Use of Recycled Content Copy Paper United States Department of the Interior OFFICE OF THE SECRETARY Washington, D.C. 1-0240 JUL 1 5 1997 Memorandum To: Heads of Offices and Bureaus From: Bonnie R. Cohen Assistant Secretary -Policy, Management and Budget Subject:Use of Recycled Content Copy Paper Executive Order (EO) 12873, "Federal Acquisition, Recycling, and Waste Prevention," and the Resource Conservation and Recovery Act (RCRA), establish a policy of reducing the use of all paper products and maximizing the acquisition and use of recycled content paper and paper products. The General Services Administration (GSA) recently reduced the price of recycled content copier paper below that of comparable copier paper produced from virgin fiber. This price reduction offers a tremendous opportunity for DOI to meet its obligations under EO 12873 and demonstrate environmental leadership by increasing its purchases of recycled content copier paper to 100%, while simultaneously saving money. To take advantage of this opportunity, we have requested that GSA substitute recycled content copier paper (NSNs: 7530-01-335- 2623 (8 1/2 x 11") and 7530-01-334-7817 (8 1/2 x 14") for all DOI orders for copier paper produced from virgin fiber as long as the price of the recycled content copier paper is less than or equal to that of virgin paper. A similar request has been made to the Government Printing Office (GPO) regarding purchases from there. (See attachments.) We have made these requests to GSA and GPO at this time for a number of reasons, including: ? Recycled content copier paper and copier paper produced from virgin fiber meet the same performance specifications. ? Paper manufacturers have demonstrated that their new mills, specifically designed to handle recycled pulp and using state of the art technology, have significantly increased the quality of recycled content copier paper over the last decade. ? Major copier manufacturers and computer printer manufacturers have demonstrated that recycled content copier paper works in their product as well as copier paper produced from virgin fiber. ? Several other federal agencies, such as the Department of Defense, Department of Energy, the Environmental Protection Agency, the National Aeronautics and Space Administration, GSA (for internal use) and the Executive Office of the President have instituted, or are about to institute, policies requiring the use of recycled content copier paper. ? Eight state governments already have-policies that require the use of recycled content copier paper. ? The Government Printing Office has eighteen months of problem- free experience working with recycled content copier paper. ? Increasing demand for recycled paper should help stabilize the market for waste paper, thus increasing the price that facility recycling programs receive when selling their recovered paper. Recent summaries of copy paper purchased by DOI from GSA and GPO indicate that our efforts need to be renewed and met with greater conviction to be in compliance with the requirements of the Executive Order and RCRA. While we routinely purchase most of our copy paper from GSA, during FY 1996, only 26% of our GSA purchases met the recycled content requirements while 68% of paper purchased from GPO met the requirements. This results in a very disappointing 31% overall rate of compliance for FY 96. Henceforth, unless an order for virgin content copy paper is accompanied by an exemption, neither GPO or GSA will fill that order. Any bureau/office seeking to purchase virgin content copy paper must explain why they can not meet the conditions of Section 504c(l) and are thus seeking exemption from the Executive Order 12873. The request for exemption must be signed by the bureau A/D for Administration (or equivalent) and be reviewed and concurred with by the Director, Office of Environmental Policy & Compliance prior to the order issuance by the purchasing official. If you anticipate major difficulty implementing this policy, please let me know right away. I ask each of you to make this policy known within your organizations and ensure that they follow this guidance. It shall be the Department's goal to achieve 100% compliance with the Executive Order and RCRA. Attachments: -EO 12873, Sec. 504 -Letter to GSA -Letter to GPO Relevant excerpt from EO 12873 dated October 20, 1993 Sec. 504. Minimum Content Standard for Printing and Writing Paper. Executive agency heads shall ensure that agencies shall meet or exceed the following minimum materials content standards when purchasing or causing the purchase of printing and writing paper: (a) For high speed copier paper, offset paper, forms bond, computer printout paper, carbonless paper, file folders, white wove envelopes and for other uncoated printing and writing paper, such as writing and office paper, book paper, cotton fiber paper, and cover stock, the minimum content standard shall be no less than 20 percent postconsumer materials beginning December 31, 1994. This minimum content standard shall be increased to 30 percent beginning on December 31, 1998.18 (b) As an alternative to meeting the standards in sections 504(a), for all printing and writing papers, the minimum content standard shall be no less than 50 percent recovered materials that are a waste material byproduct of a finished product other than a paper or textile product which would otherwise be disposed of in a landfill, as determined by the State in which the facility is located. (1) The decision not to procure recycled content printing and writing paper meeting the standards specified in this section shall be based solely on a determination by the contracting officer that a satisfactory level of competition does not exist, that the items are not available within a reasonable time period, or that the available items fail to meet reasonable performance standards established by the agency or are only available at an unreasonable price. (2) Each agency should implement waste prevention techniques, as specified in section 402(d) of this order, so that total annual expenditures for recycled content printing and writing paper do not exceed current annual budgets for paper products as measured by average annual expenditures, adjusted for inflation based on the Consumer Price Index or other suitable indices. In determining a target budget for printing and writing paper, agencies may take into account such factors as employee increases or decreases, new agency or statutory initiatives, and episodic or unique requirements (e.g., census). (3) Effective immediately, all agencies making solicitations for the purchase of printing and writing paper shall seek bids for paper with postconsumer material or recovered waste material as described in section 504(b). 18 Executive Order 12873 was amended on March 26, 1996; Federal Register Volume 61, Number 61 of March 28, 1996United States Department of the Interior OFFICE OF THE SECRETARY Washington, D C. 20240 JUL 1 5 1997 Mr. Michael DiMario Public Printer Government Printing Office Washington, D.C. 20401 Dear Mr. DiMario: The Department of the Interior (DOI) is pleased with the recent efforts on the part of the Government Printing Office (GPO) to provide its customers with high quality recycled content copier paper. Providing such paper makes it much more feasible for agencies like DOI to be in compliance with the provisions of Executive Order 12873 and Section 6002 of the Resource Conservation and Recovery Act (RCRA) which, among other things, require all Government entities to purchase recycled content paper products to the maximum extent possible. In FY 1996, however, the amount of recycled content copier paper purchased from GPO (as a percentage of total) has dropped significantly. This was due in part to one of our agencies' demand for virgin copier paper. While we will look into the justification for placing such orders, we request that in the future the GPO fill all of our DOI's orders for copier paper with recycled content copier paper. To assist our many offices and bureaus dispersed throughout the country, we request that the GPO substitute recycled content copier paper for all DOI orders for copier paper made with virgin fiber as long as the cost of recycled content paper is less than or equal to that of virgin content paper. In the event the recycled content products are out of stock, we request substituting the order with a comparable recycled content product, or back ordering if feasible for the customer, but it is important that the order NOT be filled with virgin stock paper unless an exemption from the DOI environmental executive accompanies the order. We appreciate the GPO's continued efforts in helping all of us attain the goals set out in the Executive Order. Collectively, as agencies working together in recycling efforts, affirmative procurement and other aggressive pollution prevention strategies, we can achieve positive improvements in our Nation's environment and the health of its citizens. [signed] Bonnie R. Cohen Assistant Secretary Policy, Management and Budget United States Department of the Interior OFFICE OF THE SECRETARY Washington, D.C. 20240 JUL 15 1997 The Honorable David J. Barram Acting Administrator General Services Administration Washington, DC 20405 Dear Mr. Barram: The Department of the Interior (DOI) is pleased with the recent General Services Administration (GSA) efforts in obtaining lowered prices for recycled content copier paper, placing that product at a lower cost to consuming agencies than comparable virgin copier paper. Such pricing makes it much more feasible for agencies like DOI to be in full compliance with the provisions of Executive Order 12873 and Section 6002 of the Resource Conservation and Recovery Act (RCRA) which, among other things, require all Government entities to purchase recycled content paper products to the maximum extent possible. To assist our many offices and bureaus dispersed throughout the country, we request that the GSA substitute recycled content copier paper for all DOI orders for copier paper made with virgin fiber as long as the cost of recycled content copier paper is less than or equal to that of virgin content copier paper. The preferred paper, then, will be NSN 7530-01-335-2623 (8questiondown x 11") and NSN 7530-01-334-7817 (8 questiondown x 14".) In the event these stock numbers are out of stock, we would ask that GSA substitute with a comparable recycled content product, or back order if feasible for the customer, but it is important that the order NOT be filled with virgin stock copier paper unless an exemption from the DOI environmental executive accompanies the order. We appreciate the GSA's continued efforts in helping all of us attain the goals set out in the Executive Order. Collectively, as agencies working together in recycling efforts, affirmative procurement and other aggressive pollution prevention strategies, we can achieve positive improvements in our Nation's environment and the health of its citizens. Regards, [signed] Bonnie R. Cohen Assistant Secretary Policy, Management and Budget