The Alkaline Paper Advocate

Volume 1, Number 4
Oct 1988

EPA Mandates Use of Recycled Paper

In an effort to enforce Section 6002 of the Resource Conservation and Recovery Act of 1976 and "reduce the municipal solid waste stream," the Environmental Protection Agency published a final rule in the June 22 Federal Register that mandates the use of recycled paper, not only by all federal agencies, but by "any State agency or agency of a Political subdivision of a State which is using appropriated Federal funds for such procurement, or any person contracting with any such agency with respect to work performed under such contract."

Anyone spending $10,000 of federal money for paper in any one of the following categories has to make sure that a certain percentage of it is made of recovered materials (and broke does not qualify):

Printing and writing papers must generally include 50% of what EPA calls "waste paper," a special category of recovered materials, which includes 1) postconsumer material (trash from homes and businesses and municipal solid waste), 2) dry paper and paperboard waste (envelope cuttings, bindery trimmings and so on--paper and board that was never used) and 3) obsolete inventories from merchants and others. A special exception is made for cotton fiber papers because they are used for "fine stationery, ledger papers, maps, wedding invitations and the like, and thus occupy a special niche in the printing-writing category."

Paper for high-speed copiers and forms bond (for computers, carbonless etc.) are also exempted from the requirements. There is no exception for archival paper because EPA equates alkaline with archival, and has discovered two companies that make alkaline recycled paper.

It will be very hard for government agencies to find paper that meets the requirements of both recycled content and true archival quality. After a while they will probably give up trying to find archival paper at all, because it will take all their energy to comply with the EPA rule, which has the force of law.

The procuring agencies have to be all set to implement this rule by June 22, 1989. This means that they have to have an affirmative action program in place by that time, the various aspects of which are spelled out in the rule; promotion of recycled paper, certification and verification that the minimum percent of recovered material is included in the paper, an annual review, monitoring, documentation and so on. There are additional procedures for requesting an exception to be made for cases (e.g. archival paper) in which recycled paper will not serve the purpose. Specs must be drafted based on standards related to performance; documentation must be provided showing that any recycled paper rejected is rejected for its performance, not because it will not run in the machines available; and so on. Once a case has been made for an exemption, the job is not done for good, a new exemption has to be obtained every year. And purchasers who can't find, say, any archival bond paper on the market with 50% recycled fiber are supposed to then try for 40%, or 30%, or whatever they can get.

It is all very complex, and there seems to be only one way to get around it: to use rag paper, forms bond and high speed copy paper for everything. These are the only printing and writing papers that do not have to contain recycled fiber. The rest have to contain 50% recycled fiber.

During the comment period, October to June, protests were made by representatives of the paper industry, the Librarian of Congress, the Archivist of the U.S., and the American Library Association, but they were largely ineffective. The EPA said that the objections it received to the 50%. minimum level were not supported by data.

Besides the issue of the difficulty of finding archival paper with 50%. recycled fiber in it, there are other questions. Who can guarantee that there will be no groundwood fiber in the recycled paper? According to the EPA and to knowledgeable people in the industry, it is hard to be sure that recycled pulp contains no groundwood or unbleached fibers.

How can we prove to EPA that archival standards should apply to all printing/writing paper? (A look at the types of papers that end up in presidential libraries should settle the question whether ordinary office papers should be purchased for permanence. And presidential libraries are not different from other libraries and archives in the amount of "ordinary" printing and writing paper in their collections.)

How can a purchaser conform both to the Joint Committee on Printing's paper standards and this EPA rule? Does the EPA rule interfere with conformity to the JCP standards, and can it be said to be reconcilable in practice with them?

What do the paper companies think? It is not easy for some of them to find recycled fiber of the right sort at a fair price, if they are far from the markets.

The recycling industry must be jubilant. Business is already flourishing for them. Twenty-seven percent of all paper produced is recycled; 4.4 million tons were exported last year. At least one company (Trans-Rim Ltd. of Seattle) is in a position to ask a multi-million dollar package of subsidies from the state of New York to establish a recycled. containerboard mill near Dunkirk.

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