 to
15 percent of PET machine grade PET strapping manufactured nationwide is made with recovered
materials. For hand-grade PET strapping, 15 to 25 percent is made with recovered materials.
While steel is the strongest strapping material available, polyester (which often incorporates
postconsumer PET) can be used in place of steel in many instances because its tensile strength is only
slightly different than steel's. This is an important factor in some industries, such as the cotton and lumber
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industries, in which steel strapping can rust and discolor the product during shipping. In fact, polyester is
preferred over steel by these industries. One contact claimed that strapping used in food applications (such
as that used to close cartons of fish or meat) must be approved by the FDA, but EPA was unable to
confirm this assertion.
One problem with incorporating recovered PET bottles into the polyester strapping manufacturing
process is that PVC bottles (which, to the average consumer, may resemble PET bottles) can accidentally
get mixed into the recovered PET feedstock. This can destroy an entire manufacturing run and cause
equipment problems.
PP is a less common recovered feedstock than PET. Some manufacturers claim that postconsumer
PP strapping is not clean enough for remanufacturing and the cost of reprocessing it is higher than using
virgin PP, but several manufacturers do incorporate postconsumer PP into their hand-grade strapping
products. One manufacturer pointed out that the molecular structure of PP is easy to break down, but,
unlike PET, it is extremely difficult to recouple. This means that the more recovered materials incorporated
into PP strapping, the weaker it will be, which is not necessarily the case with PET.
Stretch wrap can be manufactured with recovered and postconsumer material content. A clean
feedstock is desirable and contaminants such as food, paper, labels, staples, and dirt in recovered stretch
wrap can be a problem. One company that manufactures stretch wrap from recovered materials has
virtually eliminated the problem of contamination, however, by instituting a program whereby the company
buys back its own stretch wrap after use. The sources of postconsumer stretch wrap used to manufacture
stretch wrap with recovered content include warehouses and grocery stores.
The government agencies contacted by EPA did not know if the strapping products they bought
were made with recovered materials; thus, it was difficult to get much performance information from the
consumer's point of view.
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c. Availability and Competition
Strapping products made from recovered materials are available nationwide from numerous
sources. EPA identified eight strapping manufacturers that in some way incorporate recovered materials
into their products. Seven of these manufacturers make both manual and machine grade strapping, although
recovered materials are most often incorporated into manual grade strapping. EPA estimates that 25 to 30
companies are currently manufacturing strapping products.
EPA was able to identify only one manufacturer that incorporates recovered (postconsumer)
materials into its stretch wrap. Other companies may be incorporating recovered materials into their stretch
wrap products, but they do not market them as such.
d. Economic Feasibility
The economic feasibility of manufacturing strapping from recovered materials depends on several
factors: type of materials being used, type of strapping being manufactured, and current market prices for
virgin and recovered materials. Costs for strapping products vary by thickness of the strapping. On
average, PET strapping, regardless of whether or not it incorporates recovered materials, is twice as
expensive as PP strapping.
Strapping is sometimes made from recovered PP strapping. One company has instituted a program
whereby it buys back its own used PP strapping for remanufacturing. Other companies buy recovered PP
and polyester strapping as long as the used strapping meets their specifications. Although there are some
technical challenges that must be overcome, such as difficulty of recoupling, PP strapping can be
manufactured with recovered materials cost-effectively, as long as transportation costs for obtaining
recovered feedstocks can be kept to a minimum.
Manufacturing from recovered PET is only economically feasible if the price of recovered PET is
comparable to virgin PET. Most strapping distributors don't advertise their products as containing
recovered materials, even when they do contain them (despite the fact that customers occasionally
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request strapping that contains recovered materials). This situation allows the manufacturers to choose
whatever material (recovered or virgin) most inexpensively meets their specifications at the time of
manufacturing.
According to SRI, the average recovered content of all steel products is between 25 and 100
percent. Given the stable market for steel, manufacturing steel strapping with recovered materials content
should remain economically feasible.
Like strapping, the economic feasibility of manufacturing stretch wrap from recovered materials
depends on several factors, such as cleanliness of the recovered feedstock and market price of recovered
materials. As previously mentioned, stretch wrap can incorporate postconsumer PET from recovered soda
bottles and postconsumer polyethylene from recovered stretch wrap. Because the supply of both
postconsumer PET and postconsumer polyethylene stretch wrap is strong, feedstock supply is not a
problem. These materials are readily collected from grocery stores, warehouses, shipping yards, and
convention centers. The market price for these materials, however, can vary widely over time.
e. Government Purchasing
EPA contacted representatives from DLA, DOD, GSA, and USPS. All indicated that they
purchase manual grade strapping products, but none could provide evidence of machine grade strapping
procurement. A kit that includes hand-applied steel and nylon strapping products is offered in the GSA
Supply Catalog under Mailing and Packing Supplies. A contact at GSA estimated that the more versatile
manual grade products account for a far greater percentage of government purchases than machine grade,
but couldn't provide specific figures. One agency (DLA) indicated that it is in the process of making
strapping products a regularly stocked item. Several contacts indicated that the military and GSA do
procure strapping directly with appropriated Federal funds for use in palletizing operations.
Federal agencies also acquire these items indirectly by requiring the use of strapping and/or stretch
wrap on palletized goods and materials that it receives. The U.S. Government Printing Office (GPO), for
example, specifies the use of strapping and stretch wrap in its shipping guidance for paper suppliers: "The
packaged and packed items shall be placed on new pallets with strapping and/or wrap that provides a
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commercially acceptable shipping load." A contact at GSA indicated that, while the Federal government
requests that either shrink wrap or strapping be used, strength, camber, and other performance
characteristics are left up to the vendor and distributor.
Unfortunately, since strapping is a minor item in the overall shipping picture (compared to pallets,
boxes, packing materials, etc.), it is not closely tracked and is often purchased on an as-needed basis. The
former Commercial Item Description numbers for strapping products, AA880 and AA52211 for steel and
nonmetallic strapping respectively, have been canceled. The new numbers, D3953 and D3950, correspond
to the ASTM standards, as discussed below in section 3c, "Specifications."
f. Barriers to Purchasing
EPA identified no barriers to Federal procurement of strapping made from recovered PP, PET, and
steel.
g. Designation
In CPG III, EPA is proposing to designate manual-grade strapping containing recovered steel or
plastic. A final designation would not preclude a procuring agency from purchasing strapping
manufactured from another material such as rayon or nylon. It simply requires that a procuring agency,
when purchasing steel, PP, or polyester strapping, purchase these items made with recovered materials
when they meet applicable specifications and performance requirements
3. Procurement Recommendations
a. Recovered Materials Content
Levels of recovered materials used to manufacture strapping products depend mostly on the
method of application (e.g., manual or machine). Machine-grade strapping, for example, is less frequently
manufactured with recovered materials because machine application demands strict camber and strength
specifications that are more easily satisfied by using virgin materials. Strapping that does not meet these
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specifications can snap during application, causing equipment problems and safety concerns. Manually
applied (or manual grade) strapping products, on the other hand, are often manufactured with recovered
material content because of less stringent performance requirements.
Recovered material content strapping is currently being made with the following materials:
# PP: up to 100 percent recovered materials, of which 0 to 50 percent is postconsumer
material.
# PET (used to manufacture polyester strapping): up to 100 percent recovered material,
of which 0 to 75 percent is postconsumer material.
# Steel: 25 to 100 percent recovered material, of which 10 to 15 percent is postconsumer.
Stretch wrap is most commonly made of virgin LLDPE, but can also be made of regular LDPE
and PVC, the latter being incompatible with polyethylene recycling operations. Postconsumer PET from
used soda bottles and recovered stretch wrap can both be used to manufacture new polyethylene stretch
wrap. Currently, one manufacturer incorporates 20 percent postconsumer LDPE into its stretch wrap.
Table 38 lists the recovered materials used in the products of companies that manufacture strapping.
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Table 38
Recovered Materials Content of Strapping
Material
PET
PP
PP, Polyester, Hybrid Blend
LDPE
Postconsumer Content (%)
Company A: 40-50
Company B: >75
Company C: 15-35
Company D: 60
Company E: 50
Company F: 85
Company G: Unknown
Company A:
Company B:
Company C:
Company E:
Company F:
Company G:
Company H:
Company I: 20
Total Recovered
Materials Content (%)
40-50
>75
15-35
100
50
85
Unknown
5-10 (PP)
20 (PP)
15-20 (PP)
10 (PP)
20 (PP)
Unknown
40
20
b. Preference Program
EPA recommends that, based on the recovered materials content levels shown in Table 39,
procuring agencies establish minimum content standards for use in purchasing manual-grade strapping
containing recovered materials.
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Table 39
Draft Recovered Materials Content Recommendations for Strapping
Product
Polyester strapping
Polypropylene strapping
Steel strapping
Material
PET
PP
Steel
Postconsumer
Content (%)
50-85
~
10-15
Total Recovered
Materials Content
(%)
50-85
10-40
25-100
c.
Specifications
Specifications and guidance for breaking strength, elongation, and other characteristics of various
types of strapping and stretch wrap can be found in the ASTM standards listed in Table 40. These
specifications neither recommend nor preclude the use of recovered materials.
Table 40
ASTM Specifications and Guidance for Types of Strapping
Material
Strapping, Flat Steel and
Seals
Strapping, Nonmetallic
(and Joining Methods)
Strapping, Flat Materials
Stretch Wrap
ASTM Specification or
Guidance Number
ASTM D3953
ASTM D3950
ASTM D4675
ASTM D4649
Title
Standard Specification for Strapping, Flat
Steel and Seals
Standard Specification for Strapping,
Nonmetallic (and Joining Methods)
Standard Guide for Selection and Use of Flat
Strapping Materials
Standard Guide for Selection
of Stretch Wrap Films
Source: ASTM, 1990; ASTM, 1991; ASTM, 1994; ASTM, 1995
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X. OTHER ITEMS CONSIDERED FOR CPG III DESIGNATION
EPA categorized the items that are not being proposed for designation in CPG III into two
additional groups: 1) those items that will be considered for designation in future CPG revisions and 2)
those items that are no longer under consideration. EPA based these determinations on information provided
through public comments and its own research. (See section II.C of this document for a discussion of the
methodology used for selecting items for proposed designation in the CPG.)
A. Items Still Under Consideration
A number of items containing recovered materials are still under consideration by EPA for future CPG
designation. The Agency either has not completed its review of these items or has determined that additional research is
necessary.
As part of its effort to designate items in the CPG, EPA conducted its own research on a number of items.
Some items are being proposed for designation in CPG HI, while EPA has insufficient information to designate other
items at this time. For many of these items, EPA has information pertinent to only one or two of the item selection
criteria. EPA has incomplete information on the following items, which are arranged alphabetically by product
category. These items are still being researched and are being considered for possible future CPG designation.
Construction Products
Carpet runners
Flooring materials
Hardboard
Medium density fiberboard
Nylon carpet
Particleboard
Interior trim and window frames
Roofing materials
Rubberized asphalt
Building blocks
Decking material
Marine docks
Geotextiles
Plastic pipe
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Cenospheres
Aggregates
Concrete containing silica fume
Transportation Products
Embankments
Threshold ramps
Non-Paper Office Products
Office dividers
Lightweight furniture
Vehicular Products
Rebuilt motor parts
Miscellaneous Products
Food service trays
Rolling carts
Industrial abrasives
Limited use protective apparel
Bicycle racks
Mattresses, mattress pads, and pillows
B. Items Dropped From Further Consideration
EPA considered several items for proposed designation but determined, based on the available
information, that it was inappropriate to designate them. The items discussed below are no longer being
considered for designation. A brief explanation of the basis for this determination is also provided. EPA requests
additional information demonstrating that the items should be reconsidered for possible future designation.
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1. Miscellaneous Products Dropped From Consideration
a. Recycled Ink
EPA contacted numerous printers, ink manufacturers, and printing trade associations and was able
to identify only one potential recycled ink manufacturer. Several people commented that some parties have
tried remanufacturing and filtering waste printing press ink, but that they produced inferior quality inks that
were not cost effective. EPA learned, however, that many of the larger commercial printers recycle ink
internally as ink remaining from a press run can be reused or reblended with virgin ink. As there is little, if
any, activity to manufacture recycled content ink as a stand-alone product, EPA cannot designate this item.
b. Shotgun Shells
Two technical issues exist with regard to designating shotgun shells. First, the shotgun shell is
manufactured with an impact extrusion process that is highly sensitive to any contaminants in the plastic
resins, which precludes the use of recovered plastics. Second, shotgun shells are subject to more than
15,000 pounds per square inch of pressure when a shotgun is fired and manufacturers are hesitant to
introduce any impurities that may impair the integrity of the shotgun shell and result in a potentially fatal
injury.
XL DESIGNATED ITEM AVAILABILITY
EPA has identified a number of manufacturers and vendors of the items proposed for designation.
Once the item designations become final, these lists will be placed in the RCRA docket for this action and
will be posted on EPA's Internet web page. They will be updated periodically as new sources are identified
and product information changes. Procuring agencies should contact the manufacturers and vendors directly
to discuss their specific needs and to obtain detailed information on the availability and price of recycled
products meeting those needs.
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Other information is available from the GSA, DLA, State and local recycling offices, private
corporations, and trade associations. Refer to Appendix II of this document, for more detailed information
on these sources of information.
XII. ECONOMIC IMPACT ANALYSIS
Details of the economic impact of CPG III are described in the document entitled Economic Impact
Analysis for the Proposed Comprehensive Procurement Guideline III, EPA530-R-98-002, which is
included in the RCRA Docket for CPG III.
XIII. SUPPORTING INFORMATION
A. Carpet Cushion
"The Supporting Facts About Carpet Cushion," Carpet Cushion Council, 1994.
B. Coal Fly Ash/Foundry Sand/Flowable Fill
"Management and Use of Coal Combustion Byproducts," American Coal Ash Association, 1996.
"1995 Coal Combustion ByproductProduction and Use (Short Tons)," American Coal Ash Association,
1996.
"State Solid Waste Regulations Governing the Use of Coal Combustion Byproducts," American Coal Ash
Association, 1996.
"Coal Fly Ash," Buy Recycled Business Alliance, 1996.
"Beneficial Reuse of Spent Foundry Sand," Clean Washington Center, 1995.
"Barriers to the Increased Utilization of Coal Combustion/Desulfurization By-Products by Government and
Commercial Section (draft)," Energy & Environmental Research Center, 1993.
"Federal Highway User Guidelines for Coal Fly Ash," Federal Highway Administration, 1996.
"Federal Highway User Guidelines for Foundry Sand in Flowable Fill," Federal Highway Administration,
1996.
"Fly Ash Facts for Highway Engineers," Federal Highway Administration, 1995.
"Fine Foundry Aggregate in Your Backyard," Pennsylvania Foundryman's Association, 1995.
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"Processing and Potential Applications of Fly AshAluminum (Ash Alloy) Composite," University of
Wisconsin, 1995.
"Development and Characterization of a Closed Pore Insulation Material," Grumman Aerospace
Corporation, 1976.
"What, Why & How? Flowable Fill Materials," National Ready Mix Concrete Association, 1989.
"Ready Mixed Flowable Fill: A Controlled Density Material," National Ready Mix Concrete Association,
1993.
"Flowable Fill Made with Spent Foundry Sand," Ohio Department of Transportation, 1995.
"Practical Considerations for the Formulation and Usage of Flowable Fill Materials," L. Zimmerman,
1990.
C. Plastic Lumber
"Balloting of Draft Test Methods for Density, Compressive Properties, Flexural Properties, and
Mechanical Fasteners for Plastic Lumber and Shapes," American Society for Testing and Materials, 1996.
"The State of the Plastic Lumber Industry: 1996," Plastic Lumber Trade Association, 1996.
"The Recycled Plastic Lumber Industry: Moving Toward Adulthood," Resource Recycling Magazine,
1996.
D. Playground Equipment
"Standard Consumer Safety Performance Specification for Playground Equipment for Public Use,"
American Society for Testing and Materials, 1995.
"Handbook for Playground Safety," U.S. Consumer Product Safety Commission, 1993.
E. Compost
"Biocycle Journal of Composting and Recycling," various issues.
F. Sorbents
"National Wood Recycling Directory," American Forest & Paper Association, 1996.
"Substances Absorbed by Absorbent Products," Absorption Corporation, 1994.
"Market Overview," Coalition of Organic Absorbent Producers, 1996.
"World Catalog of Oil Spill Response Products," Marine Spill Response Corporation, 1995.
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G. Signage
"Manual of Uniform Traffic Control Devices," U.S. Department of Transportation, 1988.
"Use of Recycled Materials and Recycled Products in Highway Construction," University of
Massachusetts Transportation Center, 1995.
H. Strapping
"Standard Specification for Strapping, Nonmetallic (and Joining Methods)," American Society for Testings
and Materials, 1990.
"Standard Specification for Strapping, Flat Steel and Seals," American Society for Testing and Materials,
1991.
"Standard Guide for Selection and Use of Flat Strapping Materials," American Society for Testing and
Materials, 1994.
"Standard Guide for Selection of Stretch Wrap Films," American Society for Testing and Materials, 1995.
I. Multi-Material
"Buy Recycled Guidebook," Buy Recycled Business Alliance, National Recycling Coalition, 1996.
"McRecycle USA Database Listing," McDonald's Corporation, 1995.
"NRC 1997 Program Book," 16th Annual Congress & Exposition, National Recycling Coalition, Sept. 22-
24, 1997.
"Characterization of Municipal Solid Waste in the United States: 1996 Update," U.S. EPA, EPA530-R-97-
015, April 1997.
"Buy Recycled Training Manual: A Guidebook for Government Buyers and Using Agencies," Northeast
Maryland Waste Disposal Authority, 1995.
"The Official Recycled Products Guide," Recycling Data Management Corporation, 1996.
Opportunities for Government Procurement of New and Innovative Recycled Content Products," Final
Report, prepared for EPA Region 1, by Yale University, School of Forestry and Environmental Studies,
1995.
"Recycled Products Research for the Comprehensive Procurement Guideline," Draft Final Report,
prepared for EPA Office of Solid Waste, by Science Applications International Corporation, undated.
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"Potential Items for Future Designation: Comprehensive Guideline for Procurement of Products Containing
Recovered Content," Final Report, prepared for EPA Office of Solid Waste, by Science Applications
International Corporation, 1995.
"Research on Potential Items for Designation in the Comprehensive Procurement Guideline," Report
prepared for EPA Office of Solid Waste, by Eastern Research Group, Inc., 1995.
"Manufacturing from Recyclables: 24 Case Studies of Successful Recycling Enterprises," U.S. EPA,
EPA530-R-95-001, 1995.
"Environmental Products Guide," U.S. General Services Administration, Office of Acquisition, Acquisition
Management Center, Environmental and Engineering Policy Division, 1995.
"CPGNet," Internal website (http://www.erg.com/hotlinks/cpgnet.htm), created by Eastern Research
Group, 1997.
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APPENDIX I
MATERIALS IN SOLID WASTE
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/. Internal Promotion
Procuring agencies can use several methods to educate their employees about their APP. These
methods include preparing and distributing agency affirmative procurement policies through in-house electronic
mail and other media, publishing or posting articles in agency newsletters and on the Agency's World Wide
Web home page, including affirmative procurement program requirements in agency staff manuals, and
conducting workshops and training sessions to educate employees about their responsibilities under agertcy
affirmative procurement programs.
2. External Promotion
Methods for educating existing contractors and potential bidders of ah agency's preference to purchase
products containing recovered materials include publishing articles in appropriate trade publications, posting
notices on the agency's World Wide Web homepage, participating in vendor shows and trade fairs, placing
statements in solicitations, and discussing an agency's APP at bidders' conferences.
D. Estimation, Certification, and Verification
RCRA Section 6002(2) requires the APP to include procedures for estimating, certifying, and, where
appropriate, reasonably verifying the amount of recovered content materials used during performance of a
contract. RCRA Section 6002(c)(3) further provides "the contracting officer shall require that vendors (A)
certify that the percentage of recovered materials to be used in the performance of the contract will be at least
the amount required by applicable specifications or other contractual requirements and (B) estimate the
percentage of the total material utilized for the performance of the contract, which is recovered materials."
FASA (PL 103-355) amended this section of RCRA to require estimates only for contracts in amounts greater
than $100,000. The FAR, as amended on August 22, 1997 (62 FR 44809), addresses this change and provides
clauses to be used for estimations and certifications.
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Competition
EPA recommends that determinations of "satisfactory" competition be made in accordance with the procuring
agency's procurement requirements.
Availability and Performance
Information on the economic and technological feasibility of producing each designated item, including the
availability and number of manufacturers that produce the item, the ability of the item to meet Federal or national
specifications, the recovered materials content levels used by manufacturers to produce the item, and other information can
be found in the item-specific discussions in subsection 2, "Rationale for Designation," of each item description discussion i
sections V through X of mis document
Price
In previous guidelines, EPA defined an unreasonable price as a price that is greater than the price of a competing
product made from virgin materials. EPA further interprets the reasonable price provision of RCRA Section 6002(cXlXQ
to meai that there is no projected or observed long-term or average increases over the price of competing virgin items. This
interpretation is supported in the preamble to OFPP Policy Letter 92-4 (57 FR 53364), which provides that there is no
legal mandate to provide a price preference for products containing recovered materials over similar virgin products.
C. Promotion Program
RCRA Section 6002(iX2)(B) requires each procuring agency to adopt a program to promote its preference to
purchase EPA-designated items with recovered materials content The promotion component of the APP educates staff and
notifies an agency's current and potential vendors, suppliers, and contractors of the agency's intention to buy recycled
products.
EPA believes that an agency's promotion program should consist of two components: an internal promotion
program, targeted towards the agency's employees, and an external promotion program, targeted towards the agency's
vendors and contractors.
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3. Substantially Equivalent Alternative
The third approach specified in RCRA Section 6002(i)(3) requires procuring agencies to consider a
substantially equivalent alternative to minimum content standards and case-by-case policy development. For
some items, the use of minimum content standards is inappropriate, because the product is remanufactured,
reconditioned, or rebuilt (e.g., industrial drums).
4. Requirements for Contractors
Government contractors also are subject to the requirements of RCRA Section 6002. These
requirements are applicable where the contractor uses appropriated Federal funds and purchases $10,000 worth
of a designated item or purchased $10,000 or more of the item in the previous year. See Appendix II. A.2 for
further clarification about the applicability of RCRA Section 6002 to government contractors.
5. Exceptions
A procuring agency may not always be able to purchase a designated item with recovered materials
content. RCRA Section 6002(c)(l) allows a procuring agency the flexibility not to purchase an EPA-designated
item with recovered materials content if any of the following conditions apply:
a The agency is unable to secure a satisfactory level of competition.
The item is not reasonably available within a reasonable period of time.
The item fails to meet the performance standards set forth in the agency's.
specification.
The item is available only at an unreasonable price.
Section 402 of Executive Order 12873 further directs mat, if a procuring agency waives its
requirement to purchase an EPA-designated item with recovered materials content, it must provide a written
justification specifying one or more of the exceptions listed above.
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make it clear that EPA does not establish minimum content standards for other agencies, EPA refers to its
recommendations as "recovered materials content levels," consistent with RCRA Section 6002(e) and the
Executive Order.
Whenever possible, EPA's recommendations are expressed as recovered materials content ranges
within which the items are available. EPA recommends that procuring agencies use these ranges, in conjunction
with their own research into the recovered materials content of items available to them, to establish their
minimum content standards. In some instances, EPA recommends a specific level (e.g., 100 percent recovered
materials), rather than a range, because the item is universally available at the recommended level.
Refer to Section II.C for more information on the methodology that EPA used to establish recovered
materials content ranges for the items designated in CPG III.
2. Case-by-Case Policy Development
The second approach procuring agencies must consider is case-by-case policy development. RCRA
Section 6002(i)(3XA) describes case-by-case policy development as "a policy of awarding contracts to the
vendor offering an item composed of the highest percentage of recovered materials practicable," subject to the
limitations of RCRA Section 6002(c)(l)(A) through (C) (i.e., competition, price, availability, and
performance). The case-by-case approach is appropriate where a procuring agency determines that the
minimum content standard it has established for a particular designated item is not appropriate for a specific
procurement action (i.e., the procuring agency is unable to acquire the item within the limitations described in
RCRA Section 6002(c)(l)(A) through (C)). The case-by-case approach allows a procuring agency to specify
different (usually lower) minimum content standards for specific procurement actions, while still ensuring that
the agency fulfills its responsibility to procure the designated item containing the highest amount of recovered
materials practicable.
This method does not obviate the need for agency minimum recovered materials content standards. It should be
applied to singular procurement actions only when an agency's minimum content standard is unattainable. If a procuring
agency determines that it is consistently unable to procure an EPA-designated item using the minimum content standard
it establishes, the agency should evaluate its needs and adjust its content standard accordingly.
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As discussed in Appendix III, sections 501, 504, 505, and 506 of Executive Order 12873 also address
Federal specification requirements. Section 501 directs Executive agencies to review and revise their
specifications, product descriptions, and standards to enhance Federal procurement of products containing
recovered materials. When agencies convert to CIDs, they are required to ensure that the CIDs meet or exceed
the recovered materials requirements in the specifications or product descriptions they replace.
B. Preference Program
A preference program is the system by which an agency implements its stated "preference" for
purchasing products containing recovered materials. RCRA Section 6002(i)(3) requires procuring agencies to
consider the following options when implementing their preference programs: minimum content standards, case-
by-case policy development, or a substantially equivalent alternative.
To assist procuring agencies in establishing their preference programs, when EPA designates an item, it
examines these statutory options and recommends the approach it believes to be the most effective for
purchasing the designated item. Procuring agencies may elect either to adopt EPA's recommended approach or
to develop their own approaches, provided that, in accordance with Section 402 of the Executive Order, the
selected approach meets or exceeds EPA's recommendations as described in the RMAN(s).
1, Minimum Content Standards
One approach that RCRA Section 60Q2(i)(3) requires procuring agencies to consider is establishing
minimum content standards. RCRA Section 6002(i)(3)(B) further requires the procuring agency to ensure that
its standard requires the maximum amount of recovered materials content available for the item, without
jeopardizing its intended use.
To assist procuring agencies with establishing their minimum content standards, EPA's RMANs
recommend recovered materials content levels, where appropriate, for most of the items it designates. Under
RCRA Section 6002(i), it is the procuring agency's responsibility to establish minimum content standards,
while EPA provides recommendations regarding the levels of recovered materials in the designated items. To
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Order further directs each Agency Environmental Executive to track and report, to the FEE, agency purchases
of EPA-deslgnated items. In the absence of such an individual, EPA recommends that the head of the
implementing agency appoint an individual who will be responsible for ensuring the agency's compliance with
RCRA Section 6002 and the Executive Order.
RCRA requires and the Executive Order directs procuring agencies to establish APPs for each item
EPA designates. In fulfilling this requirement, EPA recommends that each agency develop a comprehensive
APP with a structure that provides for the integration of new items as they are designated. An agency's
comprehensive APP does not need to be limited to EPA designated items. In fact, EPA encourages agencies to
implement preference programs that expand beyond the EPA designated items in order to maximize purchases
of recycled products and foster additional markets for recovered materials.
EPA believes that developing a single APP will substantially reduce procuring agencies' administrative
burdens under RCRA that result from EPA item designations. EPA also recommends that if a procuring agency
does not purchase a specific designated item, it should simply include a statement in its preference program to
that effect. Similarly, if a procuring agency is unable to obtain a particular item for one or more of the reasons
cited in RCRA Section 6002(c)( 1), a similar statement should be included in the preference program along with
the appropriate justification. According to RCRA Section 6002(i)(2)(D), it is the procuring agency's
responsibility to monitor and regularly update its APP. Should an item that was previously unobtainable
become available, then the procuring agency should modify its APP accordingly.
A. Specifications
RCRA Section 6002(d)(l) requires Federal agencies responsible for drafting and reviewing
specifications for procurement items purchased by Federal agencies to review and revise their specifications
and remove requirements specifying virgin materials only or excluding the iise of recovered materials. This
revision process should have been completed by May 8, 1986. For items designated by EPA, Section
6002(d)(2) directs Federal agencies to revise their specifications to require the use of recovered materials to the
maximum extent possible without jeopardizing their intended end-use. Procuring agencies are required to
complete their revisions within one year of an item's designation or publication of CPG revisions, as required
by RCRA Section 6002(d)(2).
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APPENDIX V
Affirmative Procurement Program
This appendix explains RCRA Section 6002 requirements for the establishment of APPs. Agencies
should note that the FAR also addresses affirmative procurement programs. (See 62 FR 44809, August 22,
1997.)
Within 1 year after EPA designates an item, RCRA Section 6002(i) requires each procuring agency
purchasing more than $10,000 of that item, or functionally equivalent items in a fiscal year, to establish an
APP for that item. Section 402 of Executive Order 12873 reinforces this requirement and further provides that
Executive agencies "shall ensure that their APPs require that 100 percent of their purchases of products meet or
exceed the EPA guideline standards," considering competition, price, availability, and performance.
An APP is an agency's strategy for maximizing its purchases of EPA-designated items. The APP
should be developed in a manner that ensures that items composed of recovered materials are purchased to the
maximum extent practicable consistent with Federal procurement law. RCRA Section 6002(i) requires that, at
a minimum, an APP consist of four elements: (1) a preference program; (2) a promotion program; (3)
procedures for obtaining estimates and certifications of recovered materials content and, where appropriate,
reasonably verifying those estimates and certifications; and (4) procedures for monitoring and annually
reviewing the effectiveness of the APP. In addition, Section 402 of the Executive Order directs an agency APP
to encourage the electronic transfer of documents, the double-sided printing of government documents, and the
inclusion of provisions in contracts, grants, and cooperative agreements that require documents to be printed
two-sided on recycled paper.
EPA recommends that the Environmental Executive within each major procuring agency take the lead
in developing the agency's APP and in implementing the requirements set forth in the CPG. This
recommendation is consistent with the basic responsibilities of an Agency Environmental Executive as
described in sections 302 and 402 of the Executive Order. Section 302 charges each Agency Environmental
Executive with coordinating all environmental programs in the areas of acquisition, standard and specification
revision, facilities management, waste prevention, recycling, and logistics. Section 402(c) of the Executive
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APPENDIX V
AFFIRMATIVE PROCUREMENT PROGRAM
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D. OMB Circular A-l 19
OMB Circular A-l 19, "Federal Participation in the Development and Use of Voluntary Standards" (54
FR 57645), sets forth policy for executive agencies to follow in working with voluntary standards bodies and in
adopting and using voluntary standards. Paragraph 7(a)(4) recommends that Federal agencies give preference
to adopting and using standards that "foster materials, products, systems, or practices that are environmentally
sound and energy-efficient."
E. OMB Circular A-131
OMB Circular A-131, "Value Engineering" (58 FR 31056), requires executive agencies to use value
engineering as a managementtool to reduce program and acquisition costs. Paragraph 8(b) requires agencies to
develop guidelines for both in-house personnel and contractors to identify programs or projects with the most
potential to yield savings from the application of value engineering techniques. Paragraph 3(b)(4) further
requires this guidance to ensure that the application of value engineering to construction and other projects or
programs includes consideration of environmentally sound and energy-efficient results.
F. Federal Acquisition Streamlining Act
RCRA Section 60029(c) requires vendors to estimate the percentage of recovered materials used in the
performance of a contract. The Federal Acquisition Streamlining Act (FASA) (PL 103-355) amended this
section of RCRA to require estimates only for contracts in amounts "greater than $100,000."
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APPENDIX IV
Additional Policies and Procedures
In addition to the requirements of RCRA Section 6002 and the Executive Order, several other Federal
policies and procedures may affect the procurement of products containing recovered materials. This appendix
briefly summarizes requirements and policies set forth in the FAR, OFPP, Policy Letter 92-4, OMB Circulars
A-102, A-l 19, and A-131, and the GSA's proposed Cooperative Purchasing Plan.
A. Federal Acquisition Regulation
The FAR is the primary regulation used by executive agencies in their acquisition of supplies and
services (48 CFR 1). FAR Part 23 sets forth requirements and procedures for Federal agencies to use when
procuring EPA-designated items. On August 22,1997, the Civilian Agency Acquisition Council and the
Defense Acquisition Regulations Council issued a rule amending FAR Parts 1, 10, 11, 13, 15,23, 36,42, and
52 to reflect the Federal government's preference for the acquisition of environmentally sound and energy-
efficient products and services and to incorporate the requirements of RCRA Section 6002 and Executive Order
12873 (see 62 FR 44809).
B. OFPP Policy Letter 92-4
OFPP's Policy Letter 92-4, "Procurement of Environmentally Sound and Energy-Efficient Products
and Services" (57 FR 53362), establishes executive branch policies for the acquisition and use of
environmentally sound, energy-efficient products and services. In addition to reiterating the requirements of
RCRA Section 6002, the Policy Letter requires executive agencies to (1) identify and procure products and
services that, all factors taken into consideration, are environmentally sound and energy-efficient, and (2)
employ life cycle cost analysis to assist in making product and service selections.
C. OMB Circular A-102
On October 14, 1994, OMB published revisions to OMB Circular A-102, "Grants and Cooperative
Agreements with State and Local Governments" (59 FR 52224). Paragraph 2(h) of the circular requires state
and local government recipients of Federal assistance funding to comply with RCRA Section 6002.
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APPENDIX IV
ADDITIONAL POLICIES AND PROCEDURES
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Section 506 reinforces the procurement guidelines for re-refined oil and retread tires by directing
commodity managers to finalize specification revisions for the products and to develop and issue specifications
for tire retreading services. Once these specifications are finalized, commodity and fleet managers are directed
to take affirmative steps to procure retread tires and re-refined oil.
Section 602 of the Executive Order directs executive agencies to set goals for purchasing recycled and
other environmentally preferable products and to maximize the number of recycled products purchased, relative
to nonrecycled alternatives.
Finally, Section 301 requires the FEE to submit an annual report to the Office of Management and
Budget on the actions taken by agencies to comply with the requirements of the Executive Order, including the
affirmative procurement program requirements set forth in RCRA Section 6002. To enable the FEE to develop
this report, executive agencies are required to provide information on their implementation actions. The most
recent report, entitled "Report to the Office of Management and Budget: Executive Order 12873Year Two
Review," was released in October 1995.
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Section 401 directs executive agencies to consider the use of recovered materials and other
environmental factors in acquisition planning for all procurements and in the evaluation and award of contracts.
Section 402 directs the head of each executive agency to implement the affirmative procurement
program requirements of RCRA Section 6002(i) and to include a requirement that all purchases of EPA-
destgnated items meet or exceed the EPA-recommended levels. It further directs agency affirmative
procurement programs to encourage that (1) documents be transferred electronically, (2) all government
documents printed internally be printed double-sided, and (3) contracts, grants, and cooperative agreements
issued after October 20,1993, include provisions that require documents to be printed double-sided on recycled
paper that meets or exceeds the standards established in the Executive Order or in future RMANs. (See
Appendix V of this document for a detailed discussion of Affirmative Procurement Programs.)
Sections 501,504,505, and 506 of the Executive Order describe requirements for executive agencies
to incorporate the provisions of RCRA Section 6002(d)(l) and requires specific actions to be taken by certain
agencies. Section 501 directs executive agencies to review and, where applicable, revise their specifications,
product descriptions, and standards to enhance Federal procurement of products containing recovered
materials. When agencies convert to Commercial Item Descriptions (CIDs), they are required to ensure that the
CIDs meet or exceed the recovered materials requirements of the specifications or product descriptions that
they replace.
Section 504 directs executive agency heads to purchase uncoated printing and writing paper with a
minimum of20 percent postconsumer content beginning December 31,1994. Section 505 further directs the
GSA and other Federal agencies to revise their paper specifications to eliminate barriers, unrelated to
performance, to purchasing paper or paper products made by production processes that minimize emissions of
harmful by products. On May 29,1996, EPA published the final Paper Products RMAN in the Federal
Register (61 FR 26985). The Paper Products RMAN incorporates Executive Order directives for uncoated
printing and writing paper and updates EPA's 1988 recommendations for purchasing other types of paper.
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APPENDIX III
Executive Order 12873
The Executive Order entitled Federal Acquisition, Recycling, and Waste Prevention, was signed by
President Clinton on October 20, 1993. Section 502 of the Executive Order establishes a two-part process for
EPA to use when developing and issuing the procurement guidelines for products containing recovered
materials. The first part, the CPG, designates items that are or can be made with recovered materials. As with
previous procurement guidelines, the CPG is developed using formal notice-and-commentrulemaking
procedures and is codified in 40 CFR Part 247. The Executive Order directs EPA to revise the CPG annually.
The second part of the two-part procurement guidelines process, the RMAN, provides
recommendations to procuring agencies on purchasing the items designated in the CPG. The Executive Order
directs EPA to publish the RMAN in the Federal Register for public comments. Because the recommendations
are guidance, the RMAN is not codified in the CFR. RMANs are issued periodically to reflect changes in
market conditions or to provide procurement recommendations for newly designated items.
The Executive Order also directs EPA to provide guidance to executive agencies on procuring
environmentally preferable products. Section 503 directs EPA to develop and issue guiding principles for
Executive agencies to use in purchasing environmentally preferable products. On September 29, 1995, EPA
issued proposed guidance on how to incorporate the concept of waste prevention in purchasing decisions (see
60 FR 50722). The proposed guidance:
Focuses on all types of acquisition, from supplies and services to buildings and systems.
Establishes a general, umbrella guidance and requests executive agencies to select voluntary
pilot acquisitions or demonstration projects.
Establishes a framework for issuing more detailed guidance on specific product categories that
are related to current or future pilot acquisitions.
Establishes a set of guiding principles.
Outlines a number of steps for executive agencies' short-run and medium-run implementation.
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APPENDIX III
EXECUTIVE ORDER 12873
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E. How Does RCRA Section 6002 Relate to Other Federal Procurement Regulations?
The purchase of recycled products under RCRA Section 6002 must be consistent with other Federal
procurement law, which requires that contracts be awarded to the lowest priced, responsive, responsible bidder.
Federal law does not currently authorize agencies to pay a premium price for recycled products. Agencies are
using other means of purchasing recycled products that may be higher priced than virgin products, such as
soliciting only for recycled products.
On August 22, 1997, the Civilian Agency Acquisition Council and the Defense Acquisition
Regulations Council issued a rule amending the Federal Acquisition Regulation (FAR) parts 1, 10, 11, 13, 15,
23,36,42, and 52 to reflect the government's preference for the acquisition of environmentally sound and
energy-efficientproduets and services and to establish an affirmative procurement program favoring items
containing the maximum practicable content of recovered materials. See 62 Federal Register [FR] 44809,
August 22, 1997.
The Paperwork Reduction Act of 1995 (PRA) makes explicit the responsibilities of Federal agencies
with respect to the development of proposed collections of information and submission of these to OMB for
review approval. Accordingly, Federal procuring agencies should consult with their legal offices to determine
whether their requirements for estimation and certification would require OMB clearance under the PRA.
F. Where Can Agencies Find Assistance or More Information?
EPA assists procuring agencies by investigating and identifying products that can be made with
recovered materials. Based on this research, EPA conducts in-depth analyses of the feasibility of including the
product in the Federal government's procurement program. In addition, EPA, through its Recovered Materials
Advisory Notices (RMAN), provides recommendations and guidance to procuring agencies in their efforts to
comply with Section 6002 of RCRA.
For more information, agencies should contact the RCRA/Superfund Hotline at
800 424-9346 or 703 412-9810, or access EPA's Reduce, Reuse, Recycle.. .Through Procurement Website at
www.epa.gov/epaoswer/non-hw/procure.htm
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When GSA supplies products containing recovered content to other agencies, GSA has already
obtained and verified estimates and certifications. Nonetheless, agencies are still responsible for monitoring
purchases made through other agencies, such as GSA and GPO.
D. How Is Section 6002 Enforced?
Section 6002 of RCRA provides for the President's Office of Procurement Policy to implement its
requirements. In addition, Section 7002 of RCRA authorizes citizens to sue in Federal district court to seek
relief against any person alleged to be in violation of requirements of the Act, including RCRA Section 6002.
The district court has jurisdiction to enforce the requirements.
Under RCRA Section 6002, Federal grant administering agencies should inform state and local agency
grant recipients about the requirements of RCRA Section 6002. The grant recipients, in turn, are considered to
be "procuring agencies" when they are using appropriated Federal funds to purchase designated items and must
purchase these items containing recovered materials to the maximum extent practicable. RCRA Section 6002
states that procuring agencies need not purchase recycled products if the products are not reasonably available,
are only available at an unreasonable price, or do not meet reasonable performance standards. It is silent,
however, regarding penalties for failure to purchase recycled products without these limitations. Therefore,
each grant administering agency must determine the appropriate response when a grantee does not comply with
RCRA Section 6002.
RCRA Section 7002 authorizes citizens to file a civil action in Federal district court against any person
alleged to be in violation of a requirement under RCRA. Therefore, a municipality that violates RCRA Section
6002 may be subject to suit.
Executive Order 12873 (the Executive Order) directs the Federal Environmental Executive (FEE) to
take necessary actions to ensure that agencies comply with the provisions of the Executive Order. In addition,
the Executive Order directs Agency Environmental Executives to track agency purchases of EPA-designated
items and report these purchases to the Federal Environmental Executive. RCRA also requires the Office of
Federal Procurement Policy (OFPP) to submit biennial reports to Congress.
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L Purchases of Individual Items or Groups of Items
As stated above, the $ 10,000 threshold can apply to agencies' purchases of either individual items or
categories of items. Within the paper and paper products category, for example, if an agency purchases $4,000
worth of computer paper, $3,000 worth of Federal forms, and $3,000 worth of other office papers, these
combined purchases achieve the threshold for that designated item, and the agency should develop an
affirmative procurement program for all paper and paper products containing recovered materials.
2. The Cost of Services
If the cost of services and the material cost are inextricably linked, the $10,000 threshold can be
applied to the combined cost figure. If a procuring agency contracts for construction of a concrete structure, the
agency may include the cost of the services (pouring) with the cost of the product (concrete) when calculating
how much is spent on cement and concrete. Alternatively, the agency may devise a method of separating the
cost of the concrete product from the cost of pouring and finishing.
3. Purchases Made from Another Federal Agency
Many Federal agencies procure paper and paper products through GSA and the U.S. Government
Printing Office (GPO). Although both of these agencies have their own Affirmative Procurement Program
(APP), agencies that make purchases through GSA and GPO should still have their own APPs for the products
they purchase. However, the agencies would need to request estimates and certifications from GSA and GPO,
because these agencies will have already obtained this information in the initial purchases. Similarly, the
verification requirement is also fulfilled by GSA and GPO.
In other words, GPO requests estimates and certifications from its vendors and contractors and verifies
that the estimates and certifications are correct. It routinely supplies recycled paper whenever possible, even
when not specifically requested by a procuring agency. Any order for printing on offset, writing, or newsprint
stock, which constitutes the bulk of the jobs, is automatically printed on recycled paper that meets the EPA's
requirements (if the paper is available).
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C. What Is the $10,000 Threshold?
RCRA Section 6002 procurement requirements apply to any purchase by procuring agencies of an item
costing more than $ 10,000 or when the procuring agencies purchased $ 10,000 worth of the item or of
functionally equivalent items during the preceding fiscal year.
RCRA Section 6002 clearly sets out a 2-step procedure for determining whether the $ 10,000 threshold
has been reached. First, procuring agencies must determine whether they purchased $ 10,000 worth of a
designated item or functionally equivalent items during the preceding fiscal year. If so, the requirements of
RCRA Section 6002 apply to all purchases of these items occurring in the current fiscal year. Second, if the
procuring agencies did not procure $10,000 worth of a designated item during the preceding fiscal year, they
are not subject to RCRA Section 6002 unless they make a purchase of the item exceeding $10,000 in the
current fiscal year. The Section 6002 requirements then apply to the $ 10,000 purchase of the designated item;
to all subsequent purchases of the item made during the current fiscal year, regardless of size; and to all
procurements of the designated item made in the following fiscal year.
Section 6002(a) does not specify that the procurement requirements are triggered when the aggregate
quantity of items purchased during the current fiscal year is $10,000 or more. Procuring agencies need not keep
a running tally during the year of procurements of designated items. Rather, they should compute their total
procurements of a designated item once at the end of the fiscal year and only if they intend to claim an
exemption from the requirements of RCRA Section 6002 in the following fiscal year.
The RCRA Section 6002 requirements apply to each Federal agency as a whole. During each fiscal
year, each major Federal agency as a whole purchases or causes the purchase of more than $10,000 worth of
many of the designated items. Therefore, the requirements of RCRA Section 6002 apply to all procurements of
these items by these agencies and their subunits.
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2. Incidental Purchases Do Not Apply
The procurement requirements do not apply to purchases if they are unrelated to or incidental to the
Federal funding, (i.e., not the direct result of the funds disbursement). For example, if an entity has a Federal
contract to do research and builds or expands a laboratory to conduct the research, the construction is
incidental to the contract, as is the purchase of construction materials.
3. Block Grants, Commingled Monies, and Leases
RCRA Section 6002 procurement requirements apply whenever Federal monies, including block
grants, are used, whether or not they are commingled with non-Federal funds. In addition, RCRA Section 6002
also applies to a procuring agency's lease contracts for designated items. The Federal Acquisition Regulation
defines "acquisition" to include supplies or services (including construction) acquired by means of a lease (48
Code of Federal Regulations [CFR] 2.101). Under the definition of "procuring agency," therefore, lessor
contractors are subject to the RCRA Section 6002 requirements for work performed under the lease contract.
RCRA Section 6002 also applies to Department of Transportation grant programs. The conference
committee report from the Hazardous and Solid Waste Amendments of 1984 (Cong. Rec. H 1113 8 [Oct. 3,
1984]) states:
To assure the fullest participation by procuring agencies, the Conferees wish to
resolve any ambiguity with respect to §6002's coverage of the Department of
Transportation, in particular the Federal Highway Administration (FHWA). The
FHWA is a "procuring agency" under the Solid Waste Disposal Act and is therefore
fully responsible for implementing the guidelines and other requirements of §6002. It
is the intent of Congress that both FHWA's direct procurement and indirect Federal-
aid programs (Federal Highway Trust Fund) be covered by the requirements of
§6002 as amended by this Act. Indirect purchases by the Federal Aviation
Administration are also covered under Section 6002 in the same manner as is the
FHWA. Coverage of the FHWA's direct and indirect procurement activities under
this amendment extends to the review of procurement specifications pursuant to
Section 6002 (d), as amended, in addition to the affirmative procurement program
required under this section.
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supplied to the state agency, because the contract price of the mulch does not exceed $ 10,000. In Year Two,
Contractor X is subj ect to RCRA Section 6002 requirements for hydraulic mulch regardless of the amount of
the contracted purchase, because, while a "procuring agency" in Year One, it purchased in excess of $ 10,000 of
hydraulic mulch.
In another example, in Year One, Contractor Y purchases $10,000 of hydraulic mulch, but none was
purchased on behalf of a government agency using appropriated Federal funds. In Year One, ContractorY is
not a procuring agency. In Year Two, ContractorY contracts to supply less than $10,000 of hydraulic mulch to
a state agency using appropriated Federal funds. In Year Two, ContractorY is a procuring agency but is not
subj ect to RCRA Section 6002 requirements, because it was not a procuring agency during the previous year
when it acquired in excess of $ 10,000 of hydraulic mulch.
Contractors can require certifications of recycled content items to be submitted with offers.
Alternatively, EPA recommends that when an estimate has been provided in a bid, the certification of what
materials were actually used in the performance of the contract should be submitted with the last invoice.
B. To Which Purchases Does Section 6002 Apply?
1. Direct and Indirect Purchases
The RCRA Section 6002 requirements apply to both direct and indirect purchases. Purchases made as
a result of a solicitation by procuring agencies for their own general use or that of other agencies (e.g.,
purchases by the U.S. General Services Administration [GSA's] Federal Supply Service) are "direct"
purchases. Purchases of items as part of a contract also are "direct" purchases. Indirect purchases are
purchases by a state or local agency using appropriated Federal funds or, in some instances, its contractors.
Therefore, purchases of designated items meeting the $ 10,000 threshold made by states, political subdivisions
of states, or their contractors are subject to RCRA Section 6002.
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RCRA requirements apply to individual state agencies, not to a state as a whole. For example, if a state
receives several hundred thousand dollars in grant monies, only the state agency or agencies purchasing
S10,000 worth or more of a designated product must comply with Section 6002 requirements.
On October 14, 1994, the Office of Management and Budget (OMB) published revisions to Circular
A-102 to clarify the circumstances in which RCRA Section 6002 applies to state and local recipients of Federal
funds.
2. Contractors
Contractors must comply with Section 6002 with respect to work performed under the contract if they
(1) contract with a Federal agency or a state agency that is using appropriated Federal funds for a procurement
and (2) purchase or acquire a designated item whose purchase price exceeds $10,000 or purchased $10,000 or
more worth of the item during the previous year. Subcontractors are not procuring agencies; Section 6002
limits contractors subject to its requirement to direct contractors with a Federal agency or state or local
"procuring agency."
It is immaterial for purposes of the $10,000 threshold whether the contractor purchased or acquired the
designated items as a "procuring agency" (with respect to work performed under a contract with a Federal or
state agency) or in its private capacity. However, the obligations of Section 6002 are prospective. The
contractor must determine whether the $10,000 threshold is met only after it is a "procuring agency." That is,
purchases exceeding the $10,000 threshold in the year prior to the year in which a contractor becomes a
"procuring agency" do not trigger Section 6002 requirements. Furthermore, while contractors are subject to the
Section 6002 requirements once they exceed the threshold, those requirements apply only with respect to work
performed under the contract (i.e, when supplying the designated item to any state or Federal agency).
For example, in Year One, Contractor X contracts to supply $500 of hydraulic mulch to a state agency
using appropriated Federal funds to purchase the hydraulic mulch. Therefore, in Year One, Contractor X is a
"procuring agency." During Year One, Contractor X also purchases hydraulic mulch for its own use for its
other customers, with total purchases of hydraulic mulch exceeding $ 10,000. In Year One, while Contractor X
is a procuring agency, Contractor X is not subject to the RCRA Section 6002 requirements for hydraulic mulch
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APPENDIX II
Discussion of RCRA Section 6002 Requirements
This appendix provides detailed information regarding the applicability of RCRA Section 6002.
A. Who Is a Procuring Agency?
Many of the RCRA Section 6002 requirements apply to "procuring agencies," which are defined in
RCRA Section 1004(17) as "any Federal agency, or any state agency or agency of a political subdivision of a
state that is using appropriated Federal funds for such procurement, or any person contracting with any such
agency with respect to work performed under such contract." Under the statute, responsibility for complying
with RCRA Section 6002 rests with each individual procuring agency. RCRA identifies three types of
"procuring agencies": (1) Federal agencies, (2) state or local agencies using appropriated Federal funds, and (3)
contractors to (1) and (2). Procuring agency requirements are discussed in detail below. Also refer to Appendix
III, IV, and V for additional information about affirmative procurement requirements.
Private recipients of Federal funds (e.g., nonprofit organizations or individual recipients of Farm Home
Administration loans or other Federal loans, grants, or funds under a cooperative agreement) are not procuring
agencies and, therefore, are not subject to RCRA Section 6002. This is true whether the originator of the grant,
loan, or cooperative agreement is a Federal agency or a state or local agency recipient of Federal funds.
/. Federal, State, and Local Government Agencies
Federal agencies are always procuring agencies, because the RCRA Section 6002 requirements apply
to Federal agencies whether or not appropriated Federal funds are used for procuring designated items. All
Federal agencies are procuring agencies regardless of their funding authority (e.g., revolving funds, etc.). The
RCRA Section 6002 requirements apply only when Federal agencies procure designated items, however. They
do not apply when Federal agencies simply disburse funds to state or local agencies; in these instances, the
Federal agencies are not purchasing or acquiring anything. State or local agencies are procuring agencies and
must comply with the guidelines if they use appropriated Federal funds for procurement of designated items.
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APPENDIX II
DISCUSSION OF RCRA SECTION 6002 REQUIREMENTS
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In 1995, according to AF&PA, 20.7 million tons of old corrugated containers were recovered,
representing a 70 percent recovery rate. The paper industry projects that much of the growth in use of
recovered paper will be in containerboard (corrugated medium and linerboard), a paperboard grade made from
old corrugated containers. Despite the high recovery rates, there are periodic softenings in paper markets,
including markets for old corrugated containers (OCC).
1L Textiles
Textiles in MS W are found mostly in discarded clothing, although other sources may include furniture,
carpets, tires, footwear, and other nondurable goods such as sheets and towels. The 1996 estimate of textile
generation in MSW is 7.7 million tons, which represents 3.7 percent of the total MSW generated.
A significant amount of textiles is recovered for reuse. Reused garments and wiper rags reenter the
waste stream eventually, so this is considered a diversion rather than recovery for recycling and, therefore, is
not included in the estimates of recovery.
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8. Steel
EPA's 1996 waste characterization study reports that ferrous metals (steel and iron) represent
approximately 11.8 percent of MS W. According to the Steel Recycling Institute (SRI), over 67 million tons of
steel were recovered from the waste stream in 1996, representing a steel recycling rate of approximately 65
percent. The recovered steel includes 16.3 million tons of steel recovered from nearly 12 million automobiles;
19 billion steel cans and containers; and 45 million appliances. SRI estimates that every ton of recycled steel
saves 2,500 pounds of iron ore, 1,400 pounds of coal, and 120 pounds of limestone.
9. Food Waste
Food waste consists of uneaten food and food preparation waste from residences, commercial
establishments, institutional sources such as school cafeterias, and industrial sources such as factory
lunchrooms. No production data are available for food waste, but estimates have been made based on data from
sampling studies in combination with demographic data on population, numbers of garbage disposers in homes,
grocery store sales, restaurant sales, numbers of prisoners, etc. Generation of food waste was estimated to be
22 million tons in 1996. Discards of food waste in 1996 were 21.4 million tons, or 14 percent of total discards.
A significant amount of food waste composting from commercial sources was identified in 1994. In
1996, this amount was estimated at over 500,000 tons, or 2.4 percent of food waste generation.
10. Paper and Paperboard (Including Old Corrugated Containers)
Paper and paperboard, including old corrugated containers, are major components of MSW. In 1996,
over 80 million tons of waste paper, or 38 percent of total MSW, were generated. A significant portion of paper
is recovered and used in the manufacture of new paper and paperboard products. According to the American
Forest & Paper Association (AF&PA), recovered paper now supplies approximately 35 percent of all fiber
used in U.S. paper mills. Of the 43.3 million tons of paper and paperboard recovered in the United States in
1995, about 32 million tons were used to make recycled paper and paperboard products.
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6, Foundry Sand
Foundry sand is clean, high quality silica sand or lake sand bonded to form molds for ferrous (iron and
steel) and nonferrous (copper, aluminum, and brass) metal castings. After casting, the sand can often contain a
number of contaminants, including residual metals and binder materials.
There are basically two types of spent foundry sand, "green" sand and chemically bonded sand. Green
sand, used in ferrous metal castings, consists of high quality silica sand, approximately 10 percent bentonite
clay (as the binder), 2 to 5 percent water, and about 5 percent sea mold (e.g., a carbonaceous mold additive that
helps improve the casting finish). Chemically bonded sand is used in nonferrous metal castings and usually
contains 97 percent foundry sand and a small amount of organic binders and catalysts. Nearly 95 percent of all
spent foundry sand is green sand.
Annual generation of foundry sand has been estimated at between 6 and 15 million tons. The Federal
Highway Administration (FHWA) estimates that approximately 20 percent of the spent foundry sand generated
is recycled.
7. Aluminum
The largest source of aluminum in MS W is aluminum cans and other packaging. Other sources of
aluminum are found in durable and nondurable goods. In 1996, approximately 2 million tons of aluminum were
generated as containers and packaging, while 1 million tons could be found in durable and nondurable goods.
The total of 3 million tons represented 1.4 percent of total MSW generation.
Aluminum beverage containers were recovered at a rate of 63.5 percent of generation (990,000 tons) in
1996. In addition, 52 percent of all aluminum in containers and packaging was recovered for recycling in 1996.
Moreover, 2 million tons of aluminum were discarded in MSW after recovery, representing 1.3 percent of total
MSW discards.
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4. Glass
Glass is found in MSW primarily in the form of containers, but also as a component of durable goods
such as furniture, appliances, and consumer electronics. Generation of glass grew continuously through the
1960s and 1970s and began to decline in the 1980s. Glass generation was 12.4 million tons in 1996,
representing 5.9 percent of MSW generation.
Approximately 3.2 million tons of glass containers were recovered in 1996, representing25.7 percent
of glass containers generated. Most recovered glass goes towards making new glass containers, but a portion
goes towards other uses such as fiberglass and glasphalt for highway construction. Fiberglass insulation is
included in the scope of the building insulation products designation.
5. Coal Fly Ash
Coal fly ash is the term used to describe a finely divided mineral residue that results from coal
combustion. The vast majority of coal fly ash is produced in electric power generating plants, where powdered
coal is burned to produce steam to drive the turbines. It passes out of the boiler along with the stack gases and
is removed from the gases by various means, including electrostatic precipitators, mechanical precipitators,
cyclone separators, bag houses, and scrubbers. Coal fly ash is stored in silos to await reuse or disposal, or it
may be conveyed directly to a disposal area. Coal fly ash typically represents about 75 percent of the ash
generated by coal combustion, with coarser and heavier bottom ash accounting for the remaining 25 percent.
The American Coal Ash Association (ACAA) estimates that 54.2 million tons of coal fly ash were
generated in 1995. Approximately 25 percent of this material (13.6 million tons) was recovered and used in
concrete or other transportation applications. The remaining 40.6 million tons were stored or disposed of. Coal
fly ash is also used in roadbase and subbase construction, structural fills and embankments, filler in asphalt
mixes, grouting, and waste stabilization applications. EPA previously designated cement and concrete ;
containing coal fly ash.
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construction sites generally is easier to reuse than wood from demolition sites because it is relatively easy to
separate from other materials. Demolition wood on the other hand, is often less desirable because it is
I,
frequently contaminated with paints, fasteners, wall covering materials, and insulation.
According to the 1998 Biocycle article, primary timber processing mills generate large amounts of
residues in the form of bark, sawmill slabs and edgings, sawdust, and peeler log cores. Nearly all such mill
residues are used to produce other products, including paper, nonstructural panels, absorbents and adsorbents,
and fuel. Of the 86.7 million tons of wood residues generated in 1996, however, approximately six percent (5.0
million tons) were not used (McKeever, "Wood Residual Quantities in the United States," BioCycle, January
1998).
3. Rubber
The predominant source of rubber in MSW is discarded tires. Approximately 800 to 850 million scrap
tires are currently stockpiled across the United States, and over 260 million more are generated annually.
Approximately 18.6 percent of all rubber tires generated in 1996 were recovered for recycling (excluding
retreading). Improperly operated stockpiles can create serious health and environmental threats from fires and
insect- or rodent-borne diseases. Most states now have scrap tire management legislation fostering alternatives
to tire stockpiling and disposal. One of these alternatives is tire retreading, and retreads are already designated
in the CPG. The largest uses of scrap tires are tire-derived fuel and civil engineering applications. Another
alternative is to use crumb rubber, either alone or mixed with plastic, to produce new products. Several of the
items proposed for designation in CPG III contain recovered crumb rubber from tires: railroad grade crossings,
mats, carpet cushion, absorbents, and adsorbents.
Crumb rubber, a fine granular or powdered material capable of being used to make a variety of
products, is recovered from scrap tires using thermal and/or mechanical processing techniques. Crumb rubber
also is derived from the tire retreading process, when worn tire tread is removed during a buffing process before
the new tread is affixed. Rubber materials derived from this process are frequently referred to as "buffings" or
"buffing dust." Approximately 200 million pounds of tire buffings are generated each year by the tire retreading
industry in the United States.
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more communities include HDPE products in their recycling collection programs and as improvements in
recovered plastic processing are implemented.
Other postconsumer rtfsins were recycled at much lower overall rates. PP was recycled at a rate of
nearly 5 percent, LDPE/LLDPE at 2 percent and PS at 2 percent. All other resins, including PVC,
polycarbonate, and polyurethane, were recycled at negligible rates.
Technical and economic barriers prevent the increased processing and use of recovered plastic, For
example, the various plastic resins are not mutually compatible, requiring that they be separated during
processing. As a result, the price of most recovered resins is not competitive with virgin resin, which decreases
industry incentives to use them as a raw material. Thus, many communities are discouraged from including
plastic in their collection programs. The development of higher value end markets for the plastic that is
currently being collected might offset the costs of processing the recovered plastic and encourage more
communities to recover plastic from the waste stream, thereby increasing the supply of recovered resins and
making the cost of recovered resin more equitable with that of virgin resin.
Wood
EPA estimates that approximately 10.8 million tons of wood were generated as MSW in 1996, of
which only 4.5 percent (0.5 million tons) was recovered. This generation number excludes the over 5 million
tons of pallets that were refurbished and reused in 1996. Sources of wood include furniture, miscellaneous
durables, wood packaging (including pallets), and other miscellaneous products. C&D wood waste and forest
residues are also sources of wood waste and comprise a significant portion of solid waste.
A comprehensive list of C&D debris recovery programs is not available but published reports indicate
that programs exist in all parts of the United States and that it is technologically and economically feasible to
recover wood for use in products and as industrial boiler fuel, landscaping and hydraulic mulch, sludge bulking
media, and animal bedding. According to one article, C&D wood waste generation was about 33.2 million tons
in 1996, of which 14.1 million tons were potentially available for recovery; and 19.1 million tons were already
recovered, combusted, or were not usable (McKeever, "Wood Residual Quantities in the United States,"
BioCycle, January 1998). According to a 1998 EPA study on C&D debris, wood waste generated at
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Steel
Food Waste
Paper and Paperboard
Textiles
Railroad grade crossings
Park and recreational furniture
Playground equipment
Industrial drums
Strapping
Sign posts
Compost
Absorbents and adsorbents
Awards and plaques
Industrial drums
Absorbents and adsorbents
Carpet cushion
/. Plastics
Plastics in the waste stream include nondurable goods such as consumer packaging, containers, toys,
disposable diapers, trash bags, cups, eating utensils, sporting and recreational equipment, medical devices, and
housewares; durable goods such as furniture, appliances, and computers; and commercial/industrial goods such
as pipe, cable, siding, and auto parts. Plastic makes up 9 percent of MSW according to EPA's 1996
characterization study and was recovered at an overall rate of 5 percent.
PET has the highest recycling rate of all postconsumer resins with a 21 percent overall recycling rate
(3.5 million tons) for postconsumer PET. This rate reflects the high recycling rate for PET soft drink bottles,
which are the most widely recycled plastic product, with a 40 percent recycling rate. Other PET bottles (e.g.,
peanut butter jars and cooking oil bottles), packaging, and nonpackaging materials (e.g., x-ray film) are
recycled at much lower rates. Currently, the primary market for postconsumer PET is fiber for use in products
such as ski jackets, sleeping bags, and carpet. Other markets for postconsumer PET include soft drink bottles
and household product containers.
HDPE had the second highest postconsumer resin recycling rate in 1996 at 10 percent and 4.1 million
tons recycled. The primary supply of postconsumer HDPE is recycled milk and water jugs, detergent bottles,
and other household products bottles. HDPE milk and water jugs are the second most commonly recycled
product, with a 31 percent recycling rate. The availability of postconsumer HDPE is expected to increase as
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B. Materials Used in Items Proposed for Designation
Table 2 identifies the recovered materials that are or can be used in the items designated in CPG III.
Table 2
Recovered Materials Used in Items Designated in CPG III
Recovered Material
Plastic
Wood
Rubber
Glass
Coal Fly Ash
Foundry Sand
Aluminum
Designated Items
Plastic batt building insulation
Carpet backing
Carpet cushion
Park and recreational furniture
Playground equipment
Landscaping timbers and posts
Plastic binders
Plastic clipboards
Plastic file folders
Plastic clip portfolios
Plastic presentation folders
Absorbents and adsorbents
Industrial drums
» Awards and plaques
Mats
Signage/sign posts
Strapping
Absorbents and adsorbents
. Awards and plaques
Signage
Carpet cushion
Railroad grade crossings
Absorbents and adsorbents
Mats
Awards and plaques
Flowable fill
Concrete park and recreational furniture
Railroad grade crossings
Flowable fill
Park and recreational furniture
Signage
Playground equipment
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Table 1
Materials Generation and Recovery in the U.S. Municipal Waste Stream, 1996
(In Millions of Tons)
Materials
Paper and Paper-board
Glass
Metals
Ferrous
Aluminum
Other Nonferrous
Plastic
PET
HOPE
PVC
LDPE/
LLDPE
PP
PS
Other resins
Rubber and Leather
Rubber from tires
Textiles
Wood
Other
Food Waste
Yard Trimmings
Miscellaneous Inorganic Wastes
TOTAL MSW
Generation
79.3
12.4
16.0
11.8
3.0
1.3
19.8
1.7
4.1
1.2
5.0
2.6
2.0
3.1
6.2
3.2
7.7
10.8
3.7
21.9
28.0
3.2
209.7
Recovery
32.6
3.2
6.4
4.5
1.0
0.8
1.1
0.4
0.4
Negligible
0.1
0.1
Negligible
Negligible
0.6
0.6
1.0
0.5
0.8
0.5
10.8
Negligible
57.3
Source: "Characterization of Municipal Solid Waste in The United States: 1997 Update," U.S. EPA, February 1998.
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APPENDIX I
Materials in Solid Waste
The Resource Conservation and Recovery Act (RCRA) Section 6002 provides criteria for the U.S.
Environmental Protection Agency (EPA) to consider when selecting items for designation. One of these criteria
is the impact of procurement on the solid waste stream. EPA's designation of an item should promote the
statute's underlying objective of using government procurement to foster markets for items containing materials
recovered from solid waste. Consistent with this objective, each of the items that EPA proposes to designate is
made with one or more materials recovered from solid waste. This appendix briefly discusses solid waste
stream materials and provides a more detailed discussion of the materials used in the products designated in the
Comprehensive Procurement Guidelines (CPG) III.
A. General Overview of Materials in Solid Waste
Generally, solid waste has several components, such as municipal solid waste (MSW), construction
and demolition (C&D) debris, and nonhazardous industrial waste. Under RCRA Section 6002, EPA considers
materials recovered from any component of the solid waste stream when designating items containing recovered
materials.
EPA publishes annual characterization reports of the generation and recovery of MSW in the United
States. EPA's latest MSW characterization study, which presents 1996 waste generation and recovery data,
addresses the following materials: paper and paperboard, glass, metals, plastic, rubber and leather, textiles,
wood, food wastes, yard trimmings, miscellaneous inorganic wastes, and other materials. Table 1 shows the
1996 generation and recovery of these materials.
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E. Procedures to Monitor and Review the Procurement Program
Procuring agencies should monitor their APP to ensure that they are fulfilling their requirement to
purchase items composed of recovered materials to the maximum extent practicable. RCRA Section
60020X2XD) requires the APP to include procedures for monitoring and annually reviewing the effectiveness
of an agency's APP. RCRA Section 6002(g) requires OFPP to submit a report to Congress every 2 years on
actions taken by Federal agencies to implement the affirmative procurement requirements of the statute. Section
402 of Executive Order 12873 directs each agency's Environmental Executive to track and report on agency
purchases of EPA-designated items. Section 301 directs the FEE to submit a report annually, at the time of
agency budget submission, to the OMB on Executive agency compliance with the Executive Order. In order to
fulfill their responsibilities, the FEE and OFPP request information from appropriate agencies on their
affirmative procurement practices. It is important, therefore, for agencies to monitor their APP to ensure
compliance with RCRA Section 6002 and Executive Order 12873.
In order to comply with the Executive Order, agencies will need to evaluate their purchases of products
made with recovered materials content. This also will allow them to establish benchmarks from which progress
can be assessed. To evaluate their procurements of products containing recovered materials, procuring agencies
may choose to collect data on the following:
« The percentages of recovered materials content in the items procured or offered
« Comparative price informati.on on competitive procurements.
» The quantity of each item procured over a fiscal year.
* The availability of each item with recovered materials content.
» Performance information related to the recovered materials content of an item.
EPA recognizes that a procuring agency may be unable to obtain accurate data for all designated items
but believes that estimates will be sufficient to determine the overall effectiveness of an agency's APP.
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