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XII. CONSTRUCTION PRODUCTS
In the CPG, the Agency proposed that new 40 CFR 247.12 contain designations of
the following construction products: building insulation, structuralfiberboard and laminated
paperboard, plastic pipe and fittings, geotextiles, cement and concrete, carpet, and floor tiles
and patio blocks. The following subsections discuss each of these items, the Agency's
response to public comments, and the final designations of these items, where appropriate,
EPA previously designated building insulation products and cement and concrete containing
fly ash in 1989 and 1983 procurement guidelines, respectively, but proposed to consolidate
these designations in the CPG (see 59 FR 18868, April 20, 1994). These designations are
now included in 40 CFR 247.12(a) and (c), respectively.
A. Building Insulation Products
1. Background
Fiberglass insulation was designated in the 1989 procurement guideline for building
insulation products, The Agency did not recommend recovered materials content levels for
fiberglass because this item was not being made routinely with recovered material at that
time (see 54 FR 7348, February 17, 1989) and it was not clear what contents levels were
feasible. In the CPG, fiberglass is included in the building insulation products designation
(see 59 FR 18890, April 20, 1994). In the draft RMAN, EPA recommended a recovered
materials content range for fiberglass insulation of 20 to 25 percent. EPA requested.
comment on also recommending a post-consumer cullet content of five percent; Comments
on the recommendation are addressed in a separate document entitled, "RMAN for Items
Designated in the Comprehensive Procurement Guideline - Supporting Analyses."
2. Summary of Comments and Agency Response
EPA received two comments opposing the designation of fiberglass. As EPA stated
in the proposed CPG (see 59 FR 18868, April 20, 1994), fiberglass insulation was designated
in the 1989 procurement guideline for building insulation products and the Agency was not
seeking comment on the appropriateness of the prior designation. Rather, EPA requested
comment only on the recommended recovered materials content levels for fiberglass
insulation contained in the draft RMAN.
a. Competing uses of glass cullet. One commenter stated that encouraging the use of
cullet to make fiberglass will interfere with glass bottlers' efforts to use glass cullet to make
bottles.
EPA does not agree that the use of recovered cullet by fiberglass insulation
manufacturers will interfere with glass bottle manufacturers ability to obtain cullet. In fact,
the opposite may be true. It is easier for glass bottlers to obtain and use recovered cullet
than for fiberglass insulation manufacturers to do so. Glass bottlers, as a whole, are able to
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