ISRI comments on the federal government’s Comprehensive Procurement Guidelines
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ISRI comments on the federal government’s Comprehensive Procurement Guidelines

ISRI’s comments to the EPA focus on the economic and environmental benefits of recycling driven by the program.

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July 9, 2020

In early April, the U.S. Environmental Protection Agency (EPA) said it was seeking comments on its current list of items that are or can be made from recovered materials and its recommendations to federal agencies on purchasing these items. The 90-day comment period closed earlier this month.

The federal government’s buy-recycled program uses federal purchasing power to stimulate demand for products made with recovered materials. EPA designates recycled-content items and publishes recommendations to assist procuring agencies using federal funds in meeting their obligations under this program. The last update to the product designations and procurement recommendations occurred in 2007, according to the agency.

EPA was asking for input regarding whether the right products are on the list; if any should be deleted, added or modified; and whether the current recycled-content and procurement specifications are appropriate.

The Institute of Scrap Recycling Industries (ISRI), Washington, submitted comments to the U.S. Environmental Protection Agency (EPA) July 6 in support of updating the EPA’s Comprehensive Procurement Guidelines (CPG). The comments were signed by Adina Renee Adler, ISRI vice president of advocacy.

In its comments, ISRI encourages enhancing the CPG to reflect current market availability of additional goods made from recycled content and the amount of recycled content that can be incorporated into these products. ISRI also suggests the increased purchases of these products by government procurement officials for purposes of stimulating recycling and doing more to divert end-of-life materials from landfills through the use of an enhanced CPG.

ISRI writes that it intends its comments to “suggest separate EPA rule-making that clearly defines recycling and related terms; support the enhancement of the CPG to reflect current market availability of additional goods made from recycled content and the amount of recycled content that can be incorporated into these products; and promote increased purchases of these products by government procurement officials for purposes of stimulating recycling and doing more to divert end of life materials from landfills through the use of an enhanced CPG.”

ISRI describes the CPG as “a vitally important resource for promoting sustainability and the resilience of the U.S. manufacturing supply chain, of which recycling is an essential first step. The guidance set out in the CPG for procurement officials in federal, state and local governments provide a critical market for recycled materials; the purchasing of products made with recycled content spurs more recycling activity in the United States.

The association writes that it is “imperative that EPA pursue a separate rule-making that improves the definitions for ‘recycling’, ‘recyclable’ and ‘recycled material.’ For purposes of these comments—and to consider for rule-making—ISRI defines these terms in the following way:

“Recycling is the series of activities during which obsolete, previously used, off-specification, surplus or incidentally produced materials are processed into specification-grade commodities and consumed as raw-material feedstock, in lieu of virgin materials, in the manufacture of new products. The series of activities that make up recycling may include collection, processing and/or brokering and shall result in subsequent consumption by a materials manufacturer. 

“A ‘recyclable’ material is an obsolete, previously used, off-specification, surplus or incidentally produced material for processing into a specification-grade commodity for which a market exists,” the comments continue.

ISRI defines recycled material as “material that was initially obsolete, previously used, off-specification, surplus or incidentally produced and that has been processed into a specification-grade commodity for use in materials manufacturing.”

The association concludes by writing, “We also look forward to engaging in a rule-making process with EPA in which the comments provided herein—which includes proposed additional products that are available in the marketplace and made from recycled content as well as changes to recycled content levels in existing products—could be incorporated to enhance the CPG. Doing so will stimulate additional recycling in the United States, which will lead to greater environmental and economic benefits for the United States.  It is vital to the overall success of the U.S. recycling industry that government procurement help to drive demand for recycled materials, which will, in turn, drive more opportunity for growth in recycling.”

ISRI recommends that a number of new building and construction products be added to the CPG:

  • drainage tile with 40 percent recycled plastic;
  • corrugated pipes with recycled plastic ranging from 50 to 100 percent; 
  • road surfacing with 20 percent recycled rubber;
  • pipe bedding with 20 to 100 percent recycled glass;
  • underdrain filtration with 20 to 100 percent recycled glass;
  • nonstructural fill with 20 to 100 percent recycled glass;
  • engineered fill with 20 to 100 percent recycled glass;
  • sandblasting material made from 100 percent recycled glass; 
  • gypsum board made completely from recycled paper;
  • railroad ties made completely from recycled plastic;
  • wall panels made from 25 to 95 percent recycled aluminum;
  • solar panel mounting frames and structures made with 25 to 95 percent recycled aluminum;
  • gutters and downspouts made with 25 to 95 percent recycled aluminum;
  • modular threshold ramps and associated railings made with 25 to 95 percent recycled aluminum; and
  • roofing materials made with 25 to 95 percent recycled aluminum.

Among the other new products ISRI suggests adding to the CPG are totes and crates made with 50 percent recycled high-density polyethylene; grocery bags made with 20 percent recycled low-density polyethylene; and beverage containers made with 25 to 100 percent recycled plastic, 50 to 100 percent recycled metal and 20 percent recycled glass.