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2. Summary of Comments and Agency's Response
a. Chipboard binders. One commenter stated that he was not aware of any binders
made of chipboard only, but mentioned that many binders ate made exclusively of
The Agency is aware of two manufacturers that produce uncovered chipboard binders
made from recovered materials.. According to these manufacturers, their binders contain up
to 100 percent recovered materials. Therefore, EPA is designating both covered and
uncovered chipboard binders in the final CPG.
b. Pressboard binders. Another commenter stated that EPA's proposed item
designation for binders was incomplete because it did `not mention binders made from
This commenter is correct; EPA inadvertently omitted reference to pressboard in the
proposed CPG under the erroneous assumption that "pressboard" was included in the term
"chipboard." EPA has since determined that this is not the case. For this reason, today's
final item designation for binders references chipboard and pressboard, both of which are
paper and paperboard products. As explained in the Recovered Materials Advisory Notice
that accompanies the final CPG, procuring agencies should rely on the guidance provided in
Section II, Part A of the Recovered Materials Advisory Notice that accompanies this final
CPG and in the draft Paper products Recovered Materials Advisory Notice (60 FR 14182,
March 15, 1995) when purchasing chipboard or pressboard binders.
c. Cloth-covered binders. In the proposed CPG notice, EPA stated that it was not
aware of any manufacturera of cloth-covered binders that use recovered materials when
producing the cloth cover and requested comment on the validity of this information. During
the public comment period, the Agency did not receives any information that would indicate
that the cloth cover used for binders contains any recovered materials. Therefore, the
Agency is not recommending recovered materials content levels for the cloth component of
covered binders.
3. Rationale for Designation
EPA believes that binders satisfy the statutory criteria for selecting items for
a. Use of materials in solid waste. As discussed above in section II.A, plastics and
paper are significant components of the solid waste stream.
b. Technically proven uses. EPA is aware of at least three manufacturers that
produce plastic-covered binders with recovered plastic content in the covering, and two
manufacturers that produce chipboard binders with recovered paper content. In addition,

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