Quantcast Summary of Comments and Agency's Response - epafirm0059

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plastic pipe and fittings. EPA identified 10 manufacturers of plastic, pipe that use recovered
materials.
2. Summary of Comments and Agency's Response
a. Performance. While one commenter supported the proposed designation of plastic
pipe and fittings, EPA received numerous comments expressing concern about the possible
liability and adverse effects were there to be failures of plastic pipe containing recovered
materials. These commenters stated, that the ASTM and American Association of State
Highway and Transportation, Officials (AASHTO) are currently reviewing their material
specifications that preclude the use of recovered materials in plastic pipe and fittings for
possible revision to allow the use. of these materials. These commenters suggested that
ASTM and other reliable specifications are necessary to ensure the quality of plastic pipe
containing recovered materials, and that EPA should not designate plastic pipe containing
recovered materials until such specifications are in place.
As described in the proposed CPG, several manufacturers have conducted
performance testing on pipe made with recovered materials and demonstrated that the pipe
meets applicable ASTM performance specifications.' However, there currently exist ASTM
and other material specifications that preclude the use of recovered materials in plastic pipe
and fittings. As pointed out by commenters, there is a major effort underway to review
these specifications for possible revision to allow the use of recovered materials. This effort
is not yet completed. Based on the comments received, EPA has become aware that many
manufacturers and users of plastic pipe do not believe that adequate. testing, especially field
testing, has been conducted and that designation should be delayed until such testing is
conducted. For this reason, EPA has determined that it is premature to designate plastic pipe
and fittings, even for non-pressure applications.
b. Product testing. Many commenters in industry and government, particularly state
transportation officials, expressed a strong interest in working with EPA to overcome the
barriers to using plastic pipe made of recovered materials. At least one state transportation
officecurrently is conducting field testing of HDPE drain pipe made of recovered materials.
EPA will continue to follow developments in this area and will reconsider designating plastic
pipe when these barriers have been overcome. In the meantime, EPA encourages
manufacturers and users of plastic pipe made with recovered materials to keep the Agency
apprised of new developments in product performance testing and revision of material
specifications.
3. Designation
EPA is not issuing a final designation for plastic pipe and fittings, because of the
commenters' concerns described above. EPA is postponing issuance of the final designation
until the issues of performance testing and materials and performance specifications have
been addressed.
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