EPA DOES NOT ISSUE PRODUCT STANDARDS

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Plastics News makes a number of inaccurate statements in its Nov. 11, Page 50 article, ``EPA endorses recycled-content pallets'' and does a disservice to innovative manufacturers of recycled products.

Under Section 6002 of the Resource Conservation and Recovery Act, as well as Executive Order 12873, the Environmental Protection Agency identifies appropriate recycled products to include in the Comprehensive Procurement Guideline.

The guide is published as a proposed and final rule in the Federal Register. Federal agencies must establish a preference for buying the products designated in the CPG. An accompanying, nonregulatory Recovered Materials Advisory Notice recommends recovered materials content levels, provides purchasing guidance, and references industry standards and specifications.

These documents are based on extensive research on performance, price, availability and the government's purchasing experience with the specific products designated. In November, the EPA proposed designating pallets made from recovered plastic, wood and corrugated paper board, among 13 other products.

Plastics News' statement that ``The EPA refers to no performance or product standards and allows great leeway in its enforcement'' is misleading. The EPA is not in the business of issuing product standards or specifications but rather shares existing relevant technical specifications and standards.

Because research uncovered no current specifications, the EPA requested additional information from the public on the performance of recovered-content plastic pallets in the proposed rule published Nov. 7. Plastics News also erroneously attributes enforcement responsibility to the EPA. The federal and individual agency environmental executives, not the EPA, are responsible for enforcing compliance with the procurement guideline.

Contrary to your implication, designating recycled-content pallets would not adversely affect the U.S. Postal Service or other federal agencies using pallets.

The Postal Service will not be forced to discontinue using or to discard its existing pallets. If recycled-content pallets cannot satisfy postal performance requirements, the office doesn't have to buy recycled pallets.

We hope that in future articles Plastics News will publish more accurate information about the procurement guideline so that your readership will better understand how the government's preference for recycled products could benefit them.

Judy Usherson

Sue Eisenfeld

Eastern Research Group Inc.

Arlington, Va.

Editor's note: Eastern Research Group is an EPA contractor.