Frequently Asked Questions (and answers)
on EO 13101 requirements and reporting

New questions generally appear first.

Submit your questions on DOE requirements and reporting per Executive Order 13101: "Federal Acquisition, Recycling, and Waste Prevention" to: Donald.Lentzen@eh.doe.gov.

Search for your question by using the Web browser tools Edit, then Find.  Type in a keyword for your question.  For example, if you type the word Threshold at the Find prompt, the browser will jump to the first sentence containing the word Threshold.

Q:  Is it true that the tread on retread tires doesn't last as long as on new tires?

A: Retread tires were introduced to the program for testing early in the 1990's. The test was a 20,000 mile highly controlled road course with gravel road segments incorporated into the route. The tires (new and retread) ran 100% of their load carrying capacity. The treadwear mileage was extrapolated out to the tires wear bars' and to wearout using an extremely accurate mathematical formula. Retread light truck tires and medium truck/bus retreads consistently showed much better treadwear than the new tires, which were running along side of them during the testing. This is the reason commercial fleets take good care of their casings and run retreads, not only from a base cost advantage, but for treadwear as well.

Q:  Other than the list of recommended vendors, where can I find information about park benches and picnic tables made from recovered plastic?

A: Between FY 1999 and FY 2001, Princeton Plasma Physics Laboratory purchased over $7000 worth of picnic tables and park benches containing 100% recovered plastic from BARCO Products Company. PPPL is very satisfied with the products. For more information, visit the Barco Web site at http://www.buybarco.com/

Q:  Where can I find reclaimed engine coolant (antifreeze) available for sale?

A:  EPA's Web site does have an availability list for recycled coolant that does look like it offers only suppliers of the recovery equipment. However, one company (Recycling Fluid Technologies) also offers the recycled coolant itself. You just have to scroll down far enough and read the company descriptions carefully, but it does say that Recycling Fluid Technologies offers recycled content engine coolant. Mal Hickock is the contact name for that company; his phone number is 616-629-9680.

The Defense Logistics Agency (DLA) offers recycled content engine coolant. Recycling Fluid Technologies might be the one supplying DLA. It's probably available through their Defense Supply Center Richmond. See Environmental Products and Services at http://www.dscr.dla.mil.

Q:  Where can I find a supplier(s) for CPG products with the required recycled content.

A:  Go to the CPG web site, click on Products, then click on the product category of interest. Go down the list of items until you find the one you're looking for. The list of suppliers is either shown directly or is contained in the background document.

Q:  Are there Federal standards and a Qualified Products List (QPL) for retread tires?

A:  September 7, 2000:  GSA used to operate the Federal Tire Program, which issued specs and maintained a QPL for all tires except military tactical tires -- and which was liked by the new tire and retread tire industries. To put it nicely and succinctly, GSA no longer operates this program, over the objections of the tire industry and the Army. So, the Army, which is the lead for tires, took back responsibility for tire specs and the QPLs. The Tank Automotive and Armaments Command has specs for tires, including retreads, based on the old GSA specs. Mark Swift, who formerly worked for TACOM, runs the QPL program as a TACOM contractor. The web site that the Power Marketing Admin's Safety Office identified belongs to Mark. CTQP means Cooperative Tire Qualification Program. In short, yes there are Federal standards and a Federal QPL. For more info, contact TACOM's Team Tire at 810-574-6303.

Q: We purchase specialized "plastic bags" for radioactive waste packaging. We are not recording these as designated item purchases. We only record purchases of the plastic trash bags purchased for custodial services. Is this right?

A:  August 17, 2000:   The CPG designation is for plastic trash bags so the item being purchased is not a CPG item.

Q: We recently purchased $630 of cardboard shipping rings and I'd like to know whether or not to record this as a designated item purchase. They're also known as zena rings and they are not available recycled. They are a specialized product used for packaging pipe overpack containers for TRU waste. Does this fall into any of the paperboard and packaging products categories such as "industrial paperboard" or "corrugated containers"?

A:  August 17, 2000:   The CPG designation for paper, is the entire category of paper and paperboard. Agencies must purchase commonly used paper and paperboard products, like corrugated or paperboard boxes, with recycled content. It sounds like the corrugated ring is a specialty product, however, and probably is only made by a limited number of paperboard mills or converters. So, I wouldn't count it now, but they should ask the source to try to get them a product with recycled content for the future. If it can be done and still meet the performance requirements, great, and if not, they tried.

Q: Where can I get planner refills with recycled content?

A:  August 8, 2000:   Starting September 18, 2000, you can use your P-Card to order the following items with 30% post-consumer content by calling the Franklin Planner Government Products Group at 800-872-0232, ext. 100:

Any new planner (Classic, Monarch, etc.) - this is the entire planner, NOT the refills - order by name of the style planner you want.

Refill for the Classic planner - order no. 21904    Starting January 2001, Franklin Planner will have the refills for the Monarch planner available with recycled content. The recycled planners and refills will NOT be available at any of the retail stores in the near future. We can only obtain the recycled versions by calling the number above. The prices will be the same as at the retail store, and the shipping time will be no more than 7 business days. Since most planners and refills are ordered will ahead of their need, the shipping time should not be a hindrance to purchasing the planners with recycled content.

Q: What is kenaf paper, how much does it cost, and where can I get it?

A:  May 9, 2000:   Kenaf paper is a new farm crop being developed as an environmentally sound alternative to trees for commercial paper making.   Environmentallly Preferable Paper containing kenaf non-wood fiber and 30% post consumer recycled is available from Vision Paper in Albuquerque, New Mexico.

EP101 is a low cost everyday use copy paper.  It is a white 20# bond, and is packaged 10 reams per carton.  This new product is being offered at $49.99 for a single carton, delivered.  Discounts for larger volumes apply.

"Vision" is a 100% recycled line of high quality printing papers made from 30% kenaf and 30% PCW recycled, and 40% recovered materials, and processed chlorine-free.   It is competitively priced and available in parent sheet sizes, in bassis weights of 60/70 and 80# text plus 80# cover.

Samples are available on request.  The address for Vision paper is:

Vision Paper
P.O. Box 20399
Albuquerque, NM  87154
505-294-0293  (phone)
505-294-7040  (fax)
www.visionpaper.com

Q: Where is 30% postconsumer content copier paper available and at what price?

A:  May 9, 2000:  Information on suppliers have been submitted by two DOE sites, Princeton Plasma Physics Lab, and Pacific Northwest Lab.  Please note that PNL is purchasing letter sized paper from the same supplier at a lower cost.

PPPL - contact Thomas McGeachen phone: 609-243-2948; fax:   609-243-3366

Product:  Letter size: 8.5" x 11"; ASPEN Xerographic, white, 20 lb.
Supplier:  Boise Cascade Paper Division of Boise Cascade
Cost:  $2.80 per ream delivered

Product:  Legal size: 8.5" x 14"; GeoCycle High Performance Recycled Office Paper, 84 brightness, 20 lb.
Supplier:  Georgia-Pacific Papers of Georgia-Pacific Corporation

PNL- contact Sandra Cannon  phone: 509-372-6210; fax:   509-375-5963

Product:  Letter size: 8.5" x 11"; 84 brightness, 20 lb.
Supplier:  Boise Cascade Paper Division of Boise Cascade
Cost:  $2.36 per ream delivered

Product:  Legal size: 8.5" x 17";  84 brightness, 20 lb.
Supplier:  Service Paper Company, Spokane, Washington; phone:   800-829-0081

Q: Are we required to purchase recycled calendars?

A:  March 13, 2000: Yes, calendars fall under the Paper Products RMAN. They might be printed on offset printing paper, tablet paper or even on a good quality bond. It just depends on what paper the printing company is using. The content standard is 30 percent postconsumer for all of these papers, so the exact type really is irrelevant.

Q: What are Papeteries? Where can I find the best practical descriptions of the designated items?

A:  March 13, 2000: The following response on papeteries has been taken from the "Final Paper Products Recovered Materials Advisory Notice - Response to Public Comments

According to the Dictionary of Paper and the Pulp & Paper Dictionary, papeterie paper is a class of papers used for greeting cards. Papeteries are made from cotton fiber or chemical wood pulps or mixtures of both. They also are used for correspondence and can be given special treatments, such as embossing and watermarking. They have low strength, high bulk, and good folding qualities. Papeteries differ from text and cover papers by (1) the need for sizing requirements for both writing inks and offset printing inks and (2) the absence of a corresponding cover grade.

EPA is adding papeteries as a separate printing and writing paper grade in Table A-1a of the final Paper RMAN. Consistent with the change to Executive Order 12873, EPA is recommending a 20% postconsumer fiber content level for papeteries.

For more information, please refer to the "Final Paper Products Recovered Materials Advisory Notice -- Response to Public Comments" which can be found at the following link http://www.epa.gov/cpg/paprman.htm#paper2. On this page, choose the Response to Comments bullet, and look under Comment d. on the displayed page.

Q: What is the definition of a "motor vehicle"? You have heard this question before from me and sent me a memo that suggests that motor vehicles are passenger vehicles found in motor pools. However, 40 CFR 247.3 defines tires and includes high and slow speed industrial and agricultural tires (in reference to retreads). This suggests vehicles like fire trucks and farm tractors could also be considered. Can you clarify this further?

A:  September 13, 1999: Yes, you have found the correct definition of what is considered to be a Motor Vehicle. The requirement to purchase retread tires or tire retreading services applies to land vehicles (i.e., land-based motor vehicles). This includes off-road vehicles and fire trucks, to the extent that retreads are available for these vehicles. There are local governments that use retreads on fire trucks and ambulances.

Q: Does GSA, DLA, and GPO report quantities of AP material distributed that DO NOT contain the appropriate amount of recovered material - or do we need to in the annual EORS report?

A:  September 13, 1999: We should not report anything that we bought from federal supply sources, since they report to OFEE and OMB on our behalf. This is to prevent double counting. I don't really know what they report, since they don't share that data with us.

Q: According to 40 CFR Part 247.2 9(a)(2), is it correct to think that any company that receives federal money - even from a non-government operations/management company like mine - is held to AP requirements, or does AP apply only to DOE and DOE's prime contractors?

A:  September 13, 1999: AP only applies to federal agencies, like DOE, and we are required to put those same requirements into our prime contracts. Now we also strongly encourage our prime contractors to pass (or "flow down") these same requirements along to their subcontractors but DOE cannot require it.

Q: In accordance with 40 CFR Part 247.4 (Contracting officer requirements), vendors are required to provide certification of recovered materials in the products they sell us. This makes sense. But a second requirement of vendors is an estimate of the percentage of total material utilized for the performance of the contract which is recovered materials. Why does the vendor need to provide this? Does this pertain to large and lengthy contracts, such as for construction jobs where AP material will be brought on site and used at various times? For small commodity contracts we can calculate the amount of total recovered material from the certification percentage and the amount of product we buy.

A:  September 13, 1999: First of all, these requirements were set in RCRA section 6002(e) and were incorporated into the CFR. Further, the Federal Acquisition Streamlining Act (FASA) (PL103-355) amended this section of RCRA to require estimates only for contracts in amounts "greater than $100,000." The FAR was amended on August 22, 1997 to address this change and provides clauses to be used for estimations and certifications for CPG items. The Civilian Acquisition Council (CAAC) met last year to discuss further changes to the FAR which would direct agencies to use standard contract clauses to collect such information. This would alleviate any duplicative efforts.

On the surface, this provision seems somewhat meaningless. But there may be merit in having the contractor give some thought about providing the recycled content materials called for in the contract. A contractor may be aware of a variety of products containing recovered materials but uncertain as to which will actually be used or which can be obtained at some future date in fulfilling the requirements of the contract. The provision requires the contractor to give serious thought and planning to obtaining the requisite products, then certify after products are delivered as to what was actually used to fulfill the contract.

The original idea behind the estimation provision is that the estimates would provide federal agencies with information on changes in the recycled content of the products they were purchasing. So, if the agency had a minimum content of standard of say 20 percent postconsumer material for a product, and the estimates showed that the product was now available with 30 percent postconsumer content, the agency would know to increase its minimum content standard to 30 percent. In reality, there are other, more efficient means of doing market research, including the research and updating of recommendations that EPA does. However, estimation is a statutory requirement, so we have to ask for it for contracts above $100,000.

Q:  How do requirements "flow-down" from Contractors to their Sub-contractors?

A: September 3, 1999: The government can only control what we put into contracts with our prime (in this case, M&O) contractors. And so we require APP of our primes. We cannot control nor dictate what the primes require of their subcontractors. However, we strongly encourage our contractors to "flow down" these requirements to their contractors, the subs. The primes decided what to require of their contractors. Some do flow down our APP requirements, some don't.

Q:  Have any labs had problems with their supply of 30% p-c uncoated paper? Have any other labs used either of the four alternative products listed below during the last 6 months?

• James River (or Fort James) product, Eureka! 30
• Weyerhauser product, Husky XeroCopy recycled
• Boise Cascade product, Aspen
• Hammermill product, Savings DP
  

Are there other proven (other Labs have used them for the last six months) alternatives besides the four listed above?

A:  Headquarters has used in the past the James River (or Fort James) product, Eureka! 30 with out any problem. They are currently using Geroriga Pacific's Geo Cycle and have had no problems to date.
PNNL reports that they are purchasing James River (or Fort James) product, Eureka! 30 and have heard of no problems. They are able to get their paper at a cost of $2.22 a ream, due to being able to link directly to the supplier (Service Paper Company) by way of a contract. They also have an preferred agreement with Boise Cascade, but the lowest price avalable from them is $2.36 a ream.

Q:  What is the recycled content of industrial steel drums? How does this compare to the RMAN?

A:  April 22, 1999: Answer from Chuck Nettleship, Steel Recycling Institute: Cold Rolled (CR) Industrial steel drums have a minimum 25% and a maximum 32% recycled content. Hot rolled steel is 80% to 100% recycled content.
See also The Steel Recycling Institute Homepage

Q:  Who supplies the toner cartridges for Headquarters?

A:  May 5, 1999: HQ obtains its toner cartridges from GSA.

Q:  Some office products contain more than one EPA-Designated item.  Under what item should we list purchases of items such as notebooks, desktop calendars, and steno pads?

A:  According to the EPA, purchases of those items (notebooks, desktop calendars) should be listed under Uncoated Printing and Writing Paper since that is the main component of those items.

Q:  What waste should I include in the Solid Waste Prevention input data?

A:  Include both routine sanitary waste and non-routine (cleanup and stabilization) sanitary waste.   If you feel that a large cleanup project in FY98 will make the numbers look odd, please describe the waste breakout in the Comments section of the report.

Q:  Our site cannot use remanufactured toner cartridges because early experiences with remanufactured cartridges were not good, our supplier won't guarantee against any damage to our copiers and printers should a cartridge leak, and our copier warranty is void if we use remanufactured cartridges.  What can we do to comply with the spirit of the Executive Order?

A:  Some early remanufacturers of toner cartridges did not replace all of the "single-use" components of the cartridges.  This sometimes resulted in leaky cartridges.  However, current remanufacturers refurbish the cartridge as well as refill it with ink.  We have not heard of any leakage problems in the last few years.  Check the EPA Availability Lists (in the APP Guidance) for other suppliers of remanufactured cartridges.
      Also, although not nearly as beneficial as remanufactured toner cartridges, cartridges made of recycled materials are permitted as an alternative by EO 13101.  These recycled-content cartridges can be made from as little as 2 percent recovered materials.  While this is better than buying all new, virgin material cartridges, remanufactured cartridges do FAR more to reduce the overall use of resources.  Remanufactured cartridges also cost much less than new, whether "recycled" or virgin material.

Q:  As of December 31, 1998 all federal executive agencies and their contractors must use copier paper (and other selected paper products) with at least 30 percent postconsumer content. Where can I find a supplier of 30 percent postconsumer recycled content paper?

A: The following manufacturers have advised an EPA contractor that they have (or plan to have) the 30 percent recycled paper available as a stock item:
    Avenor;  Fort James Corporation;  Fraser Paper, Inc.;  Gilbert Paper Company;
    Domtar Papers;  Strathmore Paper Company;  Union Camp;  Weyerhaeuser.
Additionally, the following companies will provide 30% content paper if demand warrants:
    International Paper (Hammermill and Springhill) and Willamette Industries, Inc.

Q:  Why doesn't the Web-based Reporting System ask the same questions that the RCRA Report asks the following March?

A:  In previous years the actual reporting format was not released by OFEE and OMB until the following December.  We designed the questions based on previous year's questions. All of the Executive Agencies were in the same position.  For the FY 1998 report, a draft is expected in September 1998.  This will allow us to question sites more accurately, thus minimizing the need to ask follow up questions in January.

Q:  Are there any items that DOE need not report for FY98 because of failure last year to meet the Agency threshold of $10,000?

A:  Yes. DOE did not meet the threshold for any Parks/Recreational Products purchases. DOE sites also need not report in FY98 on patio blocks or yard trimmings compost. However, if any site purchased $10,000 or more of either item in FY98, then every site must report any purchases of those items.

Q:  When do we need to report on the 12 additional items designated in November 1997 by the EPA?

A:  Each site should be tracking the November 1997 EPA-designated 12 items for the FY99 reporting cycle.

Q:  My site purchases $2,000 worth of transportation products a year.  Since the Executive Order says the reporting threshold is $10,000, why does my site still have to report?

A:  This is the most frequently asked question we have received.  The $10,000 reporting thresholdmentioned in RCRA Section 6002 and the DOE Affirmative Procurement Program guidance is the Agency threshold, not the individual site threshold.

Q:  When I print out the FY97 data from the Web site, the sites on the right side are cut off.  How can I print out all of the site data?

A:  While this is not a problem for offices that have only one site (SRS, RF), we realize this presents difficulties for multi-site offices.  We are reformatting the Web site display to enable printouts of all site data.  If a site person needs a printout of their data, and cannot print it from the Web, please send an e-mail request to P2support@eh.doe.gov.