Quantcast Summary of Comments and Agency's Response - epafirm0047

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procurement program to include procedures for anually reviewing and monitoring the
effectiveness of an agency's affirmative procurement program. Section 402 of Executive
Order 12873 requires the Environmental Executive of each Executive agency to track and
report on agency purchases of EPA-designated items. Additionally, RCRA section 6002(g)
requires the Office of Federal Procurement Policy (OFPP) to submit a report to Congress
every two years on actions taken by Federal agencies to implement the affirmative
procurement requirements of the statute. Also, section 301 of Executive Order 12873
requires the Federal Environmental Executive to submit a report annually, at the time of
agency budget submission, to the Office of Management and Budget (OMB) on Executive
agency compliance with the Order. In order to fulfill their responsibilities, EPA anticipates
that the Federal Environmental Executive and OFPP will request information from
appropriate Federal agencies on their affirmative procurement practices. Therefore, it is
important for agencies to monitor their affirmative procurement programs to ensure
compliance with RCRA section 6002 and Executive Order 12873.
In order to comply with the Executive Order, agencies will need to evaluate their
purchases of products containing recovered materials. This will also allow them to establish
benchmarks from which progress can be assessed. To evaluate their procurements of
products containing recovered materials, procuring agencies may choose to collect data on
the following:
The approximate 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; and
( 5 ) P e r f o r m a n c e 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. However, EPA believes that estimates will be sufficient to
determine the overall effectiveness of an agency's affirmative procurement program.
F. Summary of Comments and Agency's Response
a. Administrative requirements. Several commenters expressed concern with the
administrative requirements associated with individual item designations. In particular, many
commenters objected to the requirement that procuring agencies develop affirmative
procurement programs for all designated items, including items that they may not purchase
or that they are unable to obtain with recovered materials content. In addition, a few
commenters questioned the benefit of developing an affirmative procurement program,


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