Volume 13, Number 5
Sep 1989

Recycled Paper Mandate Now in Effect: A News Report with Commentary

In June the federal government became required to buy recycled paper, in conformity with the Environmental Protection Agency's enforcement of the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act of 1976, as amended, 42 U.S.C. 6912(a) and 6962. The EPA' a "Guideline for Federal Procurement of Paper and Paper Products Containing Recovered Materials" implementing Section 6002(e) of the RCRA is printed in the Federal Register for June 22, 1988. This Guideline has been a cause of concern among librarians and archivists because of its possible effect on permanence of publications and documents. It was the subject of some discussion in the May 4 hearings on "Permanence of Print" chaired by Rep. Walgren, and Senator Pell discussed the possible conflict between recycling and permanence in his remarks the day his resolution was passed (Congressional Record, July 31, 1989). While it is true that alkaline recycled paper is made every day in increasing amounts, notably by Glatfelter and Miami paper companies, recycled fiber is necessarily weaker than new fiber, and with the increasing demand for recycled fiber from this regulation, mills will probably be dipping into fiber supplies of lower quality, which are not as well sorted and may contain groundwood, plastic and other substances that shorten the life of paper.

With the implementation of this Guideline, the EPA got into the business of setting standards for paper production, a matter for which we normally rely on the Joint Committee on Printing. But if the Walgren amendment to the Solid Waste Disposal Act is passed, permanence is one quality that will not have to be compromised.

The deadline for compliance was June 22. On June 14, the GPO had already awarded its first quarterly bid for printing and writing paper specifying recovered material content. All agencies of the federal government that buy paper and paper products are required to implement a preference program favoring recycled items . This also applies to state and local government agencies funded by the federal government that buy $10,000 or more of the designated grades.

The Guideline applies to paper and board of all sorts except for building and construction grades. There are five broad categories:

Newsprint
High-grade bleached printing/writing paper
Unbleached packaging
Tissue products
Recycled paperboard

The second category, the one from which the libraries and archives of the future are made, is required to contain at least 50% waste paper, a higher proportion than any other category or subcategory except recycled paperboard products and pad backing. The "waste paper" may include paper from any point in the waste stream, from envelope trimmings all the way to material collected from municipal solid waste, including mixed waste paper, old newspapers and "fibrous wastes." It is apparently up to the paper manufacturer to pick the kind of waste he wants to use--or to take the kind he can find on the market. If high-quality waste is not available, he is required to use low-quality waste rather than new fiber. Under such conditions, a papermaker with a reputation for making permanent papers might find it hard to maintain that reputation. Of course, he could just decide not to make paper for the government market, but it is such a large market that he might suffer financially.

There are certain exceptions. Rag content paper is exempted because it was redefined as recycled paper. The cotton linters scraped off the cottonseed after the longer fibers are removed for making textiles are thought of by the EPA as being recycled when they are included in "rag" paper, and in any case they are essential to the high quality appearance and feel of executive letterhead and other papers in that market. Form bond (computer paper and carbonless paper, for instance) and paper for high-speed copiers are exempted because apparently somebody convinced the EPA that if any recycled fiber at all were included, the machines would jam. So recycled fiber is seen as interfering with the quality of prestige papers and papers for use in office machines, even if it is used in very small amounts. If the user sees recycled fiber as interfering with the quality of papers that may have to last a long time, he has to seek an exemption on a case by case basis, with documentation, and renew this exemption every year

The recycling industry is orders of magnitude larger than the small circle of people and institutions trying to preserve the record of the past and the future. Already half the states in the union have some sort of recycling or waste management bill in effect, and the rest will not be far behind. Exemptions for printing and writing paper should be gotten if at all possible, and the exemptions should not be dependent on how prestigious or mechanized the use of the paper will be, or even on whether the paper will be used for something of enduring value, because so few purchasing agents and administrators buy their paper for a single book, pamphlet or document. Even if they did, would they be the best people to say which of these materials were of enduring value? That is for the archivists, thirty years from now, and the librarians, fifty years from now, to say; even then, there will be archivists and librarians 100 years from now who will make different judgements. All printing and writing paper used by state and local governments should be permanent. If it is not known which papers are permanent then an alkaline paper should be used, and each purchasing office should familiarize itself with available standards and testing facilities, so that it will be better informed in the future.

Exempting printing and writing paper from the requirement to use recycled fiber need not effect the solid waste problem, which is what got all of this started, if tissue products, for instance, could use more than 20-40% waste materials, as they are now required to do. Facial tissue is only required to contain 5% postconsumer recovered materials; corrugated boxes, 35%. Printing and writing papers are a small part of the paper market, by comparison. Sara Freund of the American Paper Institute said in the October 1988 Alkaline Paper Advocate that only 2.5% of all paper produced went into books, and if writing paper were added into the total, it would probably not bring it above 5%. Instead of seeing this market as a place where recycled fiber should be used, it should see it as a great source of high quality fiber. There is certainly no reason to send paper of any sort to the dump, as long as it can be properly sorted before re-use, because there is a high international demand for waste paper. In 1985 the U.S. exported 3 million tons of waste paper; in 1987, 4 million tons; and in 1988, 5 million tons.

For more information, call the RCRA Hotline, 800/424-9346 or 202/382-3000. For technical information, contact William Sanjour, Office of Solid Waste, WH-563, U.S. EPA, 401 M Street, SW, Washington, DC 20460, 202/382-4502. For news of the Walgren amendment, call Chris Wegman, 202/225-8844. Write the Newsletter office for a Recycled Paper Alert put out last May, and containing a collection of news items and a copy of the Connecticut bill on permanent paper.