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 medium-wear applications" were not well defined. These commenters noted that most
government agencies require carpeting for high-traffic or commercial applications, and were
concerned that lack of a clear definition may encourage the use of polyester carpeting in
applications where it may not be appropriate.
It is not EPA's intent to recommend the use of a product where it is not suitable.
The Carpet and Rug Institute uses the following guideline selecting the quality of carpets
to be used in various areas: "light" for bedrooms, dressing rooms, and some dining rooms
in private homes; "moderate" for living and dining rooms in private homes, motel and hotel
bedrooms and private offices; "heavy" for commercial type installations in office buildings,
public rooms, motel and hotel lobbies, stairways and stores; and "severe" for corridors, and
other wheeled traffic areas. EPA recommends that procuring agencies follow these general
guidelines in determining applications that may be suitable for the use of polyester carpet
containing recovered materials. EPA recommends the use of polyester carpet containing .
recovered materials for "light" and "moderate" applications, consistent with the types of uses
in the above guidelines.
c. Impact of solid waste generation. Some commenters were concerned that, if
government agencies substituted polyester carpeting in applications for which nylon or other
carpeting was more suitable, the polyester carpeting may "wear out" sooner and have to be
replaced more frequently, This would have the unintended effect of increasing solid waste
generation.
It clearly is not EPA's intent to increase solid waste generation from the use of a
carpet that is not suitable for a given application. Today's designation of polyester carpet
applies only in those cases where a procuring agency has determined that the use of polyester
carpet is suitable, given the performance requirements and expected wear characteristics of a
given- application. EPA does not intend for a procuring agency to select a polyester carpet
for applications where a nylon, wool, or other carpet is better suited. However, EPA
recommends that procuring agencies evaluate whether polyester carpet is appropriate to meet,
their needs, and, if so, to specify polyester carpet containing recovered materials.
d. Carpet containing recovered nylon. Several nylon fiber manufacturers stated that
they are developing technologies to recover nylon from used carpeting through chemical
recycling (i.e., depolymerization). This postconsumer nylon could be used as a feedstock to
make a wide range of new products, including nylon carpet fiber. The commenters were
concerned that the CPG will discourage the industry's active chemical recycling efforts,
be-cause the procurement designation currently applies only to polyester carpet.
EPA does not believe that the CPG will in any way discourage the industry's nylon
recycling efforts, In fact, it has been EPA's experience with the existing procurement
guidelines that item designations encourage manufacturers of similar items to begin using
recovered materials too. EPA encourages the continued efforts of the nylon fiber
manufacturers to develop and commercialize nylon recovery' technologies and to manufacture
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