BACKGROUND DOCUMENT FOR THE
FINAL COMPREHENSIVE PROCUREMENT GUIDELINE (CPG) III
AND
FINAL RECOVERED MATERIALS ADVISORY NOTICE (RMAN) III
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, SW.
Washington, DC 20460
EPA530-R-00-002
September 1999
-------
FINAL CPG III AND RMAN III BACKGROUND
DOCUMENT
CONTENTS
I. INTRODUCTION 1
A. History 1
B. Contents of This Background Document 3
C. Requirements 7
1. RCRA Section 6002 7
2. Executive Order 13101 9
II. ITEM DESIGNATIONS 10
A. Criteria for Selecting Items for Designation 10
1. Use of Materials Found in Solid Waste 11
2. Economic and Technological Feasibility and Performance 11
3. Impact of Government Procurement 12
4. Availability and Competition 13
5. Other Uses for Recovered Materials 13
6. Other Considerations 14
B. Methodology for Selecting Items for Designation 15
1. Selection of Items for Designation 15
C. Broad Categories Versus Specific Items 17
D. Item Designation Categories 18
III. RECOVERED MATERIALS CONTENT 19
A. Methodology for Recommending Recovered Materials Content Levels 21
B. Use of Minimum Recovered Materials Content Standards 22
C. Preconsumer Versus Postconsumer Recovered Materials 22
D. Recommending 100 Percent Recovered Materials Content Levels 23
E. Calculation of Product Content for Purposes of Certification 23
-------
IV. UPDATES OF THE CPG AND RMAN 24
V. AFFIRMATIVE PROCUREMENT PROGRAMS 25
VI. DEFINITIONS 28
VII. AGENCY'S RESPONSE TO COMMENTS 28
A. Request for Comments 29
B. Comments Recommending Additional Items for Designation 30
C. Recordkeeping and Reporting Requirements 32
D. Recommended Recovered Materials Content Levels 33
E. Other Comments 34
VIII. CONSTRUCTION PRODUCTS 35
A. Nylon Carpet with Backing Containing Recovered Materials 35
1. Background 35
2. Summary of Comments and Agency's Response 35
B. Carpet Cushion 37
1. Background 37
2. Summary of Comments and Agency's Response 38
3. Rationale for Designation 39
a. Use of Materials in Solid Waste 40
b. Technically Proven Uses 40
c. Impact of Government Procurement 41
4. Designation 41
5. Preference Program 42
6. Background for Recommendations 42
7. Specifications 43
C. Flowable Fill 44
1. Background 44
2. Summary of Comments and Agency's Response 46
3. Rationale for Designation 52
a. Use of Materials in Solid Waste 52
b. Technically Proven Uses 53
c. Impact of Government Procurement 57
iii
-------
4. Designation 57
5. Preference Program 57
6. Background for Recommendations 58
7. Specifications 61
D. Railroad Grade Crossing Surfaces 62
1. Background 62
2. Summary of Comments and Agency's Response 63
3. Rationale for Designation 64
a. Use of Materials in Solid Waste 64
b. Technically Proven Uses 65
c. Impact of Government Procurement 71
4. Designation 72
5. Preference Program 73
6. Background for Recommendations 74
7. Specifications 76
IX. PARK AND RECREATION PRODUCTS 79
A. Park Benches and Picnic Tables 79
1. Background 79
2. Summary of Comments and Agency's Response 80
3. Rationale for Designation 80
a. Use of Materials in Solid Waste 80
b. Technically Proven Uses 81
c. Impact of Government Procurement 86
4. Designation 87
5. Preference Program 87
6. Background for Recommendations 88
7. Specifications 92
B. Playground Equipment 94
1. Background 94
2. Summary of Comments and Agency's Response 95
3. Rationale for Designation 95
a. Use of Materials in Solid Waste 95
b. Technically Proven Uses 96
c. Impact of Government Procurement 99
4. Designation 100
5. Preference Program 100
6. Background for Recommendations 101
7. Specifications 104
IV
-------
X. LANDSCAPING PRODUCTS 106
A. Plastic Lumber Landscaping Timbers and Posts 106
1. Background 106
2. Summary of Comments and Agency's Response 106
3. Rationale for Designation 107
a. Use of Materials in Solid Waste 107
b. Technically Proven Uses 108
c. Impact of Government Procurement Ill
4. Designation Ill
5. Preference Program Ill
6. Background for Recommendations 112
7. Specifications 118
B. Food Waste Compost 119
1. Background 119
2. Summary of Comments and Agency's Response 119
3. Rationale for Designation 120
a. Use of Materials in Solid Waste 120
b. Technically Proven Uses 121
c. Impact of Government Procurement 124
4. Designation 125
5. Preference Program 125
6. Background for Recommendations 125
7. Specifications 127
XI. NONPAPER OFFICE PRODUCTS 128
A. Solid Plastic Binders, Clipboards, File Folders, Clip Portfolios, and Presentation
Folders 128
1. Background 128
2. Summary of Comments and Agency's Response 129
3. Rationale for Designation 130
a. Use of Materials in Solid Waste 130
b. Technically Proven Uses 130
c. Impact of Government Procurement 131
4. Designation 132
5. Preference Program 132
6. Background for Recommendations 133
7. Specifications 134
-------
XII. MISCELLANEOUS PRODUCTS 135
A. Sorbents 135
1. Background 135
2. Summary of Comments and Agency's Response 136
3. Rationale for Designation 138
a. Use of Materials in Solid Waste 138
b. Technically Proven Uses 139
c. Impact of Government Procurement 142
4. Designation 144
5. Preference Program 144
6. Background for Recommendations 145
7. Specifications 149
B. Industrial Drums 151
1. Background 151
2. Summary of Comments and Agency's Response 151
3. Rationale for Designation 154
a. Use of Materials in Solid Waste 154
b. Technically Proven Uses 154
c. Impact of Government Procurement 156
4. Designation 157
5. Preference Program 157
6. Background for Recommendations 158
7. Specifications 159
C. Awards and Plaques 160
1. Background 160
2. Summary of Comments and Agency's Response 161
3. Rationale for Designation 162
a. Use of Materials in Solid Waste 162
b. Technically Proven Uses 163
c. Impact of Government Procurement 163
4. Designation 164
5. Preference Program 164
6. Background for Recommendations 165
7. Specifications 166
D. Mats 166
1. Background 166
2. Summary of Comments and Agency's Response 167
3. Rationale for Designation 169
a. Use of Materials in Solid Waste 169
b. Technically Proven Uses 169
c. Impact of Government Procurement 170
4. Designation 170
VI
-------
5. Preference Program 171
6. Background for Recommendations 171
7. Specifications 174
E. Signage 174
1. Background 174
2. Summary of Comments and Agency's Response 175
3. Rationale for Designation 175
a. Use of Materials in Solid Waste 175
b. Technically Proven Uses 176
c. Impact of Government Procurement 181
4. Designation 183
5. Preference Program 183
6. Background for Recommendations 184
7. Specifications 187
F. Manual-Grade Strapping 188
1. Background 188
2. Summary of Comments and Agency's Response 189
3. Rationale for Designation 189
a. Use of Materials in Solid Waste 189
b. Technically Proven Uses 190
c. Impact of Government Procurement 194
4. Designation 194
5. Preference Program 194
6. Background for Recommendations 195
7. Specifications 197
XIII. OTHER ITEMS CONSIDERED FOR CPG III DESIGNATION 198
A. Items Still Under Consideration 198
B. Items Dropped from Further Consideration 199
1. Miscellaneous Products Dropped From Consideration 200
a. Recycled Ink 200
b. Shotgun Shells 200
XIV. DESIGNATED ITEM AVAILABILITY 200
XV. ECONOMIC IMPACT ANALYSIS 201
XVI. OTHER SUPPORTING INFORMATION 201
A. Carpet Cushion 201
vii
-------
B. Coal Fly Ash/Foundry Sand/Flowable Fill 201
C. Plastic Lumber 202
D. Playground Equipment 202
E. Compost 202
F. Sorbents 202
G. Signage 203
H. Strapping 203
I. Multimaterial 203
APPENDICES
Vlll
-------
TABLES
Table 1: List of Acronyms 4
Table 2: Draft Recovered Materials Content Levels for Nylon Carpet with Backing Containing
Recovered Materials 35
Table 3: Draft Recovered Materials Content Recommendations
for Carpet Cushion 37
Table 4: Final Recovered Materials Content Recommendations for Bonded Polyurethane, Jute,
Synthetic Fiber, and Rubber Carpet Cushion 42
Table 5: Recovered Materials Content of Carpet Cushion 43
Table 6: Typical Proportions for High Fly Ash Content Flowable Fills 44
Table 7: Typical Proportions for Low Fly Ash Content Flowable Fills 45
Table 8: Recommended Test Methods for Flowable Fills (Controlled Low-Strength Materials) 45
Table 9: Recovered Materials Content of Flowable Fill 60
Table 10: Draft Recovered Materials Content Recommendations for
Railroad Grade Crossing Surfaces 63
Table 11: Final Recovered Materials Content Recommendations for
Concrete, Rubber, and Steel Railroad Grade Crossing Surfaces 73
Table 12: Recovered Materials Content of Railroad Grade Crossing Surfaces 76
Table 13: Draft Recovered Materials Content Recommendations for
Park Benches and Picnic Tables 79
Table 14: Final Recovered Materials Content Recommendations for
Park Benches and Picnic Tables Containing Recovered Aluminum, Steel,
Concrete, or Plastic 88
Table 15: Recovered Materials Content of Park Benches and Picnic Tables 91
Table 16: Draft Recovered Materials Content Recommendations for Playground Equipment ... 94
Table 17: Final Recovered Materials Content Recommendations for Playground Equipment
Containing Recovered Plastic, Steel, or Aluminum 101
Table 18: Recovered Materials Content of Playground Equipment (Nonstructural Pieces) .... 103
IX
-------
Table 19: Draft Recovered Materials Content Recommendations for
Landscaping Timbers and Posts 106
Table 20: Final Recovered Materials Content Recommendations for
Plastic Lumber Landscaping Timbers and Posts 112
Table 21: Recovered Materials Content of Landscaping Timbers and Posts 116
Table 22: Draft Recovered Materials Content Recommendations for Solid Plastic Binders,
Clipboards, File Folders, Clip Portfolios, and Presentation Folders 128
Table 23: Final Recovered Materials Content Recommendations for Solid Plastic Binders,
Clipboards, File Folders, Clip Portfolios, and Presentation Folders 133
Table 24: Recovered Materials Content of Solid Plastic Binders,
Clipboards, File Folders, Clip Portfolios, and Presentation Folders 134
Table 25: Draft Recovered Materials Content Recommendations for Sorbents 135
Table 26: Final Recovered Materials Content Recommendations for Sorbents Used in Oil and
Solvents Cleanups and for Use as Animal Bedding 145
Table 27: Recovered Materials Content of Sorbents 148
Table 28: Draft Recovered Materials Content Recommendations for Industrial Drums 151
Table 29: Final Recovered Materials Content Recommendations for Steel, Plastic, and Fiber
Industrial Drums 157
Table 30: Recovered Materials Content of Industrial Drums 159
Table 31: Draft Recovered Materials Content Recommendations for Awards and Plaques .... 161
Table 32: Final Recovered Materials Content Recommendations for Awards and Plaques
Containing Recovered Materials 165
Table 33: Recovered Materials Content of Awards and Plaques 166
Table 34: Draft Recovered Materials Content Recommendations for Mats 167
Table 35: Final Recovered Materials Content Recommendations for Mats 171
Table 36: Recovered Materials Content of Mats 173
Table 37: Draft Recovered Materials Content Recommendations for Signage 175
-------
Table 38: Final Recovered Materials Content Recommendations for Signs Containing Recovered
Plastic or Aluminum and Sign Posts/Supports Containing Recovered Plastic or Steel 184
Table 39: Recovered Materials Content of Signage 187
Table 40: Draft Recovered Materials Content Recommendations for Strapping 188
Table 41: Final Recovered Materials Content Recommendations for Manual-Grade Polyester,
Polypropylene, and Steel Strapping 195
Table 42: Recovered Materials Content of Strapping 197
XI
-------
I. INTRODUCTION
A. History
The U.S. Environmental Protection Agency (EPA or the Agency) published the first Comprehensive
Procurement Guideline (CPG) on May 1, 1995 (60 Federal Register (FR) 21370). It established 8 product
categories, designated 19 new items, and consolidated 5 earlier item designations. EPA published the first
CPG update (CPG II) on November 13, 1997 (62 FR 60962), and designated an additional 12 products.
On August 26, 1998, EPA published a second proposed update to the CPG and a companion draft
Recovered Materials Advisory Notice (RMAN). This update, hereafter referred to as the proposed CPG III,
proposed to designate 19 new items that are or can be made with recovered materials (see 63 FR 45558),
as follows:
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:
—Plastic Lumber Landscaping Timbers and Posts
—Food Waste Compost
Nonpaper Office Products:
—Solid Plastic Binders
—Plastic Clipboards
—Plastic File Folders
—Plastic Clip Portfolios
—Plastic Presentation Folders
-------
Miscellaneous Products:
—Sorbents
—Industrial Drums
—Awards and Plaques
—Mats
—Signage
—Manual-Grade Strapping
The accompanying draft RMAN III recommended procurement practices for purchasing the 19
items proposed for designation, including recovered materials content levels (see 63 FR 45580, August 26,
1998). Copies of both of these FR notices are located in the Resource Conservation and Recovery Act
(RCRA) Docket F-98-CP3P-FFFFF.
The final CPG III designates 18 of the 19 items and the final RMAN III recommends recovered
materials content levels for these newly designated items. The recommendations are organized into product
categories, which correspond with the categories used in CPG III: construction products, park and
recreation products, landscaping products, non-paper office products, and miscellaneous products. The 18
items designated in the final CPG III include:
Construction Products:
—Carpet Cushion
—Flowable Fill
—Railroad Grade Crossing Surfaces
Park and Recreation Products:
—Park Benches and Picnic Tables
—Playground Equipment
Landscaping Products:
—Plastic Lumber Landscaping Timbers and Posts
—Food Waste Compost
Nonpaper Office Products:
—Solid Plastic Binders
—Plastic Clipboards
-------
—Plastic File Folders
—Plastic Clip Portfolios
—Plastic Presentation Folders
Miscellaneous Products:
—Sorbents
—Industrial Drums
—Awards and Plaques
—Mats
—Signage
—Manual-Grade Strapping
B. Contents of This Background Document
This document, hereafter referred to as the Final CPGIII/RMAN III Background Document,
provides a comprehensive summary of all the supporting analyses used by the Agency to issue the final
CPG III and the final RMAN III. This 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 final CPG III. In addition, the Final CPG III/RMAN III Background
Document lists the recommended procurement practices for the newly designated items, which are also
included in the Final RMAN III, and provides the Agency's detailed response to public comments
received on the proposed CPG III, the draft RMAN III FR notice, and the Background Document for
Proposed CPG III and Draft RMAN III. To avoid confusion with the previous CPGs, the final CPG III and
the final RMAN III will be referred to as CPG III and RMAN III, respectively. Appendices I-V are
referenced in this document. For the convenience of the reader, they are attached as a separate document.
For the reader's convenience, Table 1 lists acronyms referenced throughout this document.
-------
Table 1
List of Acronyms
Acronym
AASHTO
ACAA
ACI
ACR
AEP
AF&PA
APP
APWA
ARTBA
ASTM
EOF
C&D
CAAC
CCC
CFR
CLSM
COAP
CPG
CPSC
DARC
DLA
DOD
DOE
DOT
Term
American Association of State Highway and
Transportation Officials
American Coal Ash Association
American Concrete Institute
Association of Container Reconditi oners
American Electric Power
American Forest and Paper Association
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
Civilian Agency Acquisition Council
Carpet Cushion Council
Code of Federal Regulations
Controlled Low-Strength Material
Coalition for Absorbent Producers
Comprehensive Procurement Guideline
U.S. Consumer Product Safety Commission
Defense Acquisition Regulations Council
Defense Logistics Agency
U.S. Department of Defense
U.S. Department of Energy
U.S. Department of Transportation
-------
Acronym
DRMO
EAF
EO
EPA
FAR
FDA
FHWA
FR
FRA
GPO
GSA
HDPE
HUD
IDOT
ISTEA
IV
LDPE
LDR
LLDPE
LMITCO
MAC
MSW
NIH
NPS
OFPP
OSHA
Term
Defense Reutilization Marketing Office
Electric Arc Furnace
Executive Order
U.S. Environmental Protection Agency
Federal Acquisition Regulation
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
U.S. Department of Housing and Urban
Development
Illinois Department of Transportation
Intermodal Surface Transportation Efficiency
Act of 1991
Inherent Viscosity
Low-Density Polyethylene
Land Disposal Restrictions
Linear Low-Density Polyethylene
Lockheed Martin Idaho Technologies
Company
Multiple Awards Contract
Municipal Solid Waste
National Institutes of Health
National Park Service
Office of Federal Procurement Policy
Occupational Safety and Health Administration
-------
Acronym
PDI
PE
PET
PLTA
PP
PPA
PS
psi
PVC
RCRA
RMAN
SI
SRI
SSCI
TxDOT
UN
USAF
U.S.C.
USDA
USPS
uv
voc
Term
Plastic Drum Institute
Polyethylene
Polyethylene Terephthalate
Plastic Lumber Trade Association
Polypropylene
Promotional Products Association
Polystyrene
Pounds Per Square Inch
Polyvinyl Chloride
Resource Conservation and Recovery Act of
1976
Recovered Materials Advisory Notice
Synthetic Industries
Steel Recycling Institute
Steel Shipping Container Institute
Texas Department of Transportation
United Nations
U.S. Air Force
United States Code
U.S. Department of Agriculture
U.S. Postal Service
Ultraviolet
Volatile Organic Compound
-------
C. Requirements
RCRA Section 6002 and Executive Order 13101 (Executive Order or E.O.) 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 (or the Act) 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 every 2 years 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 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.
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 CPG III is published in
the FR.
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(1) requires each procuring agency
to develop an affirmative procurement program (APP). 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(1),
the APP must contain at least four elements:
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. (See Appendix IV for more
-------
information.) RCRA further requires OFPP to report to Congress every 2 years on actions taken by federal
agencies to implement such policy.
2. Executive Order 13101
Executive Order 13101, Greening the Government Through Waste Prevention, Recycling, and
Federal Acquisition, was signed by President Clinton on September 14, 1998. It replaces Executive Order
12873, Federal Acquisition, Recycling, and Waste Prevention. 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 in the Code of Federal Regulations
(CFR) at 40 CFR Part 247. The Executive Order requires EPA to update the CPG every 2 years.
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 FR 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.
Appendix III provides additional information on the provisions and requirements of Executive Order
13101, including requirements for procuring agencies to comply with EPA's guidelines.
-------
II. ITEM DESIGNATIONS
A. 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.
4. Other uses for the recovered materials used to produce the item.
EPA also consulted with federal procurement and requirements 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 the 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
designated in the CPG III have all been evaluated with respect to the EPA's criteria. Details of these
evaluations are discussed in Sections VIII through XII of this document.
10
-------
1. Use of Materials Found in Solid Waste
All items designated in the 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 designated 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
might 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 designated by EPA is presented in
subsection 3.a., "Use of Materials in Solid Waste," within the individual item designation discussions in
Sections VIII through XII 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.
11
-------
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 designated 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 subsection 3.b., "Technically Proven Uses," in the individual item designation
discussions in Sections VIII through XII 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.
Government procurement also has an impact that extends far beyond the federal, state, and local
levels. As noted in RCRA, 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.
12
-------
Information on the potential impact of government procurement for each new item designated in the
CPG III is presented in subsection 3.c., "Impact of Government Procurement," in the individual item
designation discussions in Sections VIII through XII 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 EPA has designated, including the number of
manufacturers that produce the item, is presented in subsection 3.b., "Technically Proven Uses," in the
individual item designation discussions in Sections VIII through XII 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.
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
13
-------
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, in most cases, it is not
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 designation discussions in Sections VIII through XII 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, 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. (For additional discussion of designating experimental and
developmental products, see EPA's comments on General Accounting Office Report No. B-251080, Solid
Waste: Federal Program to Buy Products with Recovered Materials Proceeds Slowly .)
B. Methodology for Selecting Items for Designation
As described in Section I.C.2, E.G. 13101 directs EPA to propose a CPG and related RMAN. This
section explains the methodology EPA used to select items for designation, including a description of the
process used to obtain information on prospective items.
14
-------
1. Selection of Items for Designation
EPA began its efforts to develop the CPG and RMAN by first creating an interagency working group
consisting of technical, research and development, environmental, and procurement officials from several of
the major federal purchasing agencies. This working group, initiated in 1993, continues to perform a review
function for all CPG-related designations.
In general, the Agency compiles a broad list of potential products made from recovered materials. In
developing this list, EPA consults publicly available sources of information including the "Official Recycled
Products Guide," the General Services Administration's (GSA's) "Recycled Products Guide," and over 50
other information sources, including the Internet. In addition, on September 20, 1995, the Agency issued an
FR notice describing a process by which interested parties could suggest items for designation. That notice
detailed the specific types of information EPA needed to evaluate potential items for designation. (See 60 FR
48714 - 48715.) EPA has, and continues to receive, requests for designation of items in response to this
notice. EPA next distributes its broad list of candidate items to the working group for review and evaluation.
Working group representatives, based on their experiences in setting product specifications and their
knowledge of the marketplace and the procurement practices of their respective agencies, may identify other
items to be added to the candidate list of products. Finally, based on a review of publicly available
information, EPA's own product research, and input from the working group, EPA develops and maintains a
candidate list.
Next, for each item on the candidate list, EPA considers the following questions that relate to the key
criteria described previously in Section II. A:
a. 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?
b. Economic and Technological Feasibility and Performance
Does the item perform as well as necessary to meet a procuring agency's needs?
Are there standards or specifications that would enable a procuring agency to buy the
item containing recovered materials?
15
-------
Is the item available at a reasonable price considering normal market fluctuations?
c. Impact of Government Procurement
Is the item purchased in appreciable quantities by the federal government or by State
and local governments?
d. 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?
For each item meeting one or more of these key criteria, EPA sought additional information and
conducted further analyses to determine whether the item met all or most of the remaining criteria. For some
items, EPA was unable to obtain sufficient information to determine if all or most of the criteria were met.
These items will undergo further research and may be designated at a later date. The items for which EPA
completed its review and which the Agency believes meets all of the evaluation criteria were proposed for
designation in the CPG. Based on the research conducted, EPA proposed designating 19 items in CPG III in
the FR on August 26, 1998, (63 FR 45558) and solicited public comments on the proposed designations.
Based on the public comments received in response to the proposed CPG III, EPA has included 18 of those
items in the final CPG III. All comments received on the proposed designations are summarized and
addressed in the final CPG III FR notice or are presented in Sections VIII through XII of this document.
Section XIII of this document describes those items which were evaluated for possible designation, but which
the Agency believes does not meet the criteria for designation based on the research information gathered.
C. 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 parking stops, 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):
16
-------
"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...."
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.
It is important to note that EPA's designation of an item does not signify that the Agency is
recommending the purchase of an item made from a particular material over a similar item made from a
different material. For example, EPA included the following statement in the preamble discussion for plastic
desktop accessories (59 FR 18879): "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
17
-------
agency, when purchasing plastic desktop accessories, purchase these accessories made with recovered
materials...."
D. 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, and an updated RMAN
(Paper Products RMAN II) was issued on June 8, 1998, at 63 FR 31214. No paper products
are included in the final 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 additional vehicular products are designated in the final 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 the CPG III, EPA designates carpet cushion, flowable fill, and railroad grade crossing
surfaces in the construction products category.
Transportation Products: products used for directing traffic, alerting drivers, and containing
roadway noise and pollution. Examples include parking stops and traffic control devices. No
additional transportation products are designated in the final
CPG III.
Park and Recreation Products: products used in operating and maintaining parks and
recreational areas. Examples include playground surfaces and running tracks. In the CPG III,
EPA designates 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 the CPG III, EPA designates food waste compost and plastic lumber
landscaping timbers and posts in the landscaping products category.
18
-------
Nonpaper 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 the CPG III, EPA
designates 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 the CPG III, EPA designates sorbents, awards and plaques, industrial drums,
manual-grade strapping, mats, and signage in the miscellaneous products category.
III. RECOVERED MATERIALS CONTENT
Under RCRA Section 6002 and Executive Order 13101, EPA is required to make recommendations to
procuring agencies for purchasing the EPA-designated items containing recovered materials. EPA's
recommendations typically include the ranges of recovered materials content levels within which the items are
currently available, relevant specifications, and other information pertinent to purchasing the items containing
recovered materials. The purpose of the recommendations is to assist procuring agencies in fulfilling their
obligations under RCRA Section 6002 and the Executive Order to purchase designated items containing the
highest percentages of recovered materials practicable.
In providing guidance in the RMAN, the Executive Order directs EPA to present "the range of
recovered materials content levels within which the designated recycled items are currently available." Based
on the information available to the Agency, EPA recommends ranges that encourage manufacturers to
incorporate the maximum amount of recovered materials into their products without compromising
competition or product performance and availability. EPA recommends that procuring agencies use these
ranges, in conjunction with their own research, to establish their minimum content standards. In some
instances, EPA recommends that procuring agencies establish a specific level (e.g., 100 percent recovered
materials), rather than a range, because the item is universally available at that recommended level.
While EPA understands that specific minimum recovered content standards might be easier for
procuring agencies to administer than a content range, which necessitates developing their own minimum
content standards, EPA recommends ranges rather than minimum standards for several reasons.
First, the Executive Order directs EPA to develop ranges, not minimum content standards or specific
recovered materials levels.
19
-------
Second, EPA has only limited information on recovered materials content levels for the new items
proposed for designation. It would not be appropriate to establish minimum content standards without more
detailed information, because the standards may be treated as maximum targets by manufacturers and may
stifle innovative approaches for increasing recovered material use. EPA hopes that the use of ranges will
encourage manufacturers producing at the low end of the recovered materials range to seek ways of
increasing their recovered materials usage. Minimum content standards are less likely to encourage such
innovation.
Third, many items are purchased locally rather than centrally. As a result, the recovered materials
content of the items are likely to vary from region to region depending on local cost and availability of
recovered materials. Minimum content standards are unlikely to be effective given the regional variance in
recovered materials content, because minimum content levels that are appropriate for one region may be
excessively high or low for other regions. A recovered materials content range gives regional procuring
agencies the flexibility to establish their own recovered content standards and to make them as high as
possible, consistent with the statute, given local product availability and market conditions.
EPA, once again, wants to stress that the recommendations in the RMAN III are just that—
recommendations and guidance to procuring agencies in fulfilling their obligations under RCRA Section
6002. The designation of an item as one that is or can be produced with recovered materials and the inclusion
of recommended content levels for an item in the RMAN does not compel the procurement of an item when
the item is not suitable for its intended purpose. RCRA Section 6002 is explicit in this regard when it
authorizes a procuring agency not to procure a designated item where the item "fails to meet the performance
standards set forth in the applicable specification or fails to meet the reasonable performance standards of the
procuring agencies." RCRA Section 6002(1)(B), the United States Code (U.S.C.) 42 U.S.C. 6962(c)(B).
Thus, for example, in the final CPG III, EPA has designated playground equipment as an item that is
or can be produced with recovered materials. The Agency's research shows that this item is available in
either steel, aluminum, or plastic containing recovered materials. However, the mere fact that this item is
available containing recovered materials does not require the procurement of steel, aluminum, or plastic
playground equipment in every circumstance. The choice of appropriate materials used may depend on state
or local codes. The effect of designation (and RCRA Section 6002) is simply to require the purchase of items
with recovered materials where consistent with the purpose for which the item is to be used. Procuring
20
-------
agencies remain free to procure playground equipment made of materials other than steel, aluminum, or
plastic (e.g., wood) where the design specifications call for other materials.
A. Methodology for Recommending Recovered Materials Content Levels
EPA identified and evaluated information regarding the percentages of recovered materials available
in the items designated in the CPG III. EPA also gathered and reviewed publicly available information,
information obtained from product manufacturers, and information provided by other federal agencies. Based
on this information, EPA established recovered materials content level ranges for each of the designated
items. In establishing the ranges, EPA's objective was to ensure the availability of the item, while challenging
manufacturers to increase their use of recovered materials. By recommending ranges, EPA believes that
sufficient information will be provided to enable procuring agencies to set appropriate procurement
specifications when purchasing the newly designated items.
It is EPA's intention to provide procuring agencies with the best and most current information
available to assist them in fulfilling their statutory obligations under RCRA Section 6002. To do this, EPA will
monitor the progress made by procuring agencies in purchasing designated items with the highest practical
recovered materials content level and will adjust the recommended content ranges accordingly. EPA
anticipates that the recommended ranges will narrow over time as other items become more available, but for
technical reasons, many items may never be available with 100 percent recovered materials content.
B. Use of Minimum Recovered Materials Content Standards
For most designated items, EPA recommends that procuring agencies establish minimum recovered
materials content standards. For some items, the use of minimum content standards is inappropriate because
the product is remanufactured, reconditioned, or rebuilt (e.g., printer ribbons contained in printer cartridges).
In these instances, EPA recommends that procuring agencies use substantially equivalent alternatives to the
minimum content standards approach as allowed in Section 6002(i)(3) of RCRA. For example, in the case of
printer ribbons, which were designated in CPG II, EPA recommended that procuring agencies adopt one or
both of the following approaches: (1) procure ribbon reinking or reloading services or (2) procure reinked or
reloaded printer ribbons. Minimum content standards are inapplicable, because the recovered material is the
21
-------
expended printer ribbon or the ribbon cartridge, rather than individual materials used to produce the new
printer ribbon.
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 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.
C. Preconsumer Versus Postconsumer Recovered Materials
Preconsumer recovered materials are often easier to incorporate into production processes than
postconsumer recovered materials, because they tend to be more uniform and contain less contamination. For
many items, however, EPA recommends that procuring agencies purchase items containing postconsumer
recovered materials, because one of the RCRA Section 6002(e) criteria for designating items is the potential
impact of the procurement of an item on the solid waste stream. The Agency believes that recommending
postconsumer recovered materials content levels for these items will have the most positive impact on
reducing the amount of solid waste requiring disposal.
For several items, EPA recommends two-part content levels—a postconsumer recovered materials
component and a total recovered materials component. In these instances, EPA found that both types of
materials were being used to manufacture a product. Recommending only postconsumer content levels would
fail to acknowledge the contribution to solid waste management made by manufacturers using other
manufacturers' byproducts or scraps as feedstock.
D. Recommending 100 Percent Recovered Materials Content Levels
EPA recommends 100 percent recovered materials content for some items. Because the RCRA
definition of recovered materials excludes internally generated scrap, it might be construed to suggest that no
manufacturer can claim that its product contains 100 percent recovered materials since all manufacturers use
some internally generated scrap as feedstock. EPA does not support this interpretation.
22
-------
There are two types of internally generated scrap (also known as manufacturer's scrap): scrap
generated in a manufacturing process using only virgin materials and scrap generated in a manufacturing
process using recovered materials as feedstock. EPA believes that scrap generated in a process using
recovered materials as feedstock should be considered differently from scrap generated in a manufacturing
process using only virgin material feedstocks. The Agency allows scrap to be counted as recovered materials
to the extent that the feedstock contains materials that would qualify as recovered materials. Otherwise, there
is an illogical and unnecessary obstacle to the manufacture of products using high levels of recovered
materials. A manufacturer using 100 percent recovered materials should be able to certify that its product
contains 100 percent recovered materials.
E. Calculation of Product Content for Purposes of Certification
RCRA Section 6002(i)(2)(C) requires the affirmative procurement program to include procedures for
estimating, certifying, and, where appropriate, reasonably verifying the amount of recovered materials content
utilized in the performance of a contract. In addition, RCRA Section 6002 requires contracting officers to
obtain from vendors a certification "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." The Federal Acquisition Streamlining Act (Pub. L. 103-355) amended RCRA Section 6002(c)
to require estimates only for contracts in amounts greater than $100,000.
Because each product is different, EPA recommends that procuring agencies discuss certification with
product vendors to ascertain the appropriate period for certifying recovered materials content. EPA
recommends that consistent with federal procurement law requirements, whenever feasible, the recovered
materials content of a product be certified on a batch-by-batch basis or as an average over a calendar quarter
or some other appropriate averaging period as determined by the procuring agencies.
IV. UPDATES OF THE CPG AND RMAN
Section 502 of the Executive Order directs EPA to update the CPG every 2 years and issue RMANs
periodically to reflect changes in market conditions. As previously discussed, on September 20, 1995, EPA
published a notice in the FR establishing a process for the public to suggest items for consideration and to
23
-------
provide information on products made from recovered materials (see 60 FR 48714). That notice also
requested information on items that the Agency should consider for designation. EPA will continue to accept
information from interested parties in response to the September 1995 request for information and will
continue to conduct its own research to identify prospective items for designation as discussed in Section II.B
of this document. The Agency may, at its discretion, propose updates to the CPG at earlier intervals than
every 2 years as required in the Executive Order. Updates to the RMAN will be made periodically to reflect
changes in market conditions with respect to the use of recovered materials in designated items. Interested
parties should, from time to time, access the CPG Web site at for the latest information
on the procurement guidelines program.
24
-------
V. AFFIRMATIVE PROCUREMENT PROGRAMS
An APP is an agency's strategy for maximizing its purchases of an EPA-designated item. RCRA
Section 6002(1) requires that an APP consist of a minimum 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 program.
The information provided in this section was previously provided in CPG/RMAN I and CPG/RMAN
II. It is included here for the convenience of the reader. In CPG III, EPA did not revise the recommendations
for APPs.
Preference programs are discussed in detail in Section B of Appendix V. This section of the document
discusses promotion and monitoring. Certification is discussed in Section III.E of this document.
EPA recommends actions be taken by requesting officials, contracting officials, contracting officers,
architects, and engineers when purchasing designated items. In order to provide maximum flexibility to
procuring agencies when implementing the requirements of RCRA Section 6002, EPA recommends the
Environmental Executive within each procuring agency take the lead in developing the agency's APP and in
implementing the recommendations set forth in the RMAN III.
The basic responsibilities of an Agency Environmental Executive are described in Sections 302 and
402 of the Executive Order. Section 302 of the Executive Order charges each agency's Environmental
Executive with coordinating all environmental programs in the areas of acquisition, standard and specification
revision, facilities management, waste prevention, recycling, and logistics. Section 302 also requires each
agency's Environmental Executive to track and report, to the Federal Environmental Executive, agency
purchases of EPA-designated items. In the absence of an agency's Environmental Executive, 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 Section 6002 and the Executive Order require procuring agencies to establish APPs for each
EPA-designated item. EPA recommends that each agency develop a single, comprehensive APP with a
25
-------
structure that allows for the integration of new items as they are designated. EPA encourages agencies to
implement preference programs for nonguideline items as well, in order to maximize their purchases of
recycled content products and foster markets for recovered materials.
RCRA Section 6002(I)(2)(B) requires each procuring agency to adopt a program to promote its
preference to buy EPA-designated items with recovered materials content. The promotion component of the
APP should educate agency staff and notify an agency's current and potential vendors, suppliers, and
contractors of the agency's intention to buy recycled content products. Therefore, EPA believes that an
agency's promotion program should consist of two components: an internal promotion program and an
external promotion program.
There are several methods that procuring agencies can use to educate employees about their APPs.
These methods include:
Preparing and distributing agency affirmative procurement policies through in-house
publications and electronic mail.
Publishing articles in agency newsletters and on the agency's World Wide Web site.
Including APP requirements in agency staff manuals.
Conducting workshops and training sessions to educate employees about their responsibilities
under agency APPs.
Methods for educating existing contractors and potential bidders of an agency's preference to
purchase products containing recovered materials include publishing articles in appropriate trade publications,
participating in vendor shows and trade fairs, placing statements in solicitations, and discussing an agency's
APP at bidders' conferences.
Procuring agencies should monitor their APPs to ensure that they are fulfilling their requirements to
purchase items composed of recovered materials to the maximum extent practicable. RCRA Section
6002(I)(2)(D) requires the APP to include procedures for annually reviewing and monitoring the
effectiveness of agency APPs. Section 302 of the Executive Order requires the Environmental Executive of
each federal Executive agency to track and report on agency purchases of EPA-designated items.
Additionally, RCRA Section 6002(g) requires OFPP to submit a report to Congress every 2 years on actions
26
-------
taken by federal agencies to implement the affirmative procurement requirements of the statute. Also, Section
301 of the Executive Order requires the Federal Environmental Executive to submit a biennial report to the
President on federal compliance with the Executive Order. In order to fulfill its responsibilities, the Office of
the Federal Environmental Executive requests information from federal agencies on their affirmative
procurement practices. Therefore, it is important for agencies to maintain adequate records of procurements
that may be affected by Executive Order and RCRA requirements.
In order to comply with the Executive Order, federal agencies will need to track their purchases of
products made with recovered materials content. This will also allow them to establish benchmarks from
which progress can be assessed. To maintain adequate records on procurement of products containing
recovered materials, procuring agencies may choose to collect data on the following:
The minimum percentages of recovered materials content in the items procured or offered.
Comparative price information 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 recovered materials content of an item.
EPA recognizes that a procuring agency may be unable to obtain accurate data for all items
designated by EPA. EPA does not believe that this is a problem. Estimated data is likely to be sufficient for
determining the effectiveness of an agency's APP.
27
-------
VI. DEFINITIONS
In the final CPG III, EPA is adding definitions for the following new item-specific terms: carpet
cushion; flowable fill; railroad grade crossing surfaces; park benches and picnic tables; playground
equipment; food waste compost; plastic lumber landscaping timbers and posts; solid plastic binders,
clipboards, file folders, clip portfolios, and presentation folders; sorbents; awards and plaques; industrial
drums; manual-grade strapping; mats; and signage. These definitions are based on industry definitions,
including American Society of Testing and Materials (ASTM) or other standard specifications, or represented
descriptions of the scope of items being designated.
This document contains discussions and recommendations on the recovered materials content levels
and postconsumer materials content levels at which the designated items are generally available. The terms
"postconsumer materials" and "recovered materials" are defined at 40 CFR 247.3. These definitions are
included here for the convenience of the reader.
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 used within the original manufacturing process.
VII. AGENCY'S RESPONSE TO COMMENTS
EPA requested information and public comment on the proposed CPG III and the draft RMAN III. In
general the agency requested comments on: (1) the items selected for designation in the CPG III; (2) the
recommended recovered material content levels for the selected items; (3) the overall accuracy of the
information presented in the proposed item designations; (4) and several specific issues pertaining to
particular products. Requests for the specific comments and information were included in the narrative
discussions for each of the items proposed for designation.
28
-------
EPA received 40 comments on the proposed CPG III and draft RMAN III. Comments addressed issues
for items in the construction, park and recreation, landscaping, non-paper office, and miscellaneous products
categories. These comments covered a variety of topics including recovered materials content levels, item
designation, terminology, and the accuracy of information presented. EPA carefully considered all of these
comments in developing the final CPG III and the RMAN III. A summary of the comments, including those
on specific item designations, and the Agency's responses are provided in the sections that follow.
Based on comments received on nylon carpet with backing containing recovered material, EPA is not
designating this item at this time. EPA will continue to monitor activity in the industry to determine whether
designation is appropriate for a future update.
EPA received general comments pertaining to item designations, recordkeeping, and the recovered
materials content of steel used in the items proposed (and previously designated) by EPA. These comments
and the Agency's response are summarized in the following subsections.
A. Request for Comments
In the draft RMAN III notice, EPA requested specific comments on whether any specifications exist or
are appropriate for park benches or picnic tables made from steel or aluminum containing recovered
materials; awards or plaques containing recovered materials; and mats containing recovered materials. EPA
did not receive any comments in response to this request.
In the proposed CPG III notice, EPA stated that it had considered two items (recycled ink and shotgun
shells) and determined that it was inappropriate to designate these items (63 FR 45574). EPA requested
additional information demonstrating whether these items should be reconsidered for possible future
designation. No comments were submitted on these items or on EPA's decision not to designate these items.
EPA has received letters from one recycled ink manufacturer, separate from the FR notice request, requesting
that ink be reconsidered for designation. However, no additional information has been submitted by this
company despite repeated requests by the Agency.
29
-------
B. Comments Recommending Additional Items for Designation
Comment: The Association of NJ Recyclers submitted comments supporting the inclusion of all 19
proposed products. It believes, however, the $10,000 threshold is too high and should be reduced. The
association also suggested several additional items for designation including mixed cullet glass for use as
storm drainage aggregate; toner cartridges; highway safety cones, barriers, barrels, and barricades; running
tracks, roadway application, and playground matting made from recycled tires; recycled steel highway
guardrails; recycled-content roadway sound barriers; recycled aggregates; landscape mulch made from
recycled roots and stumps; screened top soil made from roots and stumps; and recapped tires. The commenter
provided no additional information supporting such designations, however. In addition, the commenter
encouraged EPA to use performance-based specifications rather than item names or descriptions for the
designations, as they allow equal competition amongst virgin- and recycled-content manufacturers. The
commenter further stated that the use of performance-based standards are the leading reason that recycled
content items have been allowed to be used on projects.
Response: Some of the items suggested for designation by the Association of NJ Recyclers have
already been designated by EPA, including toner cartridges, channelizers, delineators, traffic cones, traffic
barricades, running tracks, and playground surfaces. On September 20, 1995, EPA published an FR notice
detailing the procedure for public participation in the designation process, including the types of information
the Agency evaluates in designating an item. (See 60 FR 48714.) EPA encourages the association to submit
the requisite information for the other items they believe should be designated. After receipt of this
information, EPA will consider the items in future revisions to the CPG as time and resources allow.
Notwithstanding this request for additional information, the Agency will consider evaluating these items for
possible inclusion in future amendments to the CPG.
With respect to the commenter's suggestion that the Agency use performance-based standards instead
of item names to promote the use of recycled-content items, the Agency notes that once items are designated
by EPA, procuring agencies are required to review and revise their specifications and their APPs to ensure
items containing recovered materials are equally considered in procurements. In addition, use of item names
provides the benefit of informing all procurement personnel (regardless of their experience and training) of
their obligations under the guidelines.
30
-------
With respect to the Association's comments regarding the $10,000 threshold, the Agency notes that
this figure is defined by statute and cannot be changed by EPA.
Comment: The Steel Recycling Institute (SRI) and the Steel Manufacturers Association submitted
separate comments in support of EPA's proposed designation of items containing recovered steel (i.e.,
railroad grade crossings surfaces, park and recreational furniture, playground equipment, industrial drums,
signage, and strapping). SRI also urged EPA to recognize (i.e., designate) steel in general for its high
recyclability and guaranteed recycled content. The American Iron and Steel Institute and the American Zinc
Association also submitted comments endorsing the comments provided by SRI.
SRI provided updated information for use in the "Summary of Benefits" section of the FR notice,
stating that its latest study shows that for every ton of steel recycled, 1,400 pounds of coal and 120 pounds of
limestone are saved, versus 1,000 pounds of coal and 40 pounds of limestone stated in EPA's notice (63 FR
45575).
SRI also commented on the postconsumer and recovered materials content levels of steel proposed by
EPA. This comment is addressed in Section D below.
Response: EPA agrees that steel, like many metals, is both recyclable and can contain recovered
materials. EPA also agrees that steel, like many metals, is a waste management success story in terms of its
recyclability, high recycling rate, and recovered materials content. EPA also applauds the steel industry's
source reduction efforts to produce stronger, lighter weight steel, in response to customer demand. RCRA,
however, specifically requires EPA to designate items that are or can be made with recovered materials, not
the component materials used in those items. Accordingly, EPA designates items that are manufactured with
steel, not the material itself.
With respect to the new data provided by SRI for coal and limestone savings resulting from the use of
recovered steel in manufacturing, EPA has incorporated this information in all applicable documents
supporting the final CPG/RMAN III.
Comment: The Utilities Solid Waste Activities Group, in addition to supporting EPA's proposed
designations of flowable fill and railroad grade crossings, also submitted comments recommending EPA
11
-------
consider designating abrasives containing recovered boiler slag generated from the combustion of coal and
lightweight aggregates containing fly ash in the CPG.
Response: EPA is currently researching a number of items for future designation in the CPG and will
consider abrasives and lightweight aggregates containing various materials as time, resources, and available
information allow.
Comment: The Tennessee Valley Authority, in addition to supporting EPA's proposed designations of
flowable fill and railroad grade crossings, also submitted comments recommending that EPA consider
designating other items containing coal byproducts, such as boiler slag and bottom ash.
Response: EPA continues to evaluate additional items for designation in the CPG and will consider
items containing coal byproducts as time, resources, and available information allow.
C. Recordkeeping and Reporting Requirements
Comment: The U.S. Department of Energy (DOE) stated that it supports efforts to conserve resources
by procuring products containing recovered materials. DOE stated that it has aggressively instituted an APP
throughout the Department. DOE expressed its concern, however, that as the number of designated items
increases, the administrative costs of the program will become increasingly burdensome. DOE believes that as
reporting requirements and data collection logistics continue to grow with additional designations, there is a
likelihood that the good will and positive environmental message of E.O. 13101 will be misplaced. DOE
suggested that EPA seek to revise the Federal Acquisition Regulation (FAR) to channel federal purchasing
toward products with recycled content. This way, federal agencies could report progress in implementing the
FAR language, as opposed to attempting to capture every purchase made by the federal government.
Response: EPA has stated on many occasions that implementation of RCRA Section 6002 must be
consistent with other federal procurement law. For example, in Appendix II to the "Background Document
for Proposed Comprehensive Procurement Guideline (CPG) III and Draft Recovered Materials Advisory
Notice (RMAN) III," April 1998, EPA stated the following:
32
-------
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....
On August 22, 1997, the Civilian Agency Acquisition Council (CAAC) and the Defense
Acquisition Regulations Council (DARC) issued a final rule amending the 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-efficient products and services and to establish an
affirmative procurement program favoring items containing the maximum practicable content
of recovered materials. (See 62 FR 44809, August 22, 1997.)
EPA refers procuring agencies to the FAR for guidance regarding acquisitions issues.
In addition, the Office of the Federal Environmental Executive has established a Reporting
Workgroup and associated subcommittees to examine issues associated with recordkeeping and reporting.
Topics of discussion have included the potential for automated systems and electronic commerce, vendor
reporting, as well as other alternatives. It is the intent of these efforts that, through the use of interagency
workgroups, reporting and recordkeeping requirements can be effectively and efficiently implemented.
Presumably, if such workgroups determine that additional FAR changes are warranted, such changes could be
proposed through the process and procedures already established for amending the FAR.
D. Recommended Recovered Materials Content Levels
Comment: SRI noted that all items proposed for designation (with the exception of industrial drums)
could be manufactured with steel made by both Basic Oxygen Furnace (EOF) and Electric Arc Furnace (EAF)
processes. SRI noted that items made by the EOF process typically contain 25 to 30 percent recovered
materials including more than 15 percent postconsumer steel. When these items are made out of steel
manufactured by the EAF process, they may contain up to 100 percent recovered materials, including 67
percent postconsumer steel. SRI suggested EPA recommend recycled content levels of 16 percent
postconsumer and 25 percent total recovered content for all items made from EOF steel and 67 percent
postconsumer and 100 percent total recovered content when items are made from EAF steel. SRI pointed out
that currently, industrial drums are only being made from EOF steel and, therefore, contain a total of 25
percent total recovered steel, including 16 percent postconsumer steel. SRI requested that, for all items
proposed in CPG III containing steel, the final RMAN III should reflect these recovered materials content
levels.
33
-------
Response: EPA has included the recommended recovered materials content levels for steel in the final
RMAN notice to reflect SRI's comments regarding EOF and EAF manufactured steel for the items designated
in the CPG, with one exception. Rather than recommend a single total recovered materials content level of 25
percent for items made from EOF steel, the Agency is recommending a range of 25 to 30 percent. The use of
recovered materials content range in this instance reflects both the information provided by SRI and the
requirements of E.O. 13101 for such recommendations. Based on this new industry information, EPA has
revised the content level recommendations for the steel component of traffic barricades and delineators, steel
recycling containers and waste receptacles, and for steel shower and restroom dividers/partitions to reflect
SRI's comments. These items were designated in CPG I and CPG II. Revisions for these items are reflected in
Tables C-6, D-l, D-3, and G-l. No other revisions to the recommendations for items previously designated in
CPG I and CPG II are being made at this time.
E. Other Comments
Comment: GSA indicated that all references to E.O. 12873 should be changed to E.O. 13101.
Response: EPA notes that E.O. 13101 was signed on September 14, 1998, which was during the
public comment period for the proposed rule. The provisions in E.O. 13101 do not alter EPA's basic
requirement to issue procurement guidelines. The primary change brought about by this Order, as it pertains
to the guidelines, is that the Order requires EPA to issue procurement guidelines every 2 years instead of
annually. EPA agrees with the commenter that reference to the new E.O. should be contained in the final
CPG/RMAN III. The Agency has included reference to E.O. 13101 as appropriate in the final notices and
supporting documents.
34
-------
VIII. CONSTRUCTION PRODUCTS
A. Nylon Carpet with Backing Containing Recovered Materials
1. Background
In §247.12(h), EPA proposed to designate nylon carpet with backing containing recovered materials.
In Section C-8 of the accompanying draft RMAN, EPA recommended that carpet backing contain the
following levels of recovered materials:
Table 2
Draft Recovered Materials Content Levels for Nylon Carpet with
Backing Containing Recovered Materials
Material
Old carpets
Postconsumer content (%)
35-70
Total recovered materials content
(%)
100
Note: EPA's recommendation does not preclude a procuring agency from purchasing broadloom carpet or carpet tiles made from another material
such as wool. It simply requires that procuring agencies, when purchasing nylon broadloom carpet or carpet tiles, purchase these items made
with backing containing recovered materials when they meet applicable specifications and performance requirements. Refer to Section C-4 in
RMAN I for EPA's recommendations for purchasing polyester carpet containing recovered materials.
2. Summary of Comments and Agency's Response
EPA received several comments opposing the proposed designation of nylon carpet with backing
containing recovered materials. As explained in this section, the Agency has concluded that at this time there
is insufficient evidence to support a designation and that more research is required before designation can
occur. In the final CPG III, therefore, EPA is withdrawing the proposed carpeting backing designation.
Comments: EPA received six comments in opposition to the proposed designation of nylon carpet
with backing containing recovered materials. These commenters all stated that there is only one manufacturer
currently making nylon carpet backing with recovered materials content. They indicated that the manufacturer
uses a patented process and, therefore, a designation is premature and does not meet the statutory
requirements for adequate competition when designating items.
35
-------
Response: EPA proposed to designate nylon carpet with backing containing recovered materials based
on the fact that at the time of the proposal, one manufacturer was producing carpet tiles with backing
containing recovered materials commercially and, as the Agency stated in the background document, that two
other manufacturers were piloting production runs with recovered materials content and were expected to enter
the marketplace. As a result of this comment, EPA sought additional information and found that, since the
proposal, significant developments have occurred in the carpet industry with respect to the use of recovered
materials in nylon carpet backing and the fiber facing. As an example, one company is currently making what
they call "renewed" carpet tiles. The company takes old carpet and, through a series of process steps, which
include supercleaning, retexturing of fibers, and adding colors and patterns, makes renewed carpet tiles. In
addition, many companies have begun or are expected to begin manufacturing nylon carpet tiles with
recovered materials in the fiber facing. Based on the fact that significant developments have occurred with
respect to the use of recovered materials in the nylon carpet industry, the Agency believes additional research
should be conducted before a final designation for nylon carpet or nylon carpet backing is issued to ensure
these developments are given proper consideration. The Agency, therefore, is not at this time designating this
item, but will consider designating nylon carpet products in the next procurement guideline (CPGIV).
Although the Agency is not designating this item at this time, procuring agencies may choose to
procure any item containing recovered materials, regardless of whether the item is specifically designated by
EPA. Procurement of items containing recovered materials, whether or not they are designated by EPA, is
consistent with RCRA Section 6002 and E.G. 13101.
Comments: Three commenters suggested EPA consider designating nylon carpet containing recovered
materials in the carpet fiber facing, not the backing.
Response: The Agency notes that it researched the possible designation of nylon carpet containing
recovered materials in the carpet fiber facing a few years ago and determined that, at that time, it was not
commercially available. Since that time, however, it appears that significant progress has been made in the
industry, which warrants a reevaluation of this item. EPA will consider designating nylon carpet containing
recovered materials in the carpet fiber facing for possible inclusion in the next procurement guideline (CPG
IV).
36
-------
Comment: Collins and Aikman noted a change that occurred recently in the contract number for their
carpeting containing recovered content backing. The GSA number has changed from GS-OOF-8453-A to GS-
27F-8453-A.
Response: As noted by the commenter, carpeting containing recovered content backing is currently
available through GSA contracts from one manufacturer. Procuring agencies seeking to buy this item should
note the revised contract number. EPA believes the purchase of this item complies with the intent of both
RCRA 6002 and E.O. 13101, even though the Agency does not feel it should be designated at this time.
B. Carpet Cushion
1. Background
In §247.12(1), EPA proposed to designate carpet cushion. In Section C-9 of the accompanying draft
RMAN III, EPA recommended that carpet cushion contain the levels of recovered materials shown in Table 3.
Table 3
Draft Recovered Materials Content Recommendations for Carpet Cushion
Product
Bonded
polyurethane
Jute
Synthetic fibers
Rubber
Material
Old carpet cushion
Burlap
Carpet fabrication
scrap
Tire rubber
Postconsumer
content (%)
15-50
40
—
60-90
Total recovered materials
content (%)
15-50
40
100
60-90
Note: EPA's recommendations do not preclude a procuring agency from purchasing another type of carpet cushion. They simply require that
procuring agencies, when purchasing bonded polyurethane, jute, synthetic fiber, or rubber carpet cushions, purchase these items made with
recovered materials when these items meet applicable specifications and performance requirements. Refer to Section C-4 in RMAN I for EPA's
recommendations for purchasing polyester carpet containing recovered materials.
EPA received two comments supporting the designation of carpet cushion and one comment
regarding the postconsumer content levels in synthetic fiber pads. The commenter that submitted the
comment regarding postconsumer content levels, however, did not submit additional information. Therefore,
37
-------
in the final CPG III, EPA is designating carpet cushion. In the final RMAN III, EPA is retaining the draft
recommendations for the content levels for carpet cushion as indicated below.
2. Summary of Comments and Agency's Response
Comments: DOE and GSA submitted comments supporting the designation of carpet cushion. DOE
also indicated that one of its sites recycles polyurethane from shipping containers and sells it to a local
manufacturer that uses it in its carpet cushion. GSA indicated that "72 I A" should be added after "GSA
schedule" on page 45562, paragraph 2c, line 9 of the proposed CPG notice. In addition, GSA suggested that
EPA address the ash content present in many urethane and rubber cushions as recycled content, but did not
provide any additional information.
Response: EPA notes that the carpet is available on GSA schedule 72 I A. EPA did not consider the
ash content in urethane and rubber cushions in making its recommendations. With respect to the ash content
of urethane and rubber cushions, it is the Agency's understanding that ash is generally used as filler in the
original manufacturing process for prime, densified prime, and high-density urethane and not for bonded
urethane, which was the subject of EPA's draft recommendations. Ash content, therefore, is not applicable in
the case of carpet cushion made from bonded urethane.
Comments: AlliedSignal submitted comments on EPA's proposed recovered materials content
recommendations suggesting that Table C-9 in the draft RMAN III be modified to include a minimum
postconsumer recycled content in synthetic fiber pad ranging between 25 and 100 percent. AlliedSignal
indicated that currently, most of the nylon 6 carpet that is recycled is used to make engineering resins or
synthetic fiber pad. AlliedSignal did not provide any other information to justify its request.
In a related comment, the Total Recycling Association contended that the reason there is no
postconsumer carpet fabrication scrap in the market is because the fabricating companies refuse to buy this
material, despite the fact that almost all the scrap is very recyclable. The commenter claimed that in
California, for example, there is more textile scrap available for shredding than there are markets for textile
pad. The Association believes that rebond is at least capable of being processed a second time unlike textile-
based padding. The commenter further stated that carpet pad manufacturers do not know how to expand the
38
-------
market for their materials and that they are typically small firms with little or no research and development
budgets.
Response: EPA based its recovered materials content recommendations on information obtained from
its research and published as background material for the draft RMAN III. Based on this research, EPA did
not identify any companies manufacturing products of synthetic fibers containing postconsumer materials;
rather, all companies for which EPA has information use preconsumer materials (otherwise known as
postindustrial scrap) and not postconsumer materials. The Agency, therefore, believes it cannot recommend
postconsumer content levels at this time without additional information that demonstrates the prevalence of
postconsumer material use in the industry. EPA is required by RCRA Section 6002 and E.O. 13101 to revise
its RMAN recommendations periodically. EPA will monitor market conditions and consider proposing
postconsumer content levels for synthetic fibers in subsequent revisions to the RMAN based on any available
information obtained.
Comment: AlliedSignal also stated that the CPG should suggest that carpet be recycled when being
replaced.
Response: EPA agrees that recommending carpet be recycled when it is replaced would further
promote the recycling of old carpet and would be consistent with the intent of both RCRA and the E.O. In
accordance with RCRA Section 6002 and E.O. 13101, however, recommendations in the RMAN are subject
to notice and public comment before any final recommendations can be issued in the RMAN. Accordingly,
EPA will consider issuing this recommendation in a future draft RMAN.
3. Rationale for Designation
EPA believes that carpet cushion satisfies the statutory criteria for selecting items for designation, a.
Use of Materials in 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.
39
-------
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. Technically Proven Uses
Manufacturers indicated that their recycled materials 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
Carpet Cushion Council (CCC). These standards include requirements for density, thickness, tensile strength,
and elongation. 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 materials 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 materials 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.
EPA identified 12 companies that manufacture recycled materials content carpet cushion. They are
located throughout the country, and their products are available through distributors nationwide.
40
-------
c. Impact of Government Procurement
GSA offers four different types of cushion on its carpet schedule (GSA schedule 72 I A): 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 materials content
rubber carpet cushion.
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
materials content cushion purchased. The agency has been using recovered content cushion since 1986. The
state of Florida also has installed 100 percent recovered materials 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 materials content cushion.
4. Designation
EPA is designating carpet cushion made from bonded polyurethane, jute, synthetic fibers, or rubber
containing recovered materials. This designation does 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.
41
-------
5. Preference Program
EPA is recommending the draft RMAN recommendations in the final RMAN III. Table 4 shows the
final recommendations for carpet cushions made of bonded polyurethane, jute, synthetic fiber, and rubber.
Table 4
Final Recovered Materials Content Levels for Bonded Polyurethane, Jute, Synthetic Fiber, and Rubber
Carpet Cushion
Product
Bonded
polyurethane
Jute
Synthetic fibers
Rubber
Material
Old carpet cushion
Burlap
Carpet fabrication
scrap
Tire rubber
Postconsumer
content (%)
15-50
40
—
60-90
Total recovered materials
content (%)
15-50
40
100
60-90
Note: EPA's recommendations do not preclude a procuring agency from purchasing another type of carpet cushion. They simply require that
procuring agencies, when purchasing bonded polyurethane, jute, synthetic fiber, or rubber carpet cushions, purchase these items made with
recovered materials when these items meet applicable specifications and performance requirements. Refer to Section C-4 in RMAN I for EPA's
recommendations for purchasing polyester carpet containing recovered materials.
6. Background for Recommendations
Carpet cushion, also known as carpet underlay, is padding placed beneath carpet. According to the
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 thicknesses—the most common being 1/4- and 1A- inch—and 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.
42
-------
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.
Table 5 provides information on the availability of carpet cushion made of recovered materials.
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: 20
Company G: 65-80
Company H: 92
Company I: 80
Company J: 40
Company K: Unknown
85
Unknown
100
90
Unknown
70
Unknown
Unknown
Unknown
Unknown
80
7. Specifications
EPA is not aware of any performance specifications for carpet cushion.
43
-------
c.
Flowable Fill
1. Background
In §247.12(j), EPA proposed to designate flowable fill containing coal fly ash and/or ferrous foundry
sand. In Section C-10 of the accompanying RMAN III, EPA recommended that procuring agencies refer to
the mix proportions shown in Tables 6 and 7 for typical proportions for high and low coal fly ash content
mixtures.
Table 6
Typical Proportions for High Fly Ash Content Flowable Fills
Component
Fly ash (95%)
Cement (5%)
Added water
Range
kg/m3 (lb/yd3)
949 to 1542 (1600 to 2600)
47 to 74 (80 to 125)
222 to 371 (375 to 625)
Total:
Mix Design
kg/m3 (lb/yd3)
1234 (2080)
62(104)
247 (416)*
1543 (2600)
* Equal to 189 liters (50 gallons)
Source: "Fly Ash Facts for Highway Engineers," FFfWA-SA-94-081, U.S. Department of Transportation, Federal Highway Administration,
August 1995.
44
-------
Table 7
Typical Proportions for Low Fly Ash Content Flowable Fills
Component
Fly ash (6% to 14%)
Cement
Sand
Added water
Range
kg/m3 (lb/yd3)
119 to 297 (200 to 500)
30 to 119 (50 to 200)
1483 to 1780
198 to 494 (333 to 833)
Total:
Mix Design
kg/m3 (lb/yd3)
178 (300)
59(100)
1542 (2600)
297 (500)}
2076 (3500)
High calcium fly ash is used in lower amounts than low calcium fly ash.
J Equal to 227 liters (60 gallons)
Source: "Fly Ash Facts for Highway Engineers," FHWA-SA-94-081, U.S. Department of Transportation, Federal Highway Administration,
August 1995.
EPA recommended that procuring agencies use ACI229R-94 when developing mix designs for
flowable fill containing coal fly ash and/or foundry sands. In addition, EPA recommended procuring agencies
refer to ASTM C 33-93 "Standard Specification for Concrete Aggregates" for appropriate gradation
requirements for ferrous foundry sands used in flowable fill, as well as the test methods shown in Table 8.
Table 8
Recommended Test Methods for Flowable Fills (Controlled Low-Strength Materials)
ASTM Specification Number
D4832-95el
D 5239-92
D 5971-96
D 6103-07
D 6023-96
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 CLSM
Standard Test Method for Flow Consistency of CLSM
Standard Test Method for Unit Weight, Yield, Cement Content
and Air Content (Gravimetric) of CLSM
45
-------
ASTM Specification Number
D 5971-96
D 6024-96
Title
Standard Practice for Sampling Freshly Mixed CLSM
Standard Test Method for Ball Drop on CLSM to Determine
Suitability for Load Application
EPA received 18 sets of comments on its proposal to designate flowable fill and the RMAN
recommendations. Since the proposed designation included flowable fill containing both coal fly ash and/or
ferrous foundry sands, some of the comments received pertained only to one or the other recovered material.
All of the comments and the Agency's responses are summarized in the following subsections. As explained
in the Agency's responses, EPA is designating flowable fill in the final CPG III. In the final RMAN III, EPA is
modifying the draft recommendations regarding standards and specifications procuring agencies should refer
to, based on a comment submitted by the FIRST (Foundry Industry Starts Today) Project, an industry
consortium.
2. Summary of Comments and Agency 's Response
Flowable Fill Containing Coal Fly Ash
Comments: EPA received 15 sets of comments in support of designating flowable fill containing coal
fly ash. In general, the commenters suggested that the designation of this item could greatly expand the end-
use markets for coal fly ash while reducing the need for excavating other raw materials and reducing the
amount of coal fly ash requiring disposal in landfills. One of the commenters also encouraged EPA to
consider including other coal byproduct materials, such as boiler slag and bottom ash, in its designations and
offered to provide additional information on the use of these materials.
Response: EPA will continue to evaluate items containing recovered materials in its efforts to
designate additional items in the CPG and provide recommendations in the RMAN. The Agency has
established a means by which interested parties can suggest procurement guideline items and published this
process in the FR on September 20, 1995, at 60 FR 48714. That notice clearly identifies the criteria used and
the type of information required by the Agency in order to evaluate potential items for designation. The
46
-------
Agency will review and act on any information provided in response to that notice as time and resources
allow.
Comment: One of the commenters who expressed support for the designation of flowable fill
containing coal fly ash also suggested that EPA combine this designation with the Agency's previous
designation for cement and concrete containing fly ash and call the designation "Concrete and Flowable Fill
Containing Fly Ash" to simplify reporting requirements.
Response: The Agency will consider consolidating designations in future amendments to the CPG
where it appears appropriate and as time and resources allow.
Comment: One of the commenters who expressed support for the designation of flowable fill
containing coal fly ash also renewed a previous request for the Agency to evaluate the designation of
industrial abrasives containing boiler slag and the use of coal fly ash in lightweight aggregates.
Response: EPA is researching a number of items for potential designation in future amendments to the
CPG. Both industrial abrasives and aggregates are among those items under consideration.
Flowable Fill Containing Ferrous Foundry Sands
EPA received five sets of comments specific to the proposed designation of flowable fill containing
ferrous foundry sands.
Comment: The FIRST Project supported EPA's designation of flowable fill containing foundry sand,
with a few comments. The FIRST Project took issue with EPA's statement that nonferrous foundry sands are
typically hazardous waste due to their lead and cadmium content (63 FR 45563). The FIRST Project
maintains that spent sand from the vast majority of nonferrous foundries is not hazardous, nor does it
contain lead and cadmium. Analytical data from nonferrous foundry sand samples were provided to support
the commenter's position. According to the FIRST Project, due to changes in alloy chemistries of many
nonferrous foundry operations over the past decade, spent sands meet EPA and state definitions of
nonhazardous waste. The FIRST Project, therefore, requested that EPA correct the statement about
nonferrous sand being hazardous waste. The commenter also suggested that the American Foundrymen's
47
-------
Society be listed as another resource for obtaining information regarding the use of spent foundry sand in
flowable fill.
Response: EPA based its statement regarding the hazardousness of nonferrous foundry sands on
industry data provided to the Agency in 1995 as part of the Phase IV Land Disposal Restrictions (LDR)
rulemaking (60 FR 43654, August 22, 1995). These data indicated that the sands from 98 percent of bronze
and brass foundries and 40 percent of bronze and brass and aluminum foundries were characteristically
hazardous wastes for metals.
The commenter's analytical data did not support their claim that a majority of nonferrous foundry
sands are nonhazardous because in numerous cases improper test methods were used. First, for 8 of 12
aluminum green sand waste samples, the digestion of the sample uses SW-846 Method 3010A or Method
3020A (both normally used for water), instead of Methods 3050 and 3051 (both used for solids). (The other
4 aluminum green sand samples did use Method 3051.) These digestion methods are weaker and would
extract less of whatever metals were present in the waste matrix. In addition, virtually all of the
commenter's leachate extraction data on spent sand waste samples were done using either the Synthetic
Precipitation Leaching Procedure SW-846 Method 1312, which relies on nitric/sulphuric acid as the
extractant or deionized water, rather than the Toxicity Characteristic Leachate Procedure SW-846 Method
1311, which the Agency uses to determine toxicity for purposes of assessing hazardousness under 40 CFR
261.24. Therefore, the commenter's leachate extraction data are not appropriate for determining whether
the samples tested are characteristically hazardous.
The Agency agrees with the commenter, however, that the statement in the proposed CPG III was
too general and may have implied a conclusive determination as to the regulatory nature of nonferrous
foundry sands. This clearly was not the intent of the narrative. Therefore, the Agency has removed any
characterization of nonferrous foundry sands as hazardous in the final CPG III and all supporting
documents.
The Agency agrees with the commenter that the American Foundrymen's Society should be
identified as a resource for obtaining information regarding the use of spent foundry sand in flowable fill and
will ensure this reference is made in all documents supporting the final CPG/RMAN III where appropriate.
48
-------
Comment: The FIRST Project also suggested that there is an inconsistency with two of the
specifications listed in the RMAN for flowable fill. ASTM's C33-93 Concrete Aggregate specification limits
the use of some spent sands that have fines content greater than 3 to 5 percent, while ACI 229R-94 indicates
that foundry sands with up to 20 percent fines were successfully utilized in flowable fill mix designs. The
commenter believes that recommending ASTM C33-93 effectively limits the use of this material without
taking into account whether the performance specification is clearly met. The commenter suggests that the
mix design specification should be based on performance, not simply on the aggregate.
Response: EPA has learned that ASTM C33-93 was developed to optimize the strength and
compactability of concrete and was not meant to be used with controlled low-strength material or flowable
fill. The Agency, therefore, recognizes that ASTM C33-93 may not be an appropriate specification for sands
used in flowable fill. Procuring agencies may wish to use this specification's physical tests as a measure to
assure the quality and uniformity of the sands used in flowable fill; however, the agency now believes that
this specification should not be referred to for gradation requirements. Based on this information, the final
RMAN III for flowable fill has been revised to delete any reference to the use of ASTM C33-93 for gradation
purposes. The RMAN recommends that procuring agencies "refer to ASTM C33-93, "Standard Specification
for Concrete," to assure the quality and uniformity of the ferrous foundry sands in flowable fill...."
Comment: The FIRST Project commented that applications for the use of flowable fill should be
broadened to include structural fill for foundation subbases, subfootings, floor lab bases, and pipe beddings.
Response: EPA's designation in the CPG and recommendations in the RMAN do not preclude
procuring agencies from using flowable fill in the applications suggested by the commenter. If flowable fill
meets the requisite specifications and performance standards for a particular application, then flowable fill can
be considered for use by a procuring agency. The specifications and test methods identified in the RMAN are
provided for the convenience of assisting procuring agencies in their procurement efforts. If, in developing its
affirmative procurement program (APP), a procuring Agency wants to include other applications for flowable
fill, it can exercise its discretion in doing so without being restricted to the applications recommended by EPA
in the RMAN. EPA is required to revise its RMAN recommendations periodically and will consider the
applications suggested by the commenter in future revisions. Any recommendations made by EPA, however,
must be subject to notice and public comment. EPA at this time requests that commenters provide any
pertinent information on the suggested applications, including references to any industry
49
-------
specifications and test methods germane to the various applications. We will consider all information
received in our deliberations related to updating our RMAN recommendations.
Comment: The Federal Highway Administration (FHWA) submitted comments stating its concern that,
based on one of its user guidelines, there might be a problem with foundry sand stockpile water being
contaminated with phenols and, that if this is the case, there would be a discrepancy between this and the
CPG statement that ferrous foundry sands are not known to be a hazardous waste. The commenter provided
no information or analytical data to substantiate their statement. The commenter requested that this issue be
addressed, as they could not support this designation if it placed an undue burden on state departments of
transportation to monitor each site or if it necessitates mitigation by contractors.
Response: EPA is aware that phenols may be present in some ferrous foundry sands. According to a
1989 study sponsored by the American Foundrymen's Society and conducted by the University of Wisconsin,
phenols were present in some ferrous foundry sands well below regulatory levels, so the Agency has no
reason to believe there is reason for concern. In addition, the designation of flowable fill containing ferrous
foundry sands in the CPG does not exempt these sands from regulatory control if phenols, or any other
regulated contaminants, are present at levels of regulatory concern. EPA's designation does not change the
regulatory management obligations for the recovered material nor does it in any way suggest that the
materials are relieved from waste management regulations. The determination as to whether the sands contain
contaminants at regulatory levels should be made in accordance with all applicable federal and state
regulations and, thus, no additional burden would be placed on any entity to monitor stockpiles as a result of
a final designation for this item in the CPG. All actions relating to determining the regulatory status of these
sands would be performed by generators or those manufacturing flowable fill, not by those using a
commercial product.
Comment: Lockheed Martin Idaho Technologies Company (LMITCO) commented that EPA's
guidelines for concrete containing fly ash and flowable fill containing fly ash are similar and that EPA should
consider combining the two designation as "Concrete and Flowable Fill Containing Fly Ash" to simplify
reporting.
Response: EPA will consider making this change, and other consolidations to its designations, in
future amendments to the CPG as time and resources allow.
50
-------
Comment: The Illinois Department of Transportation (IDOT) submitted comments expressing
opposition to the use of ferrous foundry sands in flowable fill since, according to IDOT, these sands are
normally contaminated with oil. The commenter did not provide any information or data to substantiate this
claim. IDOT believes the use of coal fly ash in flowable fill is logical because it has an acceptable track
record. IDOT stated that little research has been done on ferrous sand and that its use has been minimal.
EPA contacted the commenter to ascertain the basis for their comment and was told that since the
comment was submitted, IDOT has learned that "oil contamination is not always present."
Response: As stated previously, EPA's designation does not change the regulatory management
obligations for the treatment or management of the recovered material nor does it exempt the materials from
existing waste management regulations. The determination as to whether the ferrous foundry sands contain
contaminants at regulatory levels should be made in accordance with applicable federal and state regulations
before the material is used to make a commercial product.
Comment: American Electric Power (AEP) submitted comments supporting the proposed designation
of flowable fill containing ferrous foundry sand and also stated that EPA should note in the CPG and RMAN
that a variety of flowable fills have been successfully developed without the use of cement as an ingredient.
AEP referred specifically to flowable fills that utilize materials such as Class C fly ashes that have a high
calcium content, making them appropriate for use in lieu of cement. AEP added that these flowable fill mixes,
which sometimes utilize other recycled materials, such as Class F fly ash and bottom ash, as filler, have been
approved for use in several states. Supporting specifications from some of these states were attached to AEP's
comments.
Response: Information presented in the CPG and RMAN pertains to those items that are being
designated by EPA. The designation of items under RCRA Section 6002 and E.O. 13101 requires notice and
comment before final designations are promulgated. Because EPA did not propose to designate flowable fill
containing other materials such as Class C fly ashes, has not reviewed sufficient information on these
materials, and did not solicit public comments, no reference or recommendations for these items are
appropriate at this time. Procuring agencies may, however, choose to procure any item containing recovered
materials, regardless of whether the item is specifically designated by EPA. Procurement of items containing
recovered materials, whether or not they are designated by EPA, is consistent with RCRA Section 6002 and
51
-------
E.O. 13101. EPA will consider designating additional flowable fills containing other recovered materials in
future amendments to the CPG.
3. Rationale for Designation
EPA believes flowable fill satisfies the statutory criteria for selecting items for designation.
a. Use of Materials in 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.
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 FHWA 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.
52
-------
b. Technically Proven Uses
Coal Fly Ash
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.
According to FHWA, 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).
Strength development, flowability, time of set, and bleeding and shrinkage must all be taken into
account when evaluating the physical characteristics of flowable fill mixtures. Strength development depends
largely on the cement and water content of the mixture. In most high fly ash content mixes only 3 to 5 percent
portland cement is required to achieve a compressive strength between 50 and 150 pounds per square inch
(psi). Water content can also affect strength development. For example, at a given cement content, as water is
added, the compressive strength development declines over time.
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
53
-------
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
Flowable fill containing spent foundry sand has been used successfully in several state demonstration
projects and efforts to develop specifications for its use are under way.
Engineering properties that must be considered when using spent foundry sand in flowable fill
mixtures include the following:
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.
54
-------
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.
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.
55
-------
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 trench 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 trenches, 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.
Availability
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 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.
c. Impact of Government Procurement
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
56
-------
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.
4. Designation
EPA is designating flowable fill containing recovered coal fly ash and/or ferrous foundry sands. This
designation does 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.
5. Preference Program
Based on information received during the public comment period, EPA is changing its
recommendation regarding ASTM C33-93. Procuring agencies can use this specification's physical tests as a
measure to assure the quality and uniformity of the sands used in flowable fill. The agency now believes,
however, that this specification should not be referred to for gradation requirements. Based on this
information, the final RMAN III has been revised to recommend that procuring agencies "refer to ASTM C33-
93, 'Standard Specification for Concrete,' to assure the quality and uniformity of the ferrous foundry sands in
flowable fill..."
6. Background for Recommendations
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
57
-------
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.
Other names for flowable fill include: flowable mortar, controlled low-strength material, 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
—Subfooting
—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
58
-------
EPA considered the two primary recovered materials used in flowable fill, coal fly ash and spent
foundry sand.
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.
59
-------
Technically, foundry sand from both ferrous and nonferrous metal castings can be used in flowable
fill mixtures. In the past, nonferrous foundry sands often exhibited characteristics of hazardous waste. The
nonferrous metal castings industry, however, has made recent changes to its processes that result in
nonferrous foundry sands that do not always exhibit these characteristics.
Over the past 5 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.
Table 9 presents information provided by manufacturers of flowable fill on recovered materials
content availability.
Table 9
Recovered Materials Content of Flowable Fill
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
Coal Fly Ash
Foundry Sand
Company A: 22-88
Company B: 5-95
Company C: 50-85
Company D: Unknown
Unknown
Unknown
Unknown
Unknown
7.
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. EPA recommends that procuring agencies use
60
-------
ACI229R-94 and the ASTM standards listed in Table 8 when purchasing flowable fill or contracting for
construction that involves backfilling or other fill applications.
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 FHWA'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."
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.
61
-------
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.
D. Railroad Grade Crossing Surfaces
1. Background
In §247.12(k), EPA proposed to designate railroad grade crossing surfaces with recovered materials.
In Section C-ll of the accompanying draft RMAN III, EPA recommended that railroad grade crossing
surfaces contain the levels of recovered materials displayed in Table 10.
62
-------
Table 10
Draft Recovered Materials Content Recommendations for Railroad Grade Crossing Surfaces
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
Note: EPA's recommendations do not preclude a procuring agency from purchasing another type of railroad grade crossing, such as wood or
asphalt. They simply require that procuring agencies, when purchasing concrete, rubber, or steel grade crossing surfaces, purchase these items
made with recovered materials when these items meet applicable specifications and performance requirements.
EPA received 13 sets of comments in support of the proposed designation of railroad grade crossings
in CPG III and the recovered materials content ranges recommended in the draft RMAN. Specifically, these
commenters supported EPA's recommendations to include concrete containing coal fly ash as a recovered
material in the RMAN.
2. Summary of Comments and Agency's Response
Comment: The Illinois Department of Transportation (IDOT) submitted comments opposing the
designation and recovered materials content recommendations for railroad grade crossings because crossing
designs are usually job-specific, and IDOT believes this designation would inhibit innovation. In addition,
IDOT believes it would be very costly to verify the total recovered materials content.
Response: EPA disagrees that designating railroad grade crossing and providing recommendations on
recovered materials content ranges would inhibit innovation. As stated in Table
C-11A of the RMAN, "EPA's recommendations do not preclude a procuring agency from purchasing another
type of railroad grade crossing surface.... They simply require that procuring agencies, when purchasing
concrete, rubber, or steel grade crossing surfaces, purchase these items made with recovered materials when
these items meet applicable specifications and performance requirements." Thus, the job-specific
requirements and specifications should be factored into the procuring agency's decision whether to use
products containing recovered materials. If railroad grade crossings made with recovered materials do not
meet legitimate job-specific requirements, the procuring agency is not required to use the designated items
with recovered materials.
63
-------
With respect to the commenter's claim that it might be costly to verify recovered materials content in
designated items, EPA disagrees. RCRA Section 6002(1) requires that an agency's APP "contain a program
for requiring vendors to estimate, certify, and reasonably verify the recovered materials content of their
products." This provision, however, is not meant to encumber either of the contracting parties. At the federal
level, there are standard provisions for all contracts in the Federal Acquisition Regulations that can be utilized
to certify that the products contracted for are delivered. Standard clauses presumably exist for contracts issued
by state agencies as well. These standard provisions can be used to certify recovered materials content levels
with no extraneous or burdensome costs to either party.
3. Rationale for Designation
EPA believes that railroad grade crossing surfaces satisfy the statutory criteria for selecting items for
designation.
a. Uses of Materials in 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. 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 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
64
-------
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. Technically Proven Uses
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 toward
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.
65
-------
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, 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.
66
-------
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 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-specification) rubber.
A few states contacted by EPA expressed reservations regarding rubber railroad crossings, regardless
of the recovered materials content. An official with the Massachusetts Highway Department reported that a
newly installed recovered materials 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 materials 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 materials 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
10 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 recovered materials content shim-type crossings prior to 10 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 recovered materials 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,
67
-------
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.
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 materials content rubber railroad
crossings in place along a shortline 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
recovered materials 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 materials
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 materials 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.
68
-------
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.
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 toward 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.
69
-------
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.
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
70
-------
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.
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. Impact of Government Procurement
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 materials content rubber. A Class I railroad is defined as a freight railroad that has
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-Highway
71
-------
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.
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) are not required to pay a share of the
cost of the new or improved grade crossing surfaces since, per chapter 23 of the CFR, Section 646.310(a)(l),
these are deemed "of no ascertainable net benefit to the railroads."
4. Designation
EPA is designating railroad grade crossing surfaces containing recovered rubber, concrete, or steel.
This designation does 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.
72
-------
5. Preference Program
With the exception of steel, which has been revised to reflect the comment submitted by SRI
regarding the postconsumer and recovered content, EPA is recommending the draft RMAN recommendations
in the final RMAN III. EPA recommends that, based on the recovered materials content levels shown in Table
11 and the corresponding table in the RMAN III, procuring agencies establish minimum content standards for
use in purchasing or constructing new railroad grade crossing surfaces.
Table 11
Final Recovered Materials Content Recommendations for Concrete, Rubber, and Steel Railroad Grade
Crossing Surfaces
Surface Material
Concrete
Rubber
Steel
Recovered Material
Coal fly ash
Tire rubber
Steel
Postconsumer
Content (%)
—
—
16
67
Total Recovered
Materials Content (%)
15-20
85-95
25-30
100
Notes: EPA's recommendations do not preclude a procuring agency from purchasing another type of railroad grade crossing, such as wood or
asphalt. They simply require that procuring agencies, when purchasing concrete, rubber, or steel grade crossing surfaces, purchase these items
made with recovered materials when these items meet applicable specifications and performance requirements.
The recommended recovered materials content levels for rubber railroad grade crossing surfaces are based on the weight of the raw
materials, exclusive of any additives such as binders or other additives.
Coal fly ash can be used as an ingredient of concrete slabs, pavements, or controlled density fill product, depending on the type of
concrete crossing system installed. Higher percentages of coal fly ash can be used in the concrete mixture; the higher percentages help to produce
a more workable and durable product but can prolong the curing process.
The recommended recovered materials content levels for steel in this table reflect the fact that the designated items can be made from
steel manufactured in either a Basic Oxygen Furnace (BOF) or an Electric Arc Furnace (EAF). Steel from the BOF process contains 25-30%
total recovered materials, of which 16% is postconsumer steel. Steel from the EAF process contains a total of 100% recovered steel, of which
67% is postconsumer.
73
-------
6. Background for Recommendations
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 FHWA, the trend in railroad grade crossings is toward 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
FHWA. 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.
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.
74
-------
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.
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 100 percent recovered materials.
Almost all steel produced in U.S. steel mills currently contains recovered material.
Table 12 presents information provided by manufacturers of railroad crossings on recovered materials
content availability.
75
-------
Table 12
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
7.
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-volume traffic 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.
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. A table showing the traffic guidelines the state observes can be found in the document entitled,
"Background Document for Proposed CPG III and Draft RMAN III."
76
-------
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 Property—Durometer 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
Elastomers—Tension. These test methods describe procedures used to evaluate the tensile
(tension) properties of vulcanized rubbers, thermoplastic rubbers, and thermoplastic
elastomers.
D297-93 Rubber Products—Chemical Analysis. These test methods cover the qualitative and
quantitative analysis of the composition of rubber products.
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 Deterioration—Surface 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 Rubber—Deterioration 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 Property—Compression 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.
77
-------
D2137-94 Rubber Property—Brittleness 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.
78
-------
IX. PARK AND RECREATION PRODUCTS
A.
Park Benches and Picnic Tables
1. Background
In Section 247.14(c) of the proposed CPG III, EPA proposed to designate park benches and picnic
tables containing recovered steel, aluminum, plastic, or concrete. In Section E-3 of the accompanying draft
RMAN III, EPA recommended that park benches and picnic tables contain the levels of recovered materials
listed in Table 13.
Table 13
Draft Recovered Materials Content Recommendations for
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: EPA's recommendations do not preclude a procuring agency from purchasing park benches and picnic tables manufactured from other
materials. They simply require that a procuring agency, when purchasing steel, aluminum, plastic, or concrete park benches and picnic tables,
purchase these items containing recovered materials when they meet applicable specifications and performance requirements.
"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.
EPA requested any information concerning additional park and recreational furniture that is made with
recovered materials and that might be purchased in appreciable quantities by procuring agencies. EPA also
requested comments on whether any specifications exist or are appropriate for steel and aluminum when used
in park benches and picnic tables. No commenters addressed these issues. Besides SRI's general
79
-------
comment on postconsumer and recovered content levels for steel, EPA received only one other comment on
park benches and picnic tables, which was related to reporting requirements. Therefore, based on the research
conducted for the proposed CPG III and draft RMAN III and SRI's comment on steel, EPA is designating
park benches and picnic tables in the final CPG III and revising the postconsumer and recovered content
levels for park benches and picnic tables made from steel.
2. Summary of Comments and Agency's Response
Comment: Lockheed Martin Idaho Technologies Company indicated that some agencies do not
purchase park and recreation products, and, therefore, EPA should write agencywide exemptions for those
agencies so the item does not have to be tracked.
Response: EPA disagrees. The APP and recordkeeping and reporting provisions in RCRA and E.O.
13101 pertain to EPA-designated guideline items purchased by the agency. If an agency does not purchase
an EPA-designated item, presumably there would be no recordkeeping and reporting for that
item. Having EPA write exemptions for agencies that do not purchase items would have no impact. EPA
recommends that if a procuring agency does not purchase a specific designated item, it could simply include
a statement in its APP to that effect.
3. Rationale for Designation
EPA believes that park benches and picnic tables satisfy the statutory criteria for selecting items for
designation.
a. Use of Materials in Solid Waste
According to one manufacturer, extruding high density polyethylene (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
80
-------
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 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. Technically Proven Uses
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
81
-------
lumber might deteriorate more quickly than 100 percent plastic. A study conducted at Rutgers University
revealed that plastic lumber exposed to ultraviolet (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 lifecycle
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.
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
82
-------
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.
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. The Plastic Lumber Trade
Association's (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
83
-------
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.
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.
84
-------
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 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 indicated 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 industry wide standards. An independent consultant noted the importance of UV stabilizers and
85
-------
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.
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.
c. Impact of Government Procurement
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 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 DoD in the state of Texas.
86
-------
4. Designation
EPA is designating park benches and picnic tables containing recovered steel, aluminum, plastic,
plastic composites, and concrete. This designation does not preclude a procuring agency from purchasing
park benches and picnic tables manufactured from another material, such as wood. It simply requires that a
procuring agency, when purchasing park benches and picnic tables, purchase these items with recovered
materials when these items meet applicable specifications and performance requirements.
5. Preference Program
With the exception of steel, which has been revised to reflect the comment submitted by SRI
regarding the postconsumer and recovered content, EPA is recommending the draft RMAN recommendations
in the final RMAN III. EPA recommends that, based on the recovered materials content levels shown in Table
14 and the corresponding table in the RMAN III, procuring agencies establish minimum content standards for
use in purchasing new park benches and picnic tables.
87
-------
Table 14
Final Recovered Materials Content Recommendations for
Park Benches and Picnic Tables Containing Recovered Aluminum, Steel, Concrete, or Plastic
Material
Plastics
Plastic composites
Aluminum
Concrete
Steel
Postconsumer Content (%)
90-100
50-100
25
~
16
67
Total Recovered
Materials Content (%)
100
100
25
15-40
25-30
100
Notes: EPA's recommendations do not preclude a procuring agency from purchasing park benches or picnic tables made from other materials.
They simply require that procuring agencies, when purchasing park benches or picnic tables made from plastic, aluminum, concrete, or steel
purchase these items made with recovered materials when these items meet applicable specifications and performance requirements.
"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.
The recommended recovered materials content levels for steel in this table reflect the fact that the designated items can be made from
steel manufactured in either a Basic Oxygen Furnace (BOF) or an Electric Arc Furnace (EAF). Steel from the BOF process contains 25-30%
total recovered materials, of which 16% is postconsumer steel. Steel from the EAF process contains a total of 100% recovered steel, of which
67% is postconsumer.
6.
Background for Recommendations
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
88
-------
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 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 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. PLTA
identifies four main technologies used to produce recycled plastic lumber.
Single-polymer systems made from recycled HDPE. 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.
89
-------
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
polypropylene (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.
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 HDPE plastic lumber, 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).
Table 15 presents information provided by manufacturers on the recovered materials content of park
benches and picnic tables.
90
-------
Table 15
Recovered Materials Content of Park Benches and Picnic Tables
Material
HDPE
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
91
-------
Material
Plastic
(Unspecified)
(cont.)
Mixed Resins (HDPE,
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
92
-------
7. 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 of 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. 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:
D6108-97 Standard Test Method for Compressive Properties of Plastic Lumber.
D6109-97 Standard Test Method for Flexural Properties of Unreinforced and Reinforced
Plastic Lumber.
D6111-97 Standard Test Method for Bulk Density and Specific Gravity of Plastic
Lumber and Shapes by Displacement.
D6112-97 Standard Test Method for Compressive and Flexural Creep and Creep
Rupture of Plastic Lumber and Shapes.
D6117-97 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.
93
-------
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.
B. Playground Equipment
1. Background
In Section 247.14(d) of the proposed CPG III, EPA proposed to designate playground equipment with
recovered materials. In Section E-4 of the accompanying RMAN III, EPA recommended that playground
equipment contain the levels of recovered materials listed in Table 16.
Table 16
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: EPA's recommendations do not preclude a procuring agency from purchasing playground equipment made from other materials. They
simply require that procuring agencies, when purchasing playground equipment made from plastic, aluminum, or steel, purchase these items
made with recovered materials when the item meet applicable specifications and performance requirements.
"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.
94
-------
EPA did not receive any comments specific to the proposed designation of playground equipment.
The general comments submitted by SRI pertaining to the recovered materials content of all steel products
pertain to steel playground equipment, and therefore, the RMAN for this item will be revised accordingly.
95
-------
2. Summary of Comments and Agency's Response
With the exception of the comment submitted by SRI regarding the postconsumer and recovered
materials content of steel, EPA did not receive specific comments on playground equipment.
3. Rationale for Designation
EPA believes that playground equipment satisfies the statutory criteria for selecting items for
designation.
a. Use of Materials in 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.
96
-------
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.
b. Technically Proven Uses
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 1/4-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 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. 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.
97
-------
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.
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 better 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
98
-------
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 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
99
-------
resistant to rot, splintering, and breaking than wooden equipment. And unlike wood, it does not need to be
treated with potentially hazardous chemicals.
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.
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.
c. Impact of Government Procurement
The GSA contracting representative for Schedule 781-C, Park and Outdoor Recreation Equipment,
said that, in 1996, GSA-tracked playground equipment purchasing 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 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.
100
-------
4. Designation
In CPG III, EPA is designating playground equipment containing recovered plastic, steel, wood, or
aluminum. This designation does not preclude a procuring agency from purchasing playground equipment
manufactured from other materials. It simply requires 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.
5. Preference Program
With the exception of steel, which has been revised to reflect the comment submitted by SRI
regarding the postconsumer and recovered content, EPA is recommending the draft RMAN recommendations
in the final RMAN III. EPA recommends that, based on the recovered materials content levels shown in Table
17 and the corresponding table in the RMAN III, procuring agencies establish minimum content standards for
use in purchasing playground equipment.
101
-------
Table 17
Final Recovered Materials Content Recommendations for
Playground Equipment Containing Recovered Plastic, Steel, or Aluminum
Material
Plastic
Plastic composites
Steel
Aluminum
Postconsumer Content (%)
90-100
50-75
16
67
25
Total Recovered
Materials Content (%)
100
95-100
25-30
100
25
Notes: EPA's recommendations do not preclude a procuring agency from purchasing playground equipment made from other materials. They
simply require that procuring agencies, when purchasing playground equipment made from plastic, aluminum, or steel purchase these items made
with recovered materials when the item meets applicable specifications and performance requirements.
"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.
The recommended recovered materials content levels for steel in this table reflect the fact that the designated items can be made from
steel manufactured in either a Basic Oxygen Furnace (BOF) or an Electric Arc Furnace (EAF). Steel from the BOF process contains 25-30%
total recovered materials, of which 16% is postconsumer steel. Steel from the EAF process contains a total of 100% recovered steel, of which
67% is postconsumer.
6.
Background for Recommendations
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
102
-------
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.
Single-polymer systems made from recycled HDPE. 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.
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.
Fiberglass reinforced PE. 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.
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."
103
-------
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). Table 18 provides information on the availability of playground equipment manufactured with
recovered materials.
Table 18
Recovered Materials Content of Playground Equipment (Nonstructural Pieces)
Material
HDPE
HDPE, LDPE, LLDPE, and PP
Plastic (Unspecified Resins)
Composite Plastic/Fiberglass
Steel
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
Company K: 90-95
Company L: 90-95
Company M: 95
Company N: Unspecified
Company O: 75 (Plastic)
Company P: 25-100
Total Recovered
Materials Content (%)
100
100
0-100
85-90
100
30-90
100
100
96
98.9
100
100
100
Unspecified
20 (Fiberglass)/95 (Total)
25-100
104
-------
7. 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:
D6108-97 Standard Test Method for Compressive Properties of Plastic Lumber.
D6109-97 Standard Test Method for Flexural Properties of Unreinforced and Reinforced
Plastic Lumber.
D6111-97 Standard Test Method for Bulk Density and Specific Gravity of Plastic
Lumber and Shapes by Displacement.
105
-------
D6112-97 Standard Test Method for Compressive and Flexural Creep and Creep
Rupture of Plastic Lumber and Shapes.
D6117-97 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.
106
-------
X.
LANDSCAPING PRODUCTS
A. Plastic Lumber Landscaping Timbers and Posts
1. Background
In Section 247.15(e) of the proposed CPG III, EPA proposed to designate plastic lumber landscaping
timbers and posts containing recovered materials. In Section F-5 of the accompanying draft RMAN III, EPA
recommended that plastic lumber landscaping timbers and posts contain the levels of recovered materials
listed in Table 19.
Table 19
Draft Recovered Materials Content Recommendations
for Landscaping Timbers and Posts
Material
HDPE
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.
2. Summary of Comments and Agency's Response
The Agency did not receive any comments on its proposed designation of landscaping timbers and
posts in the CPG or on the recommendations contained in the draft RMAN.
107
-------
3. Rationale for Designation
EPA believes that plastic lumber landscaping timbers and posts satisfy the statutory criteria for
selecting items for designation.
a. Use of Materials in Solid Waste
Landscaping timbers and posts can be made with recovered wood (sawdust and wood chips used in
composite lumber), HDPE, 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 MSW.
One manufacturer of wood and plastic composite lumber made from recovered sawdust and
postconsumer LDPE estimates that between 25 and 100 plastic grocery bags are used to make 1 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 MSW. This manufacturer also estimates that, in 1996, the company used 50 million pounds
of HDPE, 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.
108
-------
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, HDPE, LDPE,
LLDPE, PVC, and PS.
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. Technically Proven Uses
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
109
-------
government purchaser of 6- by 6- foot plastic lumber profiles used in retaining walls confirmed that the
plastic lumber is virtually maintenance-free.
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 and 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 1/4 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 and 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 7 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
110
-------
used in landscape retaining walls for 6 years said the product has been exposed to temperatures ranging from
27 to 110 without problems.
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.
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.
Ill
-------
c. Impact of Government Procurement
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, NFS, 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 NFS, 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.
4. Designation
EPA is designating plastic lumber landscaping timbers and posts containing recovered materials. This
designation does not preclude a procuring agency from purchasing landscaping timbers and posts
manufactured from another material, such as wood. It simply 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.
5. Preference Program
EPA is recommending the draft RMAN recommendations in the final RMAN III. EPA recommends
that procuring agencies establish minimum content standards for use in purchasing landscaping timbers and
posts. Based on the research conducted by the EPA, the Agency recommends that the standards be based on
the content levels shown in Table 20 and the corresponding table in the RMAN III.
112
-------
Table 20
Final Recovered Materials Content Recommendations
for Plastic Lumber Landscaping Timbers and Posts
Material
HDPE
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.
6. Background for Recommendations
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.
113
-------
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.
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.
Single-polymer systems made from recycled HDPE. 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.
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 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.
114
-------
Fiberglass reinforced PE. 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.
Wood and 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." 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.
115
-------
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." Table 21 presents information provided
by manufacturers on the recovered materials content of plastic lumber landscaping timbers and posts.
Table 21
Recovered Materials Content of Landscaping Timbers and Posts
Material
HDPE
LDPE, HDPE,
LLDPE/Sawdust
HDPE, Fiberglass
HDPE, 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)
116
-------
Material
LDPE, PP
Mixed Resins (PET, HDPE,
LDPE, LLDPE, PVC, PS,
Other)
Mixed Resins (HDPE, LDPE,
LLDPE, PP)
Mixed Resins (HDPE, LDPE,
PET, PP)
Mixed Resins (HDPE, PP,
PET)
Mixed Resins (HDPE, 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
117
-------
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
Plastic (unspecified)/Rubber
tires
PE
Company AAA: 100
Company BBB: 60
Company CCC: 97
100
100
97
7. 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:
D6108-97 Standard Test Method for Compressive Properties of Plastic Lumber.
D6109-97 Standard Test Method for Flexural Properties of Unreinforced and Reinforced
Plastic Lumber.
D6111-97 Standard Test Method for Bulk Density and Specific Gravity of Plastic
Lumber and Shapes by Displacement.
D6112-97 Standard Test Method for Compressive and Flexural Creep and Creep
Rupture of Plastic Lumber and Shapes.
D6117-97 Standard Test Method for Mechanical Fasteners in Plastic Lumber and Shapes.
118
-------
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.
B. Food Waste Compost
1. Background
In Section 247.15(f) of the proposed CPG III, EPA proposed to revise the existing yard trimmings
compost designation to include compost made from food waste or commingled food waste and yard
trimmings. In Section F-2 of the accompanying draft RMAN III, EPA recommended that procuring agencies
purchase or use compost made from yard trimmings, leaves, grass clippings, and/or food wastes in
applications such as landscaping, seeding of grass or other plants on roadsides and embankments, as
nutritious mulch under trees and shrubs, and for erosion control and soil reclamation.
2. Summary of Comments and Agency's Response
Comment: The Department of Interior's Office of Acquisition and Property Management submitted
a comment expressing concern about vermin control with food waste compost and believes there should be
a statement added "in accordance with acceptable health and sanitary practices" after the words "food
waste" on page 45578 of the CPG and page 45586 of the RMAN.
Response: EPA agrees that a qualifying statement should be added as recommended by the
commenter and EPA has revised the final CPG/RMAN III. At the present time, state agencies have authority
for health and safety standards and permitting of facilities engaged in composting. That being the case, the
119
-------
final CPG/RMAN III has been revised to state "...in accordance with applicable state health and safety
standards and permitting."
EPA notes that quality finished food waste compost does not have the odor, texture, or other
characteristics of the food waste feedstock. It has characteristics more like soil or peat. That being said, the
use or storage of quality finished food waste compost should not attract vermin. During the actual
composting process, experienced facility operators completely cover the food waste feedstock in the
compost pile with bulking agents, a practice which helps alleviate vermin.
The Agency suggests that compost facility operators should receive the necessary training and
certification before operating such facilities and has made this recommendation in the final RMAN III. The
Composting Council has issued a standard operating guide for composting facilities that provides technical
assistance to compost facility operators. In addition, the Composting Council is in the process of
developing, for consumers, a "seal of quality" for compost products to ensure quality standards are met in
the finished compost products.
3. Rationale for Designation
EPA believes that food waste compost containing recovered organic materials meets the statutory
criteria for selecting items for designation.
a. Use of Materials in 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 wastes that 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.
120
-------
b. Technically Proven Uses
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 microorganisms 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.
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.
121
-------
Releases nutrients in organic form, such as nitrogen, into the soil slowly over time. 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.
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.
122
-------
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 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.
123
-------
c. Impact of Government Procurement
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.
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 in-vessel 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 in-vessel 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
124
-------
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.
4. Designation
EPA is revising the yard trimmings compost designation to include compost made from food
waste or commingled food waste and yard trimmings.
5. 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.
6. Background for Recommendations
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
125
-------
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 microorganism 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:
Compost is the stabilized and sanitized product of composting; compost is largely decomposed
material and is in the process of humification (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.
126
-------
7. 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 the Department of
Transportation's (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.
127
-------
XI. NONPAPER OFFICE PRODUCTS
Solid Plastic Binders, Clipboards, File Folders, Clip Portfolios,
and Presentation Folders
1.
Background
In Section 247.16(d) of the proposed CPG III, EPA proposed to amend the existing binders
designation to include solid plastic binders. In §247.16(h)-(k), EPA proposed to designate plastic
clipboards, plastic file folders, plastic clip portfolios, and plastic presentation folders containing
recovered materials. In Section G-8 of the accompanying draft RMAN III, EPA recommended that plastic
binders, clipboards, plastic file folders, plastic clip portfolios, and plastic presentation folders contain the
levels of recovered materials listed in Table 22.
Table 22
Draft Recovered Materials Content Recommendations for
Solid 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
HDPE
PE
PET
Misc. Plastics
HDPE
PS
Misc. Plastics
HDPE
HDPE
HDPE
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.
128
-------
2. Summary of Comments and Agency's Response
Comment: Lockheed Martin Idaho Technologies Company believes these products could easily
be incorporated into other categories of nonpaper office product. In addition, Lockheed Martin Idaho
Technologies Company does not believe that the reported five manufacturers indicated in the
background document constitute adequate competition. The company believes, therefore, that most
agencies would write an availability or competition exemption for these products because they would be
difficult to obtain. Lockheed Martin Idaho Technologies Company does not believe agencies should
have to track and report purchases of these items if there is going to be an exemption.
Response: EPA's prior designation for "binders" in CPGI entailed plastic covered binders,
meaning the plastic provided a covering over another material such as paperboard. The proposed
designation in CPG III is for solid plastic binders, hence, the initial distinction in designations. The
commenters point is well taken and the Agency will consider consolidating these designations under the
broader category of "binders" in a future amendment to the CPG as time and resources allow.
EPA does not agree with the commenter's assertion that because only five manufacturers were
identified by EPA, adequate competition does not exist and, by implication, the items should not be
designated. Section 6002 (e)(l) of RCRA stipulates that in designating items the guidelines shall
"designate items that are or can be made with recovered materials..." and that "... the availability of such
items" shall be considered. While EPA makes every effort to identify manufacturers and distributors of
items proposed for designation, this research is not exhaustive nor does it seek to identify all sources of
the proposed items. In this particular instance, the proposed items, from multiple suppliers, were on
GSA's New Item Introductory Schedule and, therefore, GSA could serve as a national source for these
items. EPA is well aware, however, that procuring agencies often purchase items off-schedule and might
be unable to obtain some designated items regionally for one or more of the reasons cited in RCRA
Section 6002(c)(l). If this is the case, EPA recommends that the procuring agency simply include a
statement in its APP that states the item is currently not available and, therefore, the agency has
concluded that it is not required to procure this item. Once an agency makes the aforementioned
determination, no recordkeeping or tracking of the item would be required. EPA notes, however, that in
accordance with 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.
129
-------
3. Rationale for Designation
EPA believes that plastic binders, clipboards, plastic file folders, plastic clip portfolios, and plastic
presentation folders satisfy the statutory requirements for selecting items for designation.
a. Use of Materials in Solid Waste
Recovered materials 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 materials 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. Technically Proven Uses
According to a product distributor, recovered materials 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 materials 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 materials content PS clipboards stated that the clipboards performed well.
Recovered materials 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 materials 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
130
-------
binders, clipboards, and presentation folders are also available through an additional distributor as a New
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 materials content plastic binders,
clipboards, and file folders made from other kinds of plastic, including PE, PS, PET, and unspecified plastics.
c. Impact of Government Procurement
The vendor on GSA's Federal Supply Schedule for the recovered materials 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
agencies that have already purchased the HDPE products. EPA learned that the Ontario Ministry of
Transportation in Ontario, Canada, has purchased recovered materials content HDPE binders and is pleased
with their performance. The contact stated that the HDPE binders were slightly more expensive than virgin
materials content solid plastic binders. According to another source, this price differential results from the
slightly higher costs of recycled 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 materials 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.
131
-------
4. Designation
EPA is amending the existing designation of binders to include solid plastic binders containing
recovered plastic. EPA is designating plastic clipboards, plastic file folders, plastic clip portfolios, and plastic
presentation folders containing recovered plastic. This designation does 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.
5. Preference Program
EPA is recommending the draft RMAN recommendations in the final RMAN III. EPA recommends
that, based on the recovered materials content levels shown in Table 23, procuring agencies establish
minimum content standards for use in purchasing plastic binders, clipboards, file folders, clip portfolios, and
presentation folders.
132
-------
Table 23
Final Recovered Materials Content Recommendations for
Solid 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
HDPE
PE
PET
Misc. Plastics
HDPE
PS
Misc. Plastics
HDPE
HDPE
HDPE
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.
6.
Background for Recommendations
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 24 presents information provided by manufacturers of plastic binders, clipboards, file folders,
clip portfolios, and presentation folders on recovered materials content availability.
133
-------
Table 24
Recovered Materials Content of
Solid Plastic Binders, Clipboards, File Folders, Clip Portfolios, and Presentation Folders
Material
HDPE
PE
Plastic (unspecified)
PS
PET
Postconsumer Content (%)
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
Total Recovered
Materials Content (%)
100
100
Unknown
100
Unknown
Unknown
80
Unknown
Unknown
100
7.
Specifications
EPA did not identify any specifications or standards regarding plastic binders, clipboards, file folders,
clip portfolios, and presentation folders.
134
-------
XII. MISCELLANEOUS PRODUCTS
A.
Sorbents
1. Background
In §247.17(b), EPA proposed to designate sorbents containing recovered materials. In Section H-2 of
the accompanying draft RMAN III, EPA recommended that sorbents contain the levels of recovered
materials listed in Table 25.
Table 25
Draft Recovered Materials Content Recommendations
for Sorbents
Material
Paper
Textiles
Plastics
Wood
Other Organics/Multimaterials
Postconsumer Content (%)
90-100
95-100
~
~
~
Total Recovered
Materials Content (%)
100
95-100
25-100
100
100
Notes: EPA's recommendations do not preclude a procuring agency from purchasing sorbents made from other materials. They simply
require that procuring agencies, when purchasing sorbents made from paper, wood, textiles, plastics, or other organic materials, purchase them
made with recovered materials when these items meet applicable specifications and performance requirements.
"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.
135
-------
2. Summary of Comments and Agency's Response
Comment: DOE submitted comments supporting the designation of sorbents containing recovered
materials when such materials meet the agency's needs. DOE acknowledged in its comments
that while an agency might not be able to find a sorbent containing recovered materials for every potential
spill, this would not preclude an agency from procuring sorbents containing recovered materials.
Comment: Synthetic Industries (SI) produces sorbents made of PP that are used to clean up solvent
and oil spills. SI is strongly opposed to the designation of sorbents containing postconsumer recovered PP
because, according to SI, such products are technologically infeasible. In addition, SI believes PP sorbents
should not be designated for performance-related reasons, citing doubts about the ability of manufacturers to
produce a highly sensitive PP product from postconsumer material. SI also stated that it is not feasible to
make sorbents with postconsumer PP since it is difficult to obtain a consistent, noncontaminated source of
postconsumer PP material. SI stated that if the sorbent's chemical content is not known, it could react with a
spilled chemical, create a further hazard, or not work properly.
Response: EPA did not propose to designate sorbents with postconsumer PP, only those with total
recovered plastics. EPA's research identified three companies currently making such products. The Agency
agrees with the commenter that not all sorbent materials are right for all cleanups. The Agency stated this
position in both its background document and the proposed CPG III FR notice (63 FR 45569, August 26,
1998). The Agency wrote, "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 Agency provided
a lengthy discussion of the importance of choosing sorbents for particular applications both in the FR notice
and background document. The Agency notes that these factors should be considered regardless of whether
the sorbent is made from recovered or virgin materials. In the RMAN, EPA recommends that procuring
agencies use industry standard specifications when determining the sorbents to be used in particular
applications.
Comment: The Brookhaven National Laboratory commented on the performance of recovered
materials content sorbents. The commenter believes EPA needs to convey to potential users of sorbents
that sorbent capacity is an important factor in sorbent selection for oil and solvent spills, and lower sorbent
capacities compromise performance and will result in greater waste volumes and higher disposal costs.
136
-------
Response: EPA believes that both virgin and recovered material content sorbents can provide similar
performance in oil and solvent spill situations as long as the appropriate type of sorbent is chosen (based on
a variety of factors including sorbent capacity) for the type of substance being sorbed and for the location of
the spill. Whenever an inappropriate sorbent is used, either virgin or recovered content, the possibility exists
for dangerous reactions, environmental damage, and increased sorbent use and recovery or disposal. In
addition, regarding waste and disposal issues, the management of used sorbent material does not necessarily
end in disposal. Under certain conditions, some sorbent materials can be reused or recycled. Synthetic
sorbents, for example, release sorbed substances under pressure, and inorganic sorbents can be recovered
and used again through a laundering process. Several federal agencies are successfully using recovered
content sorbents to deal with oil and solvent spills. The NFS, for example, uses a product made from
recovered polypropylene, for heavy or viscose oils. The U.S. Army Corps of Engineers at Dworshak Dam in
Idaho, uses a product made from 100 percent recovered wood waste, for emergency spill response.
Comment: Lockheed Martin Idaho Technologies Company submitted comments stating that the
background document does not discuss price and that it is likely that a price exemption will exist for
sorbents. Lockheed Martin Idaho Technologies Company does not believe agencies should have to perform
tracking and reporting for an item that will most likely be exempt based on price.
Response: The price paid for any item, regardless of whether it is made from virgin or recovered
materials, is dependent on a number of factors including quantity of items purchased, shipping distance, the
strength of the overall economy, and the operational efficiencies of the manufacturing facilities. That being
said, prices can and do vary for items. EPA has addressed this issue for all procurement guidelines in its
April 20, 1994, notice for CPGI (59 FR 18884). In that notice EPA stated the following:
"... relative prices for recycled products compared to prices of comparable virgin products
vary. In many cases, recycled products may be less expensive that their virgin counterparts.
In other cases, virgin products may have lower prices than recycled products. However, other
factors can 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. Under RCRA Section 6002(c), procuring agencies are not required to
purchase a product containing recovered materials if it is only available at an unreasonable
price. However, the decision to pay more or less for such a product is left to the procuring
agency which may not incur additional costs due to the price differentials...."
137
-------
That being said, an "exemption" for an item based on price would have to be justified by the
procuring agency and, if justified, could be addressed in the agency's APP. EPA notes that, in accordance
with RCRA Section 6002(I)(2)(D), it is the procuring agency's responsibility to monitor and regularly update
its APP. Should an item become available that was previously unobtainable or not purchased based on a
price differential, then the procuring agency should modify its APP accordingly.
3. Rationale for Designation
EPA believes that sorbents satisfy the statutory criteria for selecting items for designation.
a. Use of Materials in 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:
Lumber Mill Waste—According 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.
138
-------
Paper Mill Waste—One 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 Waste—A 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. Technically Proven Uses
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 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 poly chlorinated biphenyls), paints
139
-------
(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, polypropylene—and a
small number of organic sorbent products that are treated to make them hydrophobic—are 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 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
140
-------
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.
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,
141
-------
because trace elements of certain contaminates could potentially pose a fire hazard. 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.
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.
c. Impact of Government Procurement
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.
142
-------
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.
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 NPS 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.
DOE 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.
143
-------
4.
Designation
EPA is designating sorbents containing recovered materials for use in oil and solvent cleanups and as
animal bedding. This designation does not preclude a procuring agency from purchasing sorbents made from
other materials. It simply requires that procuring agencies, when purchasing sorbents made from paper, wood,
textiles, plastics, or other organic materials, purchase them made with recovered materials when these items
meet applicable specifications and performance requirements
5. Preference Program
EPA is recommending the draft recommendations in the final RMAN III. EPA recommends that,
based on the recovered material levels shown in Table 26 and the corresponding table in the RMAN III,
procuring agencies establish minimum content standards for use in purchasing sorbents.
Table 26
Final Recovered Materials Content Recommendations
for Sorbents Used in Oil and Solvents Cleanups and for Use as Animal Bedding
Material
Paper
Textiles
Plastics
Wood
Other Organics/Multimaterials
Postconsumer Content (%)
90-100
95-100
~
~
~
Total Recovered
Materials Content (%)
100
95-100
25-100
100
100
Notes: EPA's recommendations do not preclude a procuring agency from purchasing sorbents made from other materials. They simply require
that procuring agencies, when purchasing sorbents made from paper, wood, textiles, plastics, or other organic materials, purchase them made
with recovered materials when these items meet applicable specifications and performance requirements.
"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.
144
-------
6. Background for Recommendations
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 waste-water 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
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.
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.
Synthetic sorbents are made from either virgin synthetic materials or synthetics recovered from
the municipal and industrial solid waste streams.
145
-------
Industry Overview—Sorbents 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.
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 Overview—Sorbents 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 large—possibly 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
146
-------
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 ofSorbent 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.
Particulates 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.
Table 27 shows information EPA obtained on the recovered materials content of sorbents.
147
-------
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
148
-------
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
PP
Gypsum
Wood
Other Organics
Multimaterial
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
7. 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 multiple awards
schedule and directly from manufacturers. When sorbents are purchased through the multiple awards
149
-------
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 Sor bent 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. 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.
150
-------
B.
Industrial Drums
1. Background
In §247.17(c), EPA proposed to designate industrial drums containing recovered materials. In Section
H-3 of the accompanying draft RMAN III, EPA recommended that industrial drums contain the levels of
recovered materials listed in Table 28.
Table 28
Draft Recovered Materials Content Recommendations for Industrial Drums
Product
Steel drums
Plastic drums
Fiber drums
Material
Steel
HDPE
Paper
Postconsumer
Content (%)
16
30-100
100
Total Recovered
Materials Content (%)
20-30
30-100
100
Note: EPA's recommendations do not preclude a procuring agency from purchasing another type of industrial drum. They simply require that
procuring agencies, when purchasing steel, plastic, or fiber industrial drums, purchase them made with recovered materials when these items meet
applicable specifications and performance requirements.
2. Summary of Comments and Agency's Response
Comment: The Association of Container Reconditioners (ACR) represents the industrial container
reconditioning industry in North America. ACR submitted comments suggesting that EPA improperly favors
the procurement of new industrial drums containing recovered materials over reconditioned industrial drums.
ACR indicated that reuse of industrial drums has a reduced effect on the environment compared to new
manufacturing and, therefore, better meets the requirement in E.O. 13101 for agencies to acquire and use
environmentally preferable products. In addition, reuse can divert a significant amount of material from the
waste stream and save a large amount of energy. ACR referenced a study showing that roughly 10 times the
amount of energy is required to manufacture a steel drum than to recondition the same drum. ACR indicated
that reconditioned drums are effectively comprised of 100 percent recovered materials. In addition, on the
subject of availability, ACR stated that its members recondition for reuse as many steel drums as are
151
-------
manufactured in the United States; approximately 5.5 million plastic drums compared to 10 million
manufactured; and several hundred thousand fiber drums annually. Furthermore, reconditioned containers
meet all DOT requirements for the transport of dangerous goods. Finally, ACR suggests that if it is infeasible
for an agency to procure reconditioned drums, the agency should purchase drums that can be subsequently
reconditioned and reused by other entities.
Response: EPA disagrees with the commenter's claim that the Agency improperly favors the
procurement of new industrial drums containing recovered materials over reconditioned industrial drums.
Section 6002 (e)(l) of RCRA stipulates that in designating items the guidelines shall "...designate items that
are or can be made with recovered materials..." Many reused drums may, in fact, have been manufactured
with no recovered materials and, therefore, would contain no recovered materials. In the CPG III notice,
therefore, EPA proposed to designate industrial drums containing recovered materials. In the RMAN III
notice, however, which provides recommendations to be used in concert with the designation, EPA suggests
"...that procuring agencies reuse drums, purchase or use reconditioned drums, or procure drum
reconditioning services, whenever feasible." (See 63 FR 45588, August 26, 1998.) EPA has issued similar
designations and recommendations in the past for items that are not only made with recovered materials, but
that also can be remanufactured or, in cases where services can be obtained, to reuse the item. Specifically,
EPA designated toner cartridges in CPG I (60 FR 21384, May 1, 1995) and recommended in the RMAN that
agencies give priority to remanufacturing expended toner cartridges (60 FR 21394, May 1, 1995).
Additionally, EPA designated reclaimed engine coolants in CPG I (60 FR 21383, May 1, 1995) and
recommended that agencies "...establish a program for engine coolant reclamation and reuse...." (See 60 FR
21390, May 1, 1995.) It is EPA's intent that procuring agencies use the designation of items issued in the CPG
collectively with the recommendations provided in the RMAN when developing their APPs. EPA believes that
an agency would be in compliance with the procurement requirements of both Section 6002 of RCRA and
E.O. 13101 if it chose to reuse industrial drums, procure reconditioned drums, and/or obtain reconditioning
services pursuant to the recommendations in the RMAN.
Comment: The Steel Shipping Container Institute (SSCI) is a trade association representing the
manufacturers of 2-1/2- to 85-gallon industrial steel containers (pails and drums). SSCI submitted comments
supporting the designation of industrial drums, but requests that EPA add the words "including steel pails" to
the designation, because steel pail manufacturers use steel produced from the same EOF process as the steel
used in steel drums.
152
-------
Response: At this time, the Agency is opposed to adding "steel pails" to its designation of industrial
drums. Although it is true that steel pails contain recovered materials, other materials, such as plastic and
rubber also are used to make pails and these too may contain recovered materials. The Agency has not
researched the recovered materials content of pails made from various materials and, therefore, does not
believe it would be prudent to designate an item and recommend recovered materials content levels for only
one material without providing recommendations for the other materials from which the item can be made. If
the Agency decides to consider designating pails in the future, it will gather information on all materials that
might be used to make pails.
The commenter should note, however, that Section 601(b) of E.O. 13101 requires procuring agencies
to establish goals to, among other things, increase their procurement of products made with recovered
materials, regardless of whether these items are designated by EPA. The procurement of such items should be
considered in any reports prepared and submitted on the status of an agency's compliance with RCRA 6002
or E.O. 13101.
Comment: Lockheed Martin Idaho Technologies Company believes steel industrial drums are a
logical choice for designation, citing the fact that manufacturers currently produce them in accordance with
the CPG. Many issues need to be resolved, however, before designating plastic and fiber drums. Lockheed
Martin Idaho Technologies Company did not provide any details of what it considers to be issues of concern.
Response: EPA disagrees that there are outstanding issues of concern. In both the background
document and in the FR notice for the CPG III proposal, the Agency noted that industrial drums are
manufactured from different materials, each of which provides slightly different performance benefits.
Clearly, not all drums are used to contain all materials regardless of what material the drums are made from.
One of the criteria under RCRA Section 6002 for procuring designated items is that the items meet the
procuring agency's performance standards [6002(c)(l)(B)]. Should a procuring agency find that its
performance standards are not met by the designated item, they are not required to procure that item. The fact
that some procuring agencies might make this determination for this, or any other designated item, does not
preclude the item from being designated. Based on EPA's research, and as stated in the proposed CPG III and
draft RMAN III, industrial drums containing various recovered materials can meet DOT specifications for
packaging, including those for hazardous materials. Based on EPA's research, the Agency will finalize the
153
-------
proposed designation for industrial drums and revise the recommended recovered materials content level for
steel drums based on the general comments received from SRI.
3. Rationale for Designation
EPA believes that industrial drums satisfy the statutory criteria for selecting items for designation.
a. Use of Materials in Solid Waste
Industrial drums are made with recovered and postconsumer steel, HDPE, and paperboard. Appendix
I of this document discusses the generation and recovery of these materials in MSW.
b. Technically Proven Uses
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 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. A table listing the drum
packaging groups can be found in the document entitled "Background Document for Proposed CPG III and
Draft RMAN III."
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
steel because all steel drums contain at least 25 percent postconsumer recovered materials. Recovered
materials 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
154
-------
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 Ib). 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.
The Plastic Drum Institute (PDI) claims that there are no performance issues associated with recovered
materials 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.
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 ACR, there are over 100 drum reconditioners.
EPA identified two plastic drum manufacturers and one fiber drum manufacturer producing recovered
materials content drums. The manufacturers declined to identify the number of drums produced, citing
reasons of confidentiality. The recovered materials content fiber drum manufacturer stated that approximately
half of the drums they manufacture contain recovered materials. One of the recovered materials 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 materials content steel drums.
155
-------
c. Impact of Government Procurement
A 1994 survey of 28 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.
An SSCI 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.
156
-------
4.
Designation
EPA is designating industrial drums containing recovered steel, plastic, and fiber. This designation
does not preclude a procuring agency from purchasing industrial drums made from other materials. It simply
requires that a procuring agency, when purchasing industrial drums made from steel, plastic, or fiber,
purchase this item with recovered materials when this item meets applicable specifications and performance
requirements.
5. Preference Program
With the exception of steel, which has been revised to reflect the comment submitted by SRI on
postconsumer and recovered content, EPA is recommending the draft recommendations in the final RMAN
III. EPA recommends that, based on the recovered material levels shown in Table 29 and the corresponding
table in the RMAN III, procuring agencies establish minimum content standards for use in purchasing
industrial drums.
Table 29
Final Recovered Materials Content Recommendations for Steel, Plastic,
and Fiber Industrial Drums
Product
Steel drums
Plastic drums
Fiber drums
Material
Steel
HDPE
Paper
Postconsumer
Content (%)
16
30-100
100
Total Recovered
Materials Content (%)
25-30
30-100
100
Notes: EPA's recommendation does not preclude a procuring agency from purchasing another type of industrial drum. It simply requires that
procuring agencies, when purchasing steel, plastic, or fiber industrial drums, purchase these items made with recovered materials when these
items meet applicable specifications and performance requirements.
The recommended recovered materials content levels for steel in this table reflect the fact that the designated items are made from steel
manufactured in a Basic Oxygen Furnace (BOF). Steel from the BOF process contains 25-30% total recovered materials, of which 16% is
postconsumer steel.
157
-------
6. Background for Recommendations
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. SSCI estimates that 35 million new steel drums were manufactured in 1995 and, according to 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 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.
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.
158
-------
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.
Table 30 shows information EPA obtained on the recovered materials content of industrial drums.
Table 30
Recovered Materials Content of Industrial Drums
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
Plastic
Steel
Fiber
Company A: 100
Company B: Unknown
Company C: Unknown
Company D: 100
100
30-35
25-100
100
7. Specifications
In July 1996, the United Nations 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 United Nations Committee of Experts meeting
in December 1996 and will be published in the 10th revised edition of the United Nation's Recommendations
on the Transport of Dangerous Goods.
The United Nations 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
159
-------
verification that each batch of 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."
On March 5, 1999, DOT amended its Hazardous Materials Regulations to maintain alignment with
international standards, including the UN recommendations. DOT passed a final rule—Harmonization with
the United Nations Recommendations, International Maritime Dangerous Goods Code, and International
Civil Aviation Organization's Technical Instructions (43 FR 10741)—which added anew approval provision
to allow the use of recycled plastics material for the manufacturing of plastic drums and jerricans.
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. Background
In Section 247.17(d), EPA proposed to designate awards and plaques containing recovered materials.
In Section H-4 of the accompanying draft RMAN III, EPA recommended that awards and plaques contain
the levels of recovered materials listed in Table 31.
160
-------
Table 31
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
Note: EPA's recommendations do not preclude a procuring agency from purchasing awards and plaques made from other materials. They
simply require that procuring agencies, when purchasing awards or plaques made from paper, wood, glass, or plastics/plastics composites,
purchase them made with recovered materials when these items meet applicable specifications and performance requirements.
2. Summary of Comments and Agency's Response
Comment: DOE submitted comments supporting the designation of awards and plaques containing
recovered materials. DOE indicated that one of its sites has made an effort to reuse excess, unclassified,
nonhazardous, and nonradioactive nuclear weapons components as awards.
Comment: Lockheed Martin Idaho Technologies Company submitted comments stating that, due to
the fact that only 6 out of 13,000 manufacturers and distributors use recovered materials, it believes a
competition or availability exemption will exist for these products in most cases. Lockheed Martin Idaho
Technologies Company does not believe tracking and reporting should be required when competition is not
likely to exist.
Response: EPA's background discussion of its rationale for proposing to designate awards and
plaques was not meant to imply that only 6 out of 13,000 manufacturers and distributors of awards and
plaques use recovered materials. It was merely a statement of fact. EPA identified 13,000 sources of these
items and identified 6 suppliers that offered the items with recovered materials.
161
-------
EPA does not agree with the commenter's assertion that because only six manufacturers were
identified by EPA that adequate competition does not exist and, that by implication, the items should not be
designated. Section 6002 (e)(l) of RCRA stipulates that, in designating items, the guidelines shall
"...designate items that are or can be made with recovered materials..." and that "...the availability of such
items..." shall be considered. While EPA makes every effort to identify manufacturers and distributors of
items proposed for designation, this research is not exhaustive nor does it seek to identify all sources of the
proposed items. EPA acknowledges that some agencies might be unable to obtain some designated items
regionally for one or more of the reasons cited in RCRA Section 6002(c)(l). If this is the case, EPA
recommends that the procuring agency simply include a statement in its APP that states the item is currently
not available and, therefore, the agency has concluded that it is not required to procure this item. Once an
agency makes the aforementioned determination, no recordkeeping or tracking of the item would be
required. EPA notes that, in accordance with 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.
3. Rationale for Designation
EPA believes that awards and plaques satisfy the statutory criteria for selecting items for designation.
a. Use of Materials in 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
materials 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.
162
-------
b. Technically Proven Uses
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 materials content awards are generally
made from blown glass, while plaques are made from various materials, including compressed newsprint and
sawdust.
The promotional products industry has grown from $5 billion a year in 1990 to more than $8 billion
in 1995. A Promotional Products Association (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.
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.
c. Impact of Government Procurement
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.
163
-------
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.
4. Designation
EPA is designating awards and plaques containing recovered glass, wood, paper, plastic, and
plastic/wood composite. This designation does not preclude a procuring agency from purchasing awards and
plaques made from other materials. It simply requires that a procuring agency, when purchasing awards and
plaques made from glass, wood, paper, plastic, and plastic/wood composite, purchase this item with
recovered materials when this item meets applicable specifications and performance requirements.
5. Preference Program
EPA is recommending the draft recommendations in the final RMAN III. EPA recommends that,
based on the recovered material levels shown in Table 32 and the corresponding table in the RMAN III,
procuring agencies establish minimum content standards for use in purchasing awards and plaques.
164
-------
Table 32
Final Recovered Materials Content Recommendations
for Awards and Plaques Containing Recovered Materials
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
Note: EPA's recommendations do not preclude a procuring agency from purchasing awards and plaques made from other materials. They
simply require that procuring agencies, when purchasing awards or plaques made from paper, wood, glass, or plastics/plastics composites,
purchase them made with recovered materials when these items meet applicable specifications and performance requirements.
6. Background for Recommendations
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 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.
Table 33 presents information provided by manufacturers on the recovered materials content of
awards and plaques.
165
-------
Table 33
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)
7. Specifications
EPA did not identify any specifications or standards regarding awards and plaques.
D. Mats
1. Background
In Section 247.17(e), EPA proposed to designate mats containing recovered materials. In Section H-5
of the accompanying draft RMAN III, EPA recommended that mats contain the levels of recovered materials
listed in Table 34.
166
-------
Table 34
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
Note: EPA's recommendations do not preclude a procuring agency from purchasing mats made from other materials. They simply require
that procuring agencies, when purchasing mats made from rubber and/or plastic, purchase them made with recovered materials when these items
meet applicable specifications and performance requirements.
2. Summary of Comments and Agency's Response
Comment: DOE submitted comments to support the designation of mats containing recovered rubber
and plastic but recommends that EPA add a requirement that all mats containing steel or metal linkages
contain recovered materials as well. EPA also should include mats manufactured from scrap tires in its
designation.
Response: Although EPA did not include RMAN III recommendations for aluminum or steel frames
and linkages used in mats, the discussion of mats in the proposed CPG III did state that "EPA's research
found that mats made with recovered materials are limited to rubber and/or plastic mats which can also
include aluminum or steel linkages or frames made from recovered metals" (See 63 FR 45571 - 45572). So
that this point is more discernable, EPA will revise Table H-5 in the final RMAN III to mention that steel and
aluminum linkages used for mats should also contain recovered materials. With respect to the commenters
request to include mats manufactured from scrap tires, EPA notes that the RMAN has recommended
recovered materials content ranges forpostconsumer rubber in mats, which would include rubber from scrap
tires. In fact, on page 154 of the proposed CPG Ill/draft RMAN III background document, EPA provides an
example of one manufacturer who stated that it uses more than 45,000 nonradial truck tires to produce its
rubber mats.
167
-------
Comment: GSA indicated that "72 I A" should be added after "GSA schedule" on page 45572,
paragraph 2c, line 20 of the CPG. In addition, GSA suggested that EPA note that athletic and recreational
mats are available from GSA Schedule 78 I A.
Response: EPA will add the GSA schedule numbers in the final CPG/RMAN III and make mention of
the fact that athletic and recreational mats are available through the GSA schedule as noted in the comment.
Comment: SI produces a white, nonwoven printable fabric made from polyester staple fibers. SI
believes the designation of mats is overly broad and does not meet the "technically proven uses" statutory
criteria. SI believes that colored or clear specialty mats made from polyester fibers cannot be made from
postconsumer materials. According to SI, the inconsistency of postconsumer material results in an off-gray
color when trying to produce a pure white mat suitable for printing. SI, therefore, urges EPA to obtain
additional data on the technological and economic feasibility of making colored polyester mats at the
postconsumer levels proposed in the RMAN.
Response: EPA disagrees with the commenter's general assertion that the designation of mats does
not meet the "technically proven uses" criteria found in the statute. Based on the research conducted by EPA
for the proposed CPG III/RMAN III, the Agency identified 44 manufacturers, distributors, and suppliers of
mats containing recovered materials. These sources make or distribute a variety of types of mats including,
but not limited to: antifatigue, golf, hockey, truck beds, boat decks, boat docks, exercise, floor, livestock, and
entrance mats. In addition, as stated in the proposed CPG III, some manufacturers believe that between 75
and 95 percent of all mats manufactured in the United States do contain some percentage of postconsumer
materials (63 FR 45572).
The Agency also disagrees with the commenter's conclusion that the RMAN ranges are improper for
colored and clear mats (containing polyester) since, according to the commenter, white and clear specialty
mats cannot be made with postconsumer content. EPA's research and the recovered materials content ranges
shown in the draft RMAN III represent the ranges at which products are currently being made with recovered
plastics. Some mats are being made with postconsumer polyester fibers with a 10 percent postconsumer
content level that falls within the Agency's recovered materials content range of 10 percent to 100 percent.
Clearly, there are technical and/or market conditions that allow different plastic resins to be used at different
168
-------
percentages. This is precisely why the Agency recommends a range of content levels. Agencies can choose
to purchase mats within the range recommended by EPA or set different standards for the designated items
based on the items' availability, price, or performance requirements. Since the commenter showed particular
interest in the postconsumer content level of specialty mats (white for printing and clear), those agencies
procuring such mats could purchase these items at different recovered materials content levels (e.g., less than
the low end of the recommended ranges in the RMAN) or justify not procuring these items if the items do not
meet their specifications or performance requirements, which could include color and/or printability.
3. Rationale for Designation
EPA believes that mats satisfy the statutory criteria for selecting items for designation.
a. Use of Materials in 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. Technically Proven Uses
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.
169
-------
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.
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.
c. Impact of Government Procurement
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 2
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.
4. Designation
EPA is designating mats containing recovered rubber, plastic, and rubber/plastic composite. This designation
does not preclude a procuring agency from purchasing mats made from other materials. It simply
170
-------
requires that a procuring agency, when purchasing mats made from rubber, plastic, and rubber/plastic
composite, purchase this item with recovered materials when this item meets applicable specifications and
performance requirements.
5. Preference Program
EPA is recommending the draft recommendations in the final RMAN III. EPA recommends that,
based on the recovered material levels shown in Table 35 and the corresponding table in the RMAN III,
procuring agencies establish minimum content standards for use in purchasing mats.
Table 35
Final 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
Note: EPA's recommendations do not preclude a procuring agency from purchasing mats made from other materials. They simply require
that procuring agencies, when purchasing mats made from rubber and/or plastic, purchase them made with recovered materials when these items
meet applicable specifications and performance requirements. The Agency also recommends that when purchasing mats with steel or aluminum
linkages, that these linkages should also contain recovered materials.
6.
Background for Recommendations
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.
171
-------
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.
Table 36 displays recovered content information obtained by EPA from manufacturers of recovered
content mats.
172
-------
Table 36
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
Company N: 98
Company O: 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
Total Recovered
Materials Content (%)
92
60
100
30
92-98
90
40-92
100
75-95
75-95
100
100
90
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
173
-------
Material
Plastic
Mixed (Plastic/Rubber)
Postconsumer Content (%)
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 (%)
100
100
100
100
100
100
50
100
50
100
100
7.
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.
E. Signage
1. Background
In Section 247.17(f), EPA proposed to designate signage containing recovered materials. In Section
H-7 of the accompanying draft RMAN III, EPA recommended that signage contain the levels of recovered
materials listed in Table 37.
174
-------
Table 37
Draft Recovered Materials Content Recommendations for Signage
Item/Material
Plastic signs
Aluminum signs
Plastic sign posts/supports
Steel sign posts/supports
Postconsumer Content (%)
80-100
25
80-100
25-100
Total Recovered
Materials Content (%)
80-100
25
80-100
25-100
Notes: EPA's recommendations do not preclude a procuring agency from purchasing signs or sign posts made from other materials. They
simply require that procuring agencies, when purchasing signs made from plastic or aluminum or sign posts made from plastic or steel, purchase
these items made with recovered materials when these items meet applicable specifications and performance requirements.
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.
2. Summary of Comments and Agency's Response
EPA did not receive any comments specific to the proposed designation for signs. The general
comments submitted by SRI pertaining to the recovered materials content of all steel products pertain to steel
signs and posts/supports. The recommendations contained in the RMAN will be revised accordingly.
3. Rationale for Designation
EPA believes that signage satisfies the statutory criteria for selecting items for designation.
a. Use of Materials in 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.
175
-------
HDPE: If the federal government purchased 1,000 64-pound HDPE 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. Technically Proven Uses
Plastic Road Signs
Conventional road signs can be manufactured from 3/8- to 3/4-inch thick HDPE or PET recycled
materials 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 plastic signs,
176
-------
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 longer—from 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 aluminum—20 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 recovered materials 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
reinforced signs. In 1980, the Texas Department of Transportation (TxDOT) tested several types of fiberglass
road signs and found that pure fiberglass was too brittle and did not stand up to moderate wind
177
-------
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.
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 possess (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.
178
-------
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.
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 HDPE, 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 NPS 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 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.
179
-------
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
Recovered materials are commonly used in the manufacture of sign posts and supports. Sometimes
sign posts 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.
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 materials content plastic posts are manufactured by several
companies.
c. Impact of Government Procurement
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
180
-------
agencies (the NPS and the Forest Service) currently purchasing nonroad plastic signs containing recovered
materials.
Nonroad Signs
EPA contacted purchasers of routed plastic informational signs at NPS 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 materials content HOPE signs
indicated an increase in demand for these signs over the past 3 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
NFS, 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
181
-------
MONTANA
U.S. Forest Service, Northern Region, Missoula
NEVADA
Lake Tahoe Nevada State Park, Incline Village
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.
182
-------
4. Designation
EPA is designating signage containing recovered plastic, aluminum, and steel. This designation does
not preclude a procuring agency from purchasing signage made from other materials. It simply requires that a
procuring agency, when purchasing signage made from plastic, aluminum, or steel, purchase this item with
recovered materials when this item meets applicable specifications and performance requirements.
5. Preference Program
With the exception of steel, which has been revised to reflect the comment submitted by SRI
regarding the postconsumer and recovered materials content, EPA is recommending the draft
recommendations in the final RMAN III. EPA recommends that, based on the recovered material levels
shown in Table 37 and the corresponding table in the RMAN III, procuring agencies establish minimum
content standards for use in purchasing plastic signs for nonroad applications and aluminum signs for
roadway or nonroad applications containing recovered materials. EPA also recommends that, based on the
recovered materials content levels shown in Table 38, procuring agencies establish minimum content
standards for use in purchasing sign supports and posts containing recovered plastic or steel.
183
-------
Table 38
Final Recovered Materials Content Recommendations for Signs Containing Recovered Plastic or
Aluminum and Sign Posts/Supports Containing Recovered Plastic or Steel
Item/Material
Plastic signs
Aluminum signs
Plastic sign posts
Steel sign posts
Postconsumer Content (%)
80-100
25
80-100
16
67
Total Recovered
Materials Content (%)
80-100
25
80-100
25-30
100
Notes: EPA's recommendations do not preclude a procuring agency from purchasing signs or sign posts made from other materials. They
simply require that procuring agencies, when purchasing signs made from plastic or aluminum or sign posts made from plastic or steel, purchase
them made with recovered materials when these items meet applicable specifications and performance requirements.
Plastic signs and sign posts are recommended for nonroad applications only such as, but not limited to, railway signs in parks and
directional/informational signs in buildings.
The recommended recovered materials content levels for steel in this table reflect the fact that the designated items can be made from
steel manufactured in either a Basic Oxygen Furnace (BOF) or an Electric Arc Furnace (EAF). Steel from the BOF process contains 25-30%
total recovered materials, of which 16% is postconsumer steel. Steel from the EAF process contains a total of 100% recovered steel, of which
67% is postconsumer.
6.
Background for Recommendations
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.
184
-------
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 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,
185
-------
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.
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 HOPE 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.
186
-------
Sign Supports and Posts
Sign posts 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.
Table 39 displays recovered content information obtained by EPA from manufacturers on signage.
Table 39
Recovered Materials Content of Signage
Material
Postconsumer Content (%)
Total Recovered
Materials Content (%)
HDPE
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
7.
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
187
-------
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).
F. Manual-Grade Strapping
1. Background
In Section 247.17(g), EPA proposed to designate manual-grade strapping containing recovered
materials. In Section H-6 of the accompanying draft RMAN III, EPA recommended that manual-grade
strapping contain the levels of recovered materials listed in Table 40.
Table 40
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
Note: EPA's recommendations do not preclude a procuring agency from purchasing another type of strapping, such as nylon. They simply
require that procuring agencies, when purchasing polyester, polypropylene, or steel manual-grade strapping, purchase these items made with
recovered materials when these items meet applicable specifications and performance requirements.
188
-------
2. Summary of Comments and Agency's Response
Comment: Lockheed Martin Idaho Technologies Company commented that while they recognize
many manufacturers produce strapping with PET and PP, it does not believe a sufficient supplier base exists
for strapping containing the other proposed materials.
Response: Since EPA proposed to designate manual-grade strapping containing both recovered steel
or plastic, the Agency presumes the comments submitted pertain to manual grade strapping containing
recovered steel. EPA based its proposal on the fact that manual-grade strapping is currently being made from
recovered steel and there is an ASTM specification for steel strapping (ASTM D3953). EPA believes,
therefore, that recommending recovered materials content levels for steel strapping is justified. In addition,
based on comments submitted by SRI pertaining to the recovered materials content in steel products (see
"General Comments" section), all items included in the proposed CPG III can be made with steel made from
either the EOF or EAF process, both of which contain recovered materials content. EPA will revise its final
RMAN III recommendations for manual-grade steel strapping to take into account SRI's general comment.
3. Rationale for Designation
EPA believes that manual-grade strapping satisfies the statutory criteria for selecting items for
designation.
a. Use of Materials in 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
189
-------
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 materials 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 materials content PET strapping is between 1
and 22 pounds, with postconsumer materials accounting for as much as 16.5 pounds per coil. 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. Technically Proven Uses
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
190
-------
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.
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
191
-------
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 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.
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.
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.
192
-------
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 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, most steel items can be manufactured with steel made by both EOF and EAF
processes. SRI noted that items made by the EOF process typically contain 25 to 30 percent recovered
materials, including more than 15 percent postconsumer steel. When items are made out of steel
manufactured by the EAF process, they may contain up to 100 percent recovered materials, including 67
percent postconsumer steel. Given the stable market for steel, manufacturing steel strapping with recovered
materials content should remain economically feasible.
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.
c. Impact of Government Procurement
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
193
-------
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 on palletized
goods and materials that it receives. GPO, for example, specifies the use of strapping 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 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 7, "Specifications."
4. Designation
EPA is designating manual-grade strapping containing recovered steel or plastic. A final designation
does 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
5. Preference Program
With the exception of steel, which has been revised to reflect the comment submitted by SRI
regarding the postconsumer and recovered materials content, EPA is recommending the draft
recommendations in the final RMAN III. EPA recommends that, based on the recovered material levels
194
-------
shown in Table 41 and the corresponding table in the RMAN III, procuring agencies establish minimum
content standards for use in purchasing manual-grade strapping containing recovered materials.
Table 41
Final Recovered Materials Content Recommendations for Manual-Grade Polyester, Polypropylene, and
Steel Strapping
Product
Polyester strapping
Polypropylene strapping
Steel strapping
Material
PET
PP
Steel
Postconsumer Content
(%)
50-85
~
16
67
Total Recovered
Materials Content (%)
50-85
10-40
25-30
100
Notes: EPA's recommendations do not preclude a procuring agency from purchasing another type of strapping, such as nylon. They simply
require that procuring agencies, when purchasing polyester, polypropylene, or steel manual-grade strapping, purchase these items made with
recovered materials when these items meet applicable specifications and performance requirements.
The recommended recovered materials content levels for steel in this table reflect the fact that the designated items can be made from
steel manufactured in either a Basic Oxygen Furnace (BOF) or an Electric Arc Furnace (EAF). Steel from the BOF process contains 25-30%
total recovered materials, of which 16% is postconsumer steel. Steel from the EAF process contains a total of 100% recovered steel, of which
67% is postconsumer.
6.
Background for Recommendations
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.
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 marketplace—steel, 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
195
-------
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.
Table 42 lists the recovered materials used in the products of companies that manufacture strapping.
Table 42
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
196
-------
7. Specifications
A table of specifications and guidance for breaking strength, elongation, and other characteristics of
various types of strapping and stretch wrap can be found in the document entitled, "Background Document
for Proposed CPG III and Draft RMAN III. These specifications neither recommend nor preclude the use of
recovered materials.
197
-------
XIII. 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 III, 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
198
-------
Cenospheres
Aggregates
Concrete containing silica fume
Transportation Products
Embankments
Threshold ramps
Nonpaper 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 two additional 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 is no
longer conducting research relative to these items or considering them for designation in a future CPG.
However, the Agency will review any information submitted in support of designating these items in the
future to determine whether these items should be reconsidered.
199
-------
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. EPA did learn 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.
However, as there is little, if any, activity to manufacture recycled content ink as a stand-alone product, EPA
cannot designate this item. As mentioned above, EPA only identified one manufacturer producing and selling
recycled ink.
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.
XIV. 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.
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.
200
-------
XV. 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, July 14, 1999, which is included in the
RCRA Docket for CPG III.
XVI. OTHER 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 Byproduct—Production 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.
"Processing and Potential Applications of Fly Ash—Aluminum (Ash Alloy) Composite," University of
Wisconsin, 1995.
"Development and Characterization of a Closed Pore Insulation Material," Grumman Aerospace Corporation,
1976.
201
-------
"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.
202
-------
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. Multimaterial
"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: 1998 Update," U.S. EPA, EPA530-R-99-021,
September 1999.
"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, n.d.
"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.
203
-------
"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 Web site , created by Eastern Research Group, 1997.
204
------- |