agency's current and potential vendors. suppliers, and contractors of the agency's intention to
buy recycled content products.
In the previous guidelines, EPA targeted its recommendations for promoting the
affirmative procurement program at the agency's vendors and contractors. EPA has
determined that the education of an agency's employees is also an important part of the
promotion program. Therefore, EPA believes that an agency's promotion program should
consist of two components: an internal promotion program and an external promotion
1. Internal Promotion
There are several methods that procuring agencies can use to educate their employees
about their affirmative procurement programs. `These methods include preparing and
distributing agency affirmative procurement policies, publishing articles in agency newsletters
and publications, including discussions of an agency's affirmative procurement program in
staff and technical manuals, and conducting workshops and training sessions to educate
employees about their responsibilities under an agency's affirmative procurement program.
2. External Promotion
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 affirmative procurement program at
D. Estimation, Certification, and Verification
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. RCRA
section 6002(c)(3) further provides "the contracting officer shall require that vendors (A)
certify that the percentage of recovered materiala to be used in the performance of the.
contract will be at least the amount required by applicable specifications or other contractual
requirements and (B) estimate the percentage of the total material utilized for the
performance of the contract which is recovered materials."
E. Procedures to Monitor and Review the Procurement Program
Procuring agencies should monitor their affirmative procurement programs 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 affirmative