WASHINGTON - A new Environ-mental Protection Agency proposal recommends that plastic shipping pallets purchased by the federal government be made entirely of recycled plastic. But government purchasers may ignore the order because the EPA refers to no performance or product standards - and allows leeway in its enforcement.
The effect on the U.S. Postal Service also is unclear. The agency has 3 million orange-and-black, 40-by-48-inch, high-molecular-weight polyethylene cargo pallets in use nationwide and is one of the largest users of plastic pallets in the world.
Paul Seehaver, Postal Service manager of transport equipment in Washington, said extensive Postal Service testing started in 1993. It resulted in first-generation standards, which required twin-sheet thermoformed pallets to contain no more than 10 percent post-industrial regrind. Most pallets used now meet the first-generation specifications and can carry loads of 1,500 pounds, Seehaver said.
An improved engineering de-sign produced second-generation pallets containing no more than 30 percent post-industrial regrind and post-consumer PE. Specifi-cations being written cover the third generation, which Seehaver said probably would call for ``not less than 30 percent post-consumer waste and regrind.'' How that might be divided ``is still being written,'' he said.
The Postal Service orders twin-sheet pallets from Trienda Corp. of Portage, Wis., and Cadillac Products Inc. of Troy, Mich.
Thermoforming is one of three commonly used pallet manufacturing processes. Other pallets are built of plastic lumber or are structural foam molded.
Jack Young, government sales manager for Trienda, also noted the Postal Service is reviewing how much recycled content it will allow in the 19-pound pallets, which have survived 500 cycles of use in tests.
This performance, he said, far exceeds the capability of wood pallets, which weigh twice as much as a plastic version and typically survive four use cycles.
But EPA has no product or performance standards for pallets.
Terry Grist, a specialist in EPA's office of solid waste in Arlington, Va., said 15 of 19 firms surveyed claim to make 100 percent recycled-content plastic pallets. That survey, coupled with information from ``The Recycled Products Guide,'' was the basis for EPA's recommendation that government-bought pallets should contain 25-100 percent recycled content, Grist said.
Recycling Data Management Corp. of Ogdensburg, N.Y., publishes the guide. Jackie Bou-langer, in charge of the guide's research and development, said it lists percentages of post-consumer and post-industrial plastic as provided by manufacturers, but contains no comparative performance data.
EPA announced the proposed federal procurement revision Nov. 4 and it was outlined Nov. 7 in the Federal Register. A 90-day public comment period is under way, Grist said.
The recovered material pallet is one of 13 products proposed for addition to the government's must-buy list, which started with President Clinton's 1993 executive order expediting the process of increasing Washington's broader use of recycled-content products. The government's buy-recycled program is mandated by the Resource Conservation and Recovery Act. With the additions, 32 products in seven categories must be made from recovered materials.
Guidelines require that within one year following EPA designation of items, ``procuring agencies must revise their specifications to require the use of recovered materials to the maximum extent possible without jeopardizing the intended end-use of items.''
``Agencies must actively advertise their desire to buy recycled products,'' note the guidelines.
Government purchasers are allowed exemptions if recycled-content products do not meet specifications, cost too much, or if inadequate competition exists. This prompted one recycler and pallet maker to label the EPA move as a ``marketing fashion trend: It's too easy to get out of.''
Prabhat Krishnaswamy, senior research scientist at the materials-testing Battelle Institute in Columbus, Ohio, said he is developing performance guidelines for plastic lumber pallets in a Department of Energy-funded program that seeks alternatives to wood pallets.
Otherwise, he said he is not aware of any accepted or published standards for pallets of recycled plastic lumber.
``We have no grades or quality levels. We've only just started developing terminology,'' which has not yet met with ASTM approval, Krishnaswamy said.
``One would be concerned about imposing regulations in a product area where there are very few product standards,'' he said, adding product standards ``allow you to predict the performance based on the recycled content of the material used.''
And James Favaron, chief technology officer for Cookson plc's specialty molding group, a pallet maker in Latham, N.Y., said his company's testing of pallets shows 25-30 percent recycled content ``is where we start losing physical properties.''
``If you have to keep adding modifiers to get the strength up, you might as well use virgin,'' he said. ``There's a balance. You can do some things with design, but only so much. Your costs may go up to achieve a load-carrying factor.''
Marshall White, director of Sardo Pallet and Container Research Laboratory at the Virginia Institute of Technology in Blacksburg, said, ``Recycled content is almost a meaningless term in itself.
``Lacking product standards, it's pretty difficult to predict the performance of plastic pallets,'' he said.
``In paper, the standards of products and performance are much better-defined.''