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 2. Summary of Comments and Agency's Response.
a. Structural fiberboard data. While no commenters opposed the designation of
structural fiberboard, two commenters stated that the information and data the Agency used
in developing the proposed CPG and draft RMAN were inaccurate. The commenters
maintained that EPA's information on recovered materials usage, particularly its
postconsumer recovered paper data, were not representative of current industry capabilities.
Based on these comments, the Agency conducted additional research to obtain more
current industry data. EPA determined that, although the data used to develop the proposed
CPG. and draft RMAN accurately reflected industry use of recovered materials for the year in
which they were gathered, 1991, they did not reflect current industry usage of recovered
materials, especially postconsumer recovered paper. On the basis of this additional research,
EPA has revised the recovered materials content recommendations for structural fiberboard
contained in the RMAN that accompanies this CPG.
b. Laminated paperboard. EPA did not receive any comments on its proposed
designation of laminated paperboard. Therefore, the Agency is designating laminated
paperboard as proposed.
c. Other board products. In its proposal, EPA also requested additional information
about the use of recovered materials to produce other board products, including
particleboard, hardboard, and medium density fiberboard. The Agency received two
comments on these- products and will use this information in evaluating these products for
potential designation in future updates to the CPG.
3. Rationale for Designation
EPA believes that structural fiberboard and laminated paperboard products satisfy the
statutory criteria for selecting items for designation.
a. Use of materials in solid waste. As discussed above in section II.A, both paper
and wood ate significant components of the solid waste stream.
b. Technically proven uses. Roth structural fiberboard and laminated paperboard can
be produced with high levels of recovered materials without compromising product
performance. All seven manufacturers of structural fiberboard and all of the laminated
paperboard manufacturers use recovered materials in the manufacture of their products.
In addition, both structural fiberboard and laminated paperboard containing recovered
materials are established products with established specifications. ASTM specification C 208
applies to structural fiberboard products containing recovered materials. Roth structural
fiberboard and laminated paperboard meet other applicable performance requirements, such
as those established by the American National Standards Institute (ANSI), American Society
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