Quantcast General Comments Applicable to Item Designations

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X. GENERAL COMMENTS APPLICABLE TO ITEM DESIGNATIONS
a. One commenter suggested that EPA designate items in a material neutral manner.
In other words, rather than designating items made of specific materials (e.g., "plastic" trash
bags), EPA should simply designate the items in generic terms (e.g., trash bags).
EPA believes that such an approach is not appropriate for all items. Under RCRA
section 6002(c)(1), each procuring agency which procures "any items" designated by EPA is
required to procure such items composed of the highest percentage of recovered materials
practicable. As a result, if EPA designates a generic category of items, procuring agencies
are obligated to try to purchase all items within that category containing recovered materials.
For example, when EPA designated "paper and paper products" or "building insulation'
products," procuring agencies were obligated to purchase all types of paper products or.
building insulation containing recovered materials, even though EPA did not provide content
recommendations for all products within these categories. In other instances, where EPA is
not aware that items manufactured from other types of materials are made with or could
contain recovered materials, EPA has limited its designations so as not to create an
unnecessary burden on agencies to try to purchase an item that is not available. When EPA
learns that the generic item is being made with additional recovered materials, EPA will
evaluate the new information and consider amending the item designation accordingly.
In implementing this process for the items listed in the proposed CPG, 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): "This designation does not preclude a procuring agency from
purchasing de&top 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..."
b. No commenters opposed the designations of the following items: structural
fiberboard, laminated paperboard, patio blocks, traffic barricades, traffic cones, playground
surfaces, running hacks, hydraulic mulch, plastic desktop accessories, and plastic trash bags.
Therefore, today, EPA is promulgating these item designations as proposed. The following
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