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 use all three colors of bottle cullet, while fiberglass insulation manufacturers are more
restricted regarding the percentage of each color that can be used. In the absence of
empirical data to the contrary, EPA does not believe that there will be. a supply problem for
glass bottlers.
b. Impact on waste minimization programs. A second commenter stated that the
introduction of postconsumer glass cullet into his fiberglass insulation manufacturing process
would increase the quantity of hazardous waste generated at his facility, adversely affecting
his waste minimization program. This commenter stated that postconsumer cullet introduces
metals (including lead, selenium, and chromium) into the manufacturing process which
would, in turn, cause furnace dust and emissions to be hazardous.
EPA notes that it is not mandating the use of recovered materials in the manufacture
of fiberglass insulation. It is solely the decision of the manufacturer to market his product to
procuring agencies seeking fiberglass insulation containing recovered materials:
Additionally, the recommended content levels included in the RMAN do not specify
postconsumer recovered cullet. Provided the commenter has access to sufficient
preconsumer recovered glass cullet to meet the content standards established by a procuring
agency, it may be possible for the commenter to sell his product to the procuring agency and
not increase his generation of hazardous waste.
The Agency applauds all efforts to minimize hazardous waste generation. EPA's
research shows that fiberglass insulation manufacturing plants typically generate hazardous
waste whether or not they use recovered materials in their raw material mix. EPA
encourages the fiberglass insulation industry to work with the glass packaging industry to
seek ways to reduce the toxic constituents added to glass packaging to eliminate or reduce the
likelihood that additional hazardous waste will be generated due to cullet usage in making
fiberglass products.
B. Structural Fiberboard and Laminated Paperboard
1. Background
In the proposed CPG, EPA proposed designating structural fiberboard and laminated
paperboard (59 FR 18868) for both insulating and structural purposes, including building
board, insulating formboard, sheathing, shingle backer, sound-deadening board; roof
insulating board, acoustical and non-acoustical ceiling tile, insulating wallboard, acoustical
and non-acoustical lay-in panels, floor underlayments, and roof overlay (coverboard).
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Structural fiberboard was defined as having a density between 10 lbs/ft and 31 lbs/ft , as
defined by ASTM specification C 208. Laminated paperboard products were defined as
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having a density in the range of 42 lbs/ft .
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