MINUTES
EX
PARTE
MEETING
BETWEEN
EPA
AND
NRC
STAKHOLDER
GROUP
NOVEMBER
21,
2003
Attendees
Organization
Kate
Krebs
National
Recycling
Coalition
(
NRC)
George
Vary
American
Zinc
Association
Chip
Foley
Steel
Recycling
Institute
Deborah
Hanlon
U.
S.
EPA,
Office
of
Solid
Waste
(
OSW)
Terry
Grist
EPA,
OSW
Sue
Nogas
EPA,
OSW
Richard
Witt
EPA,
Office
of
General
Counsel
Introduction
On
November
21,
2003,
an
informal
stakeholder
group
facilitated
by
NRC
met
with
representatives
of
the
U.
S.
Environmental
Protection
Agency
(
EPA)
to
discuss
the
Comprehensive
Procurement
Guidelines
(
CPG)
program
generally.

Meeting
Discussion
During
the
meeting,
the
stakeholders
raised
concern
over
certain
language
that
appeared
in
the
CPG
IV
proposed
rule
preamble,
published
in
the
Federal
Register
on
August
21,
2001
(
66FR
45256).
The
language
also
appeared
in
footnotes
to
several
tables
in
EPA's
draft
Recovered
Materials
Advisory
Notice
IV
(
RMAN
IV)
(
see
66
FR
45297).
Specifically,
the
stakeholders
were
concerned
that
this
language
could
somehow
be
misinterpreted
to
mean
that
procuring
agencies
need
not
buy
designated
items
with
recovered
materials,
but
rather
could
buy
virgin
products.
As
an
illustration,
here
is
the
language
as
it
appears
beneath
the
draft
RMAN
IV
table
for
roofing
materials
(
see
66
FR
45304):

A
final
designation
would
not
preclude
a
procuring
agency
from
purchasing
roofing
materials
manufactured
from
another
material.
It
imply
requires
that
a
procuring
agency,
when
purchasing
steel,
aluminum,
fiber,
rubber,
plastic,
wood,
or
cement
roofing
materials,
purchase
these
items
made
with
recovered
materials
when
these
items
meet
applicable
specifications
and
performance
requirements.

EPA
representatives
agreed
to
review
this
language
in
the
CPG
IV
final
rule
preamble
and
final
RMAN
IV
table
footnotes
and
consider
clarifying
it
if
necessary.

**
Minutes
prepared
by
Sue
Nogas,
EPA.
