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 Executive Order, EPA reviewed and evaluated information obtained from product
manufacturers. Based on this information, EPA established a range of recovered materials
content levels within which each of the designated items is available. In establishing the
range, EPA's objective was to ensure the availability of the item, while challenging
manufacturers to increase their use of recovered materials.
EPA believes that a range of content levels is appropriate at this time for three
reasons. Fist, EPA maintains only limited information on recovered materials content levels
for the newly-designated items. Second, rather than being purchased centrally, many of the
newly-designated items will be purchased locally, meaning that the recovered materials
content of these designated items is likely to vary substantially, making it problematic to
recommend a single content level at this time. Third, the Executive Order directs EPA to
propose a Recovered Materials Advisory Notice that presents `the range of recovered
materials content levels within which the designated recycled items are currently available."
In recommending a range, EPA believes that it is providing sufficient information to enable
procuring agencies to establish appropriate procurement specifications for purchasing the
newly-designated items.
It is EPA's intention to provide procuring agencies with the best and most current
information available to assist them in fulfilling their statutory obligations under RCRA
section 6002. To do this, EPA will monitor the progress made by procuring agencies in
purchasing designated items with the highest recovered materials content practicable and
revise the recommended content ranges accordingly. Revisions to recovered materials
content ranges will be published in an RMAN. EPA anticipates that, over time, the
recommended ranges will narrow.
In the RMAN, EPA also increased the recommended recovered materials content
level for rock wool insulation and added recommended content levels for fiberglass
insulation. Roth items were designated in the existing building insulation guideline (40 CFR
Part 248).
In previous procurement guidelines,. EPA, recommended a single content level for
each designated item. When issuing changes to these recommendations, in those instances
where there is sufficient information on current manufacturing practices to determine that a
single recovered materials content level is appropriate (e.g., rock wool insulation), EPA will
recommend one. In other instances, EPA will recommend a range of recovered materials
content levels (e.g., for fiberglass insulation).
The Agency received a number of comments on the recommended recovered materials
content levels in the draft RMAN. These comments and then Agency's responses are
presented in a document entitled "RMAN For Items Designated in the Comprehensive
Procurement Guideline - Supporting Analyses." A copy of this document has been placed in
the RCRA public docket.
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