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subsections discuss the significant comments pertaining to the remaining proposed item
c. Several commenters requested that EPA designate additional items in the final
CPG. Suggested items included carpet underlay, lead acid batteries, rebuilt and
remanufactured automotive parts, roofing materials, and grocery bags.
Because the designation of items under RCRA section 6002 imposes legally
enforceable duties on procuring agencies, EPA's designation of items must occur through
formal notice-and-comment rulemaking procedures, EPA cannot designate items without
having provided the opportunity for public comment. EPA will consider the feasibility of
designating the suggested items in a future proposed revision to the CPG.
A. Re-refined Lubricating Gil and Retread Tires
In the proposed CPG, the Agency stated it would include the previous designations
for re-refined lubricating oil and retread tires in a new 40 CFR 247.11(a) and (b),
respectively, as part of consolidating the guidelines (see 59 FR 18867, April 20, 1994). The
new 40 CFR 247.11 includes the existing designations of these two items and a new
designation for engine coolants which is discussed in the following subsection.
B. Engine Coolants
1. Background
In the proposed CPG, the Agency proposed todesignate reclaimed engine coolants
(see 59 FR 18867, April 20, 1994), also known as antifreeze. Automotive engine coolants
are marketed in this country in two formulations: ethylene glycol-based or propylene glycol-
based coolants. Propylene glycol-based engine coolants have just recently been marketed
nationwide for consumer purchase. There are additional formulations used in other
2. Summary of Comments and Agency's Response
a. Applicability of designation to non-vehicular engines. Two commenters asked that
EPA clarify that the proposed designation applies only to engine coolants used in vehicles
and not to other glycol-based coolants used in other types of machinery such as generator
EPA believed that inclusion of engine coolants in the Vehicular Products Category
clarifies that the designation is limited to vehicular engine coolants and does not apply to

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