Guidance on Conducting Inspections of Federal
Facilities for Compliance with Section 6002 of
the
Resource Conservation and Recovery Act
May 12, 1999 EPA 3QQ-B-Q2-QQ5
This guidance is intended to assist EPA and State compliance inspectors determine
compliance with EPA guidelines on procuring recycled content products by all Federal
facilities. To promote compliance with the guidelines, this guidance is being made
available to Federal facilities.
INTRODUCTION: On September 14, 1998, President Clinton signed Executive Order 13101:
" Greening the Government Through Waste Prevention, Recycling and Federal Acquisition." Section
403 of the Order directed that EPA develop guidance for inspections of Federal facilities for
compliance with the buy-recycled program established under section 6002 of the Resource
Conservation and Recovery Act (RCRA). The guidance is to be used by EPA whenever the Agency
conducts RCRA inspections or multi-media regulatory compliance inspections where RCRA
compliance is a component of the inspection. The guidance may also be used by States authorized
to conduct inspections under RCRA.
EXECUTIVE ORDER 13101
GREENING THE GOVERNMENT THROUGH WASTE
PREVENTION, RECYCLING, AND FEDERAL ACQUISITION
Sec. 403. Federal Facility Compliance, (a) Within 6 months of the date of this
order, the Administrator of the EPA shall, in consultation with the Federal
Environmental Executive, prepare guidance for use in determining Federal facility
compliance with section 6002 of RCRA and the related requirements of this order.
(b) EPA inspections of Federal facilities conducted pursuant to RCRA and the
Federal Facility Compliance Act and EPA "multi-media" inspections carried out at
Federal facilities will include, where appropriate, evaluation of facility compliance with
section 6002 of RCRA and any implementing guidance.
(c) Where inspections of Federal facilities are carried out by authorized States
pursuant to RCRA and the Federal Facility Compliance Act, the Administrator of the
EPA will encourage those States to include evaluation of facility compliance with
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section 6002 of RCRA in light of EPA guidance prepared pursuant to subsection (a),
where appropriate, similar to inspections performed by the EPA. The EPA may
provide information and technical assistance to the States to enable them to include
such considerations in their inspection.
(d) The EPA shall report annually to the Federal Environmental Executive on the
results of inspections performed by the EPA to determine Federal facility compliance
with section 6002 of RCRA not later than February 1st for those inspections conducted
during the previous fiscal year.
INSPECTION FOCUS: EPA has determined that for the first year of implementation,
inspection activities carried out pursuant to section 403 of the Order should focus primarily on
information collection. EPA compliance assistance programs will use this information to promote
Federal facility awareness of, and compliance with, RCRA section 6002 requirements. To ensure
federal facility compliance with RCRA section 6002 in the future, EPA's response to non-
compliance with that section may change.
E,
f NFORCEMENT: Violations of RCRA section 6002 by federal agencies do not give rise to
administrative penalty actions or orders under RCRA's enforcement authorities. This conclusion does
not, however, limit EPA's authority to issue notices of violation (NOV) or enter into compliance
agreements at Federal facilities for violations of RCRA section 6002 that are discovered through the
inspections mandated by Executive Order 13101. Moreover, citizens may take action pursuant to
RCRA section 7002 for violations of RCRA 6002 requirements.
B
' ACKGROUND: When the Resource Conservation and Recovery Act (RCRA) was enacted
in 1976, Congress stated that obj ectives of the statute included the conservation of resources through
recycling. Recognizing that recycling works best if there are markets for the materials collected,
Congress directed the Federal government to employ its purchasing power to help create and sustain
those markets by buying products manufactured with the collected materials. Section 6002 of RCRA
establishes the Federal program that directs federal purchasing decisions for recycled content
products.
B
>UY RECYCLED PROGRAM: Section 6002 of RCRA establishes a Federal buy-recycled
program. RCRA section 6002(e) requires EPA to: (1) designate items that are or can be made with
recovered materials and (2) prepare guidelines to assist procuring agencies in complying with
affirmative procurement requirements set forth in subsections (c), (d), and (i) of section 6002. Once
EPA has formally designated items, section 6002 requires that any procuring agency using
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appropriated Federal funds must purchase those items composed of the highest percentage of
recovered materials practicable.
RCRA §6002: Federal Procurement
(c)(l)... each procuring agency which procures any items designated in such guidelines shall procure
such items composed of the highest percentage of recovered materials practicable ....
(e) The Administrator shall... prepare ... guidelines for the use of procuring agencies .... Such
guidelines shall designate those items which are or can be produced with recovered materials ....
P
ROCURING AGENCIES: For the purposes of RCRA section 6002, procuring agencies
include the following:
1. any Federal agency;
2. any State or local agencies using appropriated Federal funds for a procurement, or
3. any contractors with these agencies (with respect to work performed under the
contract).
The requirements of RCRA section 6002 apply to such procuring agencies only when
procuring designated items where the price of the item exceeds $10,000 or the quantity of the item
purchased in the previous year exceeded $10,000. The $10,000 threshold applies to all purchases
made by an entire agency rather than regional or local offices (e.g., Department of the Interior,
Department of Defense, etc). Most Federal agencies exceed the $10,000 threshold for EPA
designated items.1
c
1PG ITEMS: The Comprehensive Procurement Guidelines (CPG) designate those items
that must contain recycled content when purchased by Federal agencies. The CPG acknowledges,
however, that specific circumstances may arise that preclude the purchase of products made with
recovered materials.
1 Section 403 of Executive Order 13101 states that inspections carried out under the
Order 13101 are to be conducted at Federal facilities; state and local agencies using appropriated
funds will not be included in these inspections. Government owned , contractor operated (GOCO)
facilities are considered Federal facilities for the purposes of this guidance.
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...for the EPA-designated guideline items,... and for all future designated guideline
items, agencies shall ensure that their affirmative procurement programs requirelOO
percent of their purchases of products to meet or exceed the EPA guideline unless
written justification is provided that a product is not available competitively within a
reasonable time frame, does not meet appropriate performance standards, or is only
available at an unreasonable price. (EO 13101, Sec. 402 (c)).
Designated items that do not contain recovered materials may be purchased if it is determined that:
1. the price of a given designated item made with recovered materials is unreasonably high,
2. there is inadequate competition (not enough sources of supply),
3. unusual and unreasonable delays would result from obtaining the item, or
4. it does not meet the agency's reasonable performance specifications.
D
ESIGNATED ITEMS: To date, the EPA Comprehensive Procurement Guidelines (CPG)
program has designated 36 products in 8 product categories. In 1998, EPA proposed to designate
an additional 19 products; EPA expects those products to be formally listed in June of 1999. EPA
research indicates that the designated items are of high quality, are widely available, and cost-
competitive with products made from virgin materials. Moreover, Government procurement of these
products will create markets for a variety of recycled materials that make up a large part of the
municipal waste stream, including various types of paper, used tires, oil and antifreeze, plastics, steel,
and yard debris. Purchase of the guideline items also creates markets for non-hazardous industrial
wastes that are generated in large quantities, such as coal fly ash and blast furnace slag.
A key component of the CPG program is EPA's list of designated products and the
accompanying recycled content recommendations. EPA has already designated or has proposed
designating the products listed below. EPA has also published final or proposed recycled content
recommendations for each item. All proposals, designations and recommendations are published in
the Federal Register. Additional information on the CPG designated items and content
recommendations can be found on the World Wide Web at
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EPA Designated and Proposed CPG Items
CONSTRUCTION PRODUCTS
Designated:
•Building insulation products
•Polyester Carpet
•Cement and concrete containing:
-Coal fly ash
-Ground granulated blast furnace slag
•Consolidated and reprocessed latex paint
•Floor tiles
•Laminated paperboard
•Patio blocks
•Shower and restroom dividers/partitions
•Structural fiberboard
Proposed:
•Carpet backing
•Carpet cushion
•Flowable fill
•Railroad grade crossings/surfaces
LANDSCAPING PRODUCTS
Designated:
•Garden and soaker hoses
• Hydraulic mulch
• Lawn and garden edging
• Yard trimmings compost
Proposed:
• Food waste compost
• Landscaping timbers and posts (plastic lumber)
NON-PAPER OFFICE PRODUCTS
Designated:
• Binders (paper, plastic covered)
• Office recycling containers
• Office waste receptacles
• Plastic desktop accessories
• Plastic envelopes
• Plastic trash bags
• Printer ribbons
• Toner cartridges
Proposed:
• Plastic binders (solid)
• Plastic clipboards
• Plastic clip portfolios
• Plastic file folders
• Plastic presentation folders
PAPER AND PAPER PRODUCTS
Designated:
• Commercial/industrial sanitary tissue products
• Miscellaneous papers
• Newsprint
• Paperboard and packaging products
• Printing and writing papers
Proposed:
• None at this time.
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PARK AND RECREATION PRODUCTS
Designated:
• Plastic fencing
• Playground surfaces
• Running tracks
Proposed:
• Park and recreational furniture
• Playground equipment
TRANSPORTATION PRODUCTS
Designated:
• Channelizers
• Delineators
• Flexible delineators
• Parking stops
• Traffic barricades
• Traffic cones
Proposed:
• None at this time.
VEHICULAR PRODUCTS
Designated:
• Engine coolants
• Re-refined lubricating oils
• Retread tires
Proposed:
• None at this time.
MISCELLANEOUS PRODUCTS
Designated:
• Pallets
Proposed:
• Sorbents
• Awards and plaques
• Industrial drums
• Mats
• Signage
• Strapping and stretch wrap
!VE<
^COVERED MATERIAL RECOMMENDATIONS: For each of the designated and
proposed products, EPA has issued a Recovered Materials Advisory Notice (RMAN) which
establishes the recommended recycled content level for a given product. In most circumstances,
minimum content recommendations are provided for both postconsumer recycled content and
recovered material levels. "Postconsumer material" means a material or finished product that has
served its intended 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 material." "Recovered materials" mean waste materials and byproducts that have been
recovered or diverted from solid waste, but such term does not include those materials and by-
products generated from, and commonly reused within, an original manufacturing process.
Exhibit 1 below provides an example of such an RMAN for the product "Building Insulation."
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Exhibit 1: EPA's Recommended Recovered Materials Content Levels for Building Insulation
Product
Rock Wool
Fiberglass
Cellulose Loose-Fill
and Spray-On
Perlite Composite
Board
Plastic Rigid Foam,
Polyi socyanurate/
Polyurethane:
Rigid Foam
Foam-in-Place
Glass Fiber
Reinforced
Phenolic Rigid Foam
Plastic, Non-Woven
Batt
Material
Slag
Glass Gullet
Postconsumer Paper
Postconsumer Paper
—
~
Recovered and/or
Postconsumer
Plastics
Postconsumer
Content (%)
—
-
75
23
—
~
—
Total Recovered
Materials Content
(%)
75
20-25
75
23
9
5
6
5
100
In other circumstances, where specific recycled material content is not appropriate or where
on-site management of the designated items may be more effective, the RMAN may indicate a
preference for an activity over a given level of recovered material. An example of this type of
RMAN, for engine coolants, is presented in Exhibit 2 below.
Exhibit 2:Recommended Recovered Materials Content Ranges - Coolants:
EPA recommends that procuring agencies whose vehicles are serviced by a motor pool or
vehicle maintenance facility establish a program for engine coolant reclamation and reuse that
consists of either reclaiming the spent engine coolants onsite for use in the agencies' vehicles or
establishing a service contract for reclamation of the agencies' spent engine coolant for use in
the agencies' vehicles.
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EPA also recommends that procuring agencies request reclaimed engine coolant when having
their vehicles serviced at commercial service centers. Additionally, EPA recommends that
agencies purchase reclaimed engine coolant when making direct purchases of this item, such as
when necessary to make up for losses due to leakage or spillage
EPA does not recommend one type of engine coolant over another. EPA recommends,
however, that procuring agencies purchase engine coolant containing only one base chemical,
typically ethylene glycol or propylene glycol, to prevent the commingling of incompatible types
of engine coolant.
To facilitate ease of implementation, the EPA RMAN documents also include known product
specifications as well as product information such as product manufacturers and suppliers.
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INSPECTION GUIDANCE:
During initial implementation of the requirement for EPA inspections at Federal facilities for
compliance with RCRA 6002, EPA has elected to focus on field level awareness of the RCRA 6002
requirements. As such, inspections at Federal facilities pursuant to RCRA and the Federal Facility
Compliance Act and EPA "multi-media" inspections carried out at Federal facilities, will include;
1) distribution of a questionnaire to the facility and,
2) inspection of the facility motor vehicle maintenance activities (where such activities exist)
for compliance with RCRA 6002 .
Motor vehicle maintenance activities were selected for this effort due to the:
1) common presence of such activities at a broad range of Federal facilities,
2) significant awareness and availability of products and services that meet the EPA guidelines
for vehicular products and,
3) likelihood that RCRA inspections would normally be conducted at these locations.
Inspectors should become familiar with the basic concepts of the CPG program and are
requested to briefly outline to facility personnel EPA's authority for both generating the CPG
designations under RCRA section 6002 and conducting inspections under section 403 of EO 13101.
While the introduction and background to this document provide a brief overview on this topic,
inspectors should contact RCRA personnel or the Federal Facility Coordinator in their Region for
additional information. Inspectors may also wish to contact the RCRA hotline at 800-424-3323 or
search the Internet at http://www.epa.gov/cpg/products/htm for further information.
FA,
iCILITY QUESTIONNAIRE: Attached to this document is a questionnaire
including a matrix addressing facility purchase and use of CPG items. The questionnaire and matrix
should be provided to the facility environmental manager for response. The questionnaire requests
that the manager, in coordination with the facility procurement manager, provide a response to each
written question and complete the matrix. Once completed, the entire package is to be mailed to EPA
Headquarters by the facility within two weeks of the inspection.
fSPECTIONl The CPG designation of "Vehicular Products" has been in existence for a
lengthy period of time and has received considerable attention in the Federal community. Therefore,
during the first year of implementing the inspections called for in EO 13101, EPA has elected to
gather information on facility compliance with this aspect of the CPG program.
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Inspectors should visit the facility motor vehicle maintenance facility if one exists. If the
facility is large and has more than one vehicle maintenance/service facility, the inspector should
request visit the largest facility (shop) which deals with cars, trucks and or tactical vehicles. If no
motor vehicle maintenance activities occur at the facility, certain questions in the following list may
be still relevant.
These recommended inspection protocols and questions are based on the EPA CPG
designated items in the category of Vehicular Products and reflects the RMAN for those products.
Some additional background questions are also included.
INSPECTION PROCEDURES AT A SPECIFIC FEDERAL FACILITY
MOTOR VEHICLE MAINTENANCE SHOP
RE-REFINED OILS AND LUBRICANTS:
BACKGROUND Re-refined lubricating oils include engine lubrication oil, hydraulic fluids, and gear
oils. EPA's designation specifically excludes marine and aviation oils. The recycling of used oil has
evolved from simply removing water, insolubles, and dirt, to the more complicated removal of heavy
metals, nitrogen, chlorine, and oxygenated compounds. Today, re-refined lubricating oil is subject to
the same stringent refining, compounding, and performance standards as virgin oil for use in
automotive, heavy-duty diesel, and other internal combustion engines, hydraulic fluids, and gear oils.
In addition, extensive laboratory testing and field studies have concluded that re-refined oil is
equivalent to virgin oil, passes all prescribed tests, and can even outperform virgin oil. In fact, the
three major U.S. automobile manufacturers now recognize that re-refined oil meets the performance
criteria in their warranties.
While oil that is removed from vehicles may be disposed of as a waste, it is generally kept for
pick-up by a recycling contractor. In some circumstances, the facility may burn the used oil in its
boilers to "recover" the heating value of the oil.
RMAN for RE-REFINED OILS. Recommended Recovered Materials Content Ranges:
EPA recommends that procuring agencies set their minimum re-refined oil content standard at the
highest level of re-refined oil that they determine meets the statutory requirements of RCRA section
6002(c)(l), but no lower than 25 percent re-refined oil.
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EPA recommends that procuring agencies review their procurement practices and eliminate those
which would inhibit or preclude procurement of lubricating oils containing re-refined oil. For
example, procuring agencies should avoid the practice of inviting bids and issuing contracts to do the
following:
• Supply a broad range of lubricating oil products on an "all or none" basis.
• Supply lubricating oils for an excessively long period of time.
• Deliver lubricating oils to geographic locations throughout the United States or to an excessively
broad geographic area.
• Supply excessively large contract quantities.
The Defense Logistics Agency (DLA) offers re-refined engine lubricating oils for diesel and non-
diesel vehicles. DLA also offers closed loop contracts for used oil removal and supply of re-refined
oil.
General questions:
Approximately how many vehicles (including aircraft) are serviced by the shop annually?
What type of vehicles are serviced? (e.g., sedans, trucks, heavy equipment, aircraft)
Specific questions regarding shop use of oil and lubricants:
What is the estimated annual consumption of oil and lubricants in the shop?
Does the shop use re-refined oil for replacement engine lubricating oils?
Does the shop use re-refined oil for replacement hydraulic fluids?
Does the shop use re-refined oil for replacement gear oils?
If the shop does not use re-refined oils for any or all of the uses, are they aware of the RCRA/CPG
requirement to do so?
If they are aware of the requirement to do so yet still do not use re-refined oils, what is their
explanation for not using these products?
Does their facility procurement process allow them to purchase re-refined oil? If not, what are the
barriers to such purchases?
Do they purchase oil for use in the shop using a government charge card at a commercial vendor
(e.g., K-Mart or Sears) outside of the facility?
What is the fate of used oil removed from the facility's vehicles?
If the oil is sent out to a recycler, do they know if it ultimately used for energy recovery or if it is re-
refined?
Shop inspection protocol:
Inspectors should ask to see the oil containers used by the facility. If the shop uses re-refined
products, these products can be recognized quickly by the label on the oil container. At some
facilities a bulk distribution apparatus that is fed by 55 gallon (or larger) drums of oil is used for shop
distribution of engine lubricating oils and hydraulic fluids. Like quart cans and one or five gallon jugs,
these drums are generally marked if their contents contain re-refined oil; the bulk distribution may not
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contain any markings reflecting re-refined content. Inspectors should record and include in their
inspection report whether the oil being used for engine lubrication, hydraulic fluid and gear oils is re-
refined.
RETREAD TIRES
BACKGROUND: For most cases, retread tires can be driven under the same conditions and at the
same speeds as new tires with no loss in safety or comfort. In fact, retread tires have been safely used
on school buses, trucks, cars, fire engines, and other emergency vehicles for years. Retreading tires
also helps conserve a valuable nonrenewable resource—oil. Every year, retreading saves more than
400 million gallons of oil in North America. Retread tires also help divert thousands of scrap tires
from disposal each year.
RMANfor RETREAD TIRES: Recommended Recovered Materials Content Ranges:
EPA recommends that procuring agencies purchase either tire retreading services for worn tires or
retread tires as replacement tires. The U.S. Army Tank-automotive Command (TACOM) recently
replaced the U.S. General Services Administration (GSA) as manager of tires, although GSA still
offers retreading services contracts for medium truck-bus tires. TACOM offers a specification,
Qualified Products List, and list of suppliers for retread tires. TACOM also is offering an inspection
program to assure the quality of retreading operations.
Questions regarding shop use of retread tires:
Approximately how many tires does the shop replace annually?
What type(s) of tires does the shop use (i.e., bus, heavy truck, medium truck, light truck, off-road,
passenger vehicle)?
Does the shop use retread tires? If so, for which types of tires?
Does the shop have in place an agreement or contract with a "retreader" to retread the facility's tires?
If the shop does not use retread tires for any or all of the uses, are they aware of the RCRA/CPG
requirement to do so?
If they are aware of the requirement to do so yet still do not use retread tires, what is their
explanation for not using these products?
Does their facility procurement process allow them to purchase retread tires? If not, what are the
barriers?
Do they purchase retread tires for use in the shop using a government charge card at a commercial
vendor (e.g., Bandag, Goodyear, or other retreader) outside of the facility?
What is the fate of used tires removed from the facility's vehicles?
Shop inspection protocol: Inspectors should be aware that a facility might be using retread truck tires
but not retread passenger tires because of availability problems or performance concerns. Inspectors
should ask to see replacement tires stored for use by the facility. If the shop uses retread products,
these products can generally be recognized quickly by the label on the side of the tire or actual
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markings remaining from the retread process. If there are vehicles in the shop for repair, inspectors
should determine whether the tires on a representative sample of those vehicles are retread tires.
Inspectors should record and include in their inspection report whether the tires being used at the
facility are retread tires.
ENGINE COOLANT
BACKGROUND. Recycled engine coolants, also known as antifreeze, might actually be purer than
virgin coolant because the recycling process reduces the chlorides that come from hard water. Testing
shows that, like new coolant, recycled coolant meets nationally recognized performance specifications
established by the American Society for Testing Materials (ASTM) and the Society of Automotive
Engineers (SAE).
RMANfor Engine Coolants. Recommended Recovered Materials Content Ranges:
• EPA recommends that procuring agencies whose vehicles are serviced by a motor pool or vehicle
maintenance facility establish a program for engine coolant reclamation and reuse that consists of
either reclaiming the spent engine coolants onsite for use in the agencies' vehicles or establishing a
service contract for reclamation of the agencies' spent engine coolant for use in the agencies'
vehicles.
• EPA also recommends that procuring agencies request reclaimed engine coolant when having their
vehicles serviced at commercial service centers. Additionally, EPA recommends that agencies
purchase reclaimed engine coolant when making direct purchases of this item, such as when necessary
to make up for losses due to leakage or spillage.
• EPA does not recommend one type of engine coolant over another. EPA recommends, however,
that procuring agencies purchase engine coolant containing only one base chemical, typically ethylene
glycol or propylene glycol, to prevent the commingling of incompatible types of engine coolant.
Specific questions regarding shop use of engine coolants:
How frequently is the coolant changed in each vehicle?
What is the estimated average annual usage of coolant in this shop?
Does the shop use reclaimed engine coolant?
Does the shop have in place an agreement or contract with a vendor to reclaim the facility's used
coolant?
Does the shop have on-site, a reclamation device to reclaim used coolant?
If the shop does not use reclaimed coolant, are they aware of the RCRA/CPG requirement to do so?
If they are aware of the requirement to do so yet still do not use reclaimed coolant, what is their
explanation for not using this product?
Does their facility procurement process allow them to purchase reclaimed coolant? If not, what are
the barriers to such purchases?
Do they purchase coolant (reclaimed or virgin) for use in the shop using a government charge card
at a commercial vendor (e.g., K-Mart or Sears) outside of the facility?
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What is the fate of used coolant removed from the facility's vehicles?
Shop inspection protocol: Inspectors should ask to see the area where engine coolants are stored
for use by the facility. If the shop uses reclaimed coolant, these products can generally be recognized
by the label on container. Inspectors should record and include in their inspection report how storage
and disposal of engine coolants is handled at the facility.
INSPECTORS:
SEE ATTACHED INSPECTOR CHECK LIST
(Attachment 1)
Please provide attached questionnaire to facility contact.
(Attachment 2)
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INSPECTOR CHECKLIST FOR
INSPECTIONS OF FEDERAL FACILITIES FOR
COMPLIANCE WITH SECTION 6002 OF THE
RESOURCE CONSERVATION AND RECOVERY ACT
Note to inspectors: If the facility has no motor vehicle maintenance shop, please provide the
Inspection Questionnaire to the facility and note on the top of this form that the facility does not
maintain vehicles onsite. If the facility has more than one motor vehicle maintenance shop, please
indicate whether the response to questions listed below reflect practices at the entire facility or
only the shop(s) inspected.
Re-refined oils and lubricants:
Background questions:
Approximately how many vehicles are serviced for replacement or addition of oils and lubricants
by the shop or facility annually?
What type of vehicles are serviced? (e.g., sedans, trucks, heavy equipment, aircraft)
Specific questions regarding use of oil and lubricants:
What is the estimated annual consumption of oil and lubricants in the shop?
Motor oil: gallons
other lubricants: gallons
Approximately how frequently is the engine oil replaced in facility vehicles?
Every miles or months
Does the facility or shop test the oil to determine if replacement is needed?
yes no
Does the shop or facility use re-refined oil for replacement engine lubricating (motor) oils?
yes no
Does the shop or facility use re-refined oil for replacement hydraulic fluids?
yes no
Does the shop or facility use re-refined oil for replacement gear oils?
yes no
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Do shop containers containing unused oils and other lubricants indicate these products are re-
refined?
Oil - yes no
Hydraulic fluids - yes no
Gear oils - yes no
Is the shop or facility aware of the RCRA/CPG requirement to use re-refined oils or lubricants?
yes no
If the facility is aware of the requirement to use re-refined oils and lubricants and still does not use
these products, what is their explanation for not using these products?
Re-refined is too expensive
Specifications don't allow use of re-refined
Re-refined is not available
Other
Where does the shop or facility purchase oil and other lubricants?
Commercial bulk vendor (e.g., Safely Kleen) yes no
Govt. vendor (e.g., DLA, GSA) yes no
Local commercial vendor (e.g., auto supply)yes no
Other
Do shop or facility personnel purchase oil or other lubricants for use in the shop using a
government charge card or account at a commercial vendor (e.g., K-Mart or Sears) outside of the
facility? Always Occasionally Never
What is the fate of used oil removed from the facility's vehicles?
Disposed of as hazardous waste
Picked up by vendor for "recycling"
Reused at facility for heating fuel
Other
If the oil is collected or sent out to a recycler, is it ultimately used for energy recovery or is it re-
refined? Energy recovery Re-refined Don't know
RETREAD TIRES
Background questions:
Approximately how many tires does the shop or facility replace annually?
What type(s) of replacement tires does the shop or facility use?
Bus yes no
Heavy truck yes no
Pickup truck yes no
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Passenger vehicle yes no
Other
Specific questions regarding the use of retread tires:
Does the shop or facility install retread tires on facility vehicles onsite? yes no
If yes, for which types of tires?
Bus
Heavy truck
Pickup truck
Passenger vehicle
Other
Does the shop or facility have in place an agreement or contract with a "retreader" to retread the
facility's tires? yes no
Does the shop or facility use an outside service or vendor for tire replacement?
yes no
If yes, does that vendor offer retread tires? yes no don't know
If yes, does the facility purchase these tires? yes no
Is the shop or facility aware of the RCRA/CPG requirement to use retread tires?
yes no
If the shop or facility is aware of the requirement to do so yet still do not use retread tires, what is
the explanation for not using these products?
Retread tires are "unsafe"
Specifications don't allow use of retread tires
Retread tires are not available to the facility
Other
Does the shop or facility purchase retread tires for use in the shop using a government charge
card or account at a commercial vendor (e.g., Bandag, Goodyear, or other retreader) outside of
the facility? Always Occasionally Never
How are used tires disposed of by the facility?
ENGINE COOLANTS:
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Background questions:
Approximately how many vehicles are serviced for replacement or addition of coolants by the
shop or facility annually?
What type of vehicles are serviced? (e.g., sedans, trucks, heavy equipment)
Specific questions regarding shop of facility use of engine coolants:
Where does the shop or facility purchase coolant (reclaimed or virgin)?
Commercial bulk vendor (e.g., Safety Kleen) yes no
Govt vendor (DLA, GSA) yes no
Local commercial vendor (e.g. auto supply) yes no
Other
Approximately how frequently is the coolant changed in each vehicle?
Every miles or months?
What is the estimated average annual usage of coolant in this shop or facility?
gallons
Does the shop or facility use reclaimed engine coolant?
yes no
Does the shop or facility have in place an agreement or contract with a vendor to reclaim the
facility's used coolant? yes no
Does the shop or facility have on-site, a reclamation device to reclaim used coolant?
yes no
Is the shop aware of the RCRA/CPG requirement to use reclaimed coolant? yes no
If the facility is aware of the requirement to do so yet still do not use reclaimed coolant,
what is the explanation for not using this product?
Reclaimed coolant is not effective
Specifications don't allow use of reclaimed coolant
Reclaimed coolant is not available to the facility
Coolant reclamation devices are too costly
Other
Does the facility purchase coolant (reclaimed or virgin) for use in the shop using a government
charge card at a commercial vendor (e.g., K-Mart or Sears) outside of the facility?
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How does the facility dispose of coolant that is removed from facility vehicles (and is not
reclaimed)?
*************************************
Please add any additional observations regarding this inspection.
Inspectors are requested to forward a copy of this check sheet to the EPA Headquarters EO
13101 Program Manager within two weeks of the Federal facility inspection.
The checklist should be mailed to:
US Environmental Protection Agency
EO13101 Program Manager (mail code 2261 A)
401 M Street SW
Washington, DC 20460
May 12,1999
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FACILITY QUESTIONNAIRE
This questionnaire is designed to determine the level of your facility's awareness of and
compliance with the recycled content procurement requirements of Executive Order 13101, Section
6002 of the Resource Conservation and Recovery Act (RCRA), and the corresponding
recommendations and guidance provided by EPA. Please respond to each of the questions and return
the questionnaire within two weeks to the address printed at the end of this form.
THIS QUESTIONNAIRE SHOULD BE COMPLETED BY THOSE INDIVIDUALS MOST
FAMILIAR WITH THE FACILITY'S ENVIRONMENTAL AND PROCUREMENT
PROGRAMS.
List below the name, address and point of contact for your facility and the phone number, email
address and position of facility personnel completing this questionnaire.
PLEASE PROVIDE A RESPONSE TO THE QUESTIONS LISTED BELOW. USE SPACE
AT THE END OF THE QUESTIONNAIRE TO PROVIDE CLARIFICATION ON ANY
RESPONSE; PLEASE REMEMBER TO INCLUDE THE QUESTION NUMBER WHEN
PROVIDING ADDITIONAL INFORMATION OR CLARIFICATION.
#la) Prior to the receipt of this questionnaire, was your facility's environmental manager aware of
the requirements in RCRA 6002 for the procurement of EPA designated recycled content products?
yes no
#lb) Was your facility's procurement manager aware of the requirements in RCRA 6002 for the
procurement of EPA designated recycled content products? yes no
#2) Do you know whether your agency (i.e. Department of Defense, Department of Agriculture) has
an Affirmative Procurement Program (APP) established to meet the requirements of EO 12873, EO
13101 and/or RCRA 6002? yes no
If yes to #2, do you have a written or electronic copy of the APP for your agency? yes
no
#3) Does your facility have a policy or program which places a preference on procurement of items
containing recycled content or manufactured from recovered materials? yes no
If yes to #3, is the program formal (e.g., written policy signed by facility manager, director
May 12,1999
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or commander)? yes no
If yes to #3, does your facility announce and publicize the program to potential and active
vendors providing services or materials to the facility? yes no
If yes, how does your facility accomplish this?
If yes to #3, how does your facility promote the program to facility and shop level personnel?
If yes to #3, does your facility monitor and review the effectiveness of the program including
the tracking of purchases? yes no
If yes to #3, which entity or office in your facility (e.g., supply - procurement -shop manager)
is responsible for implementing the program? (list as many as appropriate)
#4) Does your facility's acquisition and/or procurement planning process investigate and/or
emphasize the use of recycled content products? yes no
If yes to #4, when you return this questionnaire, please provide a copy of a contract or
procurement document or procurement policy that reflects the process described.
#5) Are personnel at your facility who are authorized to use government credit cards for procurement
of items for use at your facility informed of the requirement to purchase designated recycled content
products? yes no
#6) Are records of credit card purchases of designated recycled content items maintained at your
facility? yes no
#7) Please list a sample of any items you know of that are purchased by your facility which contain
recycled content or are manufactured from recovered materials and are not on EPA's list of
designated recycled content items (that list is attached in matrix form to this document).
#8) Would you like to receive additional information regarding the Comprehensive Procurement
Guidelines? yes no
#9) Please list any items, issues or questions that are not part of this questionnaire that you feel should
be included ?
May 12,1999
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Attached to this document is a matrix listing each of the EPA designated recycled content
items. Please complete the matrix by placing an x in the appropriate box beside each item on
the matrix.
EPA will be periodically updating this document and the guidance for inspectors. If you have
additional suggestions or comments regarding this document, please add them to this page prior to
returning it to EPA.
Please complete the attached matrix and return it along with this
questionnaire and any other supporting documentation to:
US Environmental Protection Agency
EO13101 Program Manager (mail code 2261 A)
401 M Street SW
Washington, DC 20460
Facility personnel are encouraged to contact the RCRA hotline at 800-424-9346 or search the
Internet at http://www.epa.gov/cpg/products/htm or http://www.ofee.gov/for further information
about the Federal Government Buy-Recycled Program.
May 12,1999
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