Federal Procurement: Better Guidance and Monitoring Needed to	 
Assess Purchases of Environmentally Friendly Products (22-JUN-01,
GAO-01-430).							 
								 
The Resource Conservation and Recovery Act of 1976 (RCRA),	 
directed the Environmental Protection Agency (EPA) to identify	 
products made with recycled waste materials or solid waste	 
by-products and to develop guidance for purchasing these	 
products. The act also requires procuring agencies to establish  
programs for purchasing these products. This report examines (1) 
implement RCRA requirements for procuring products with recycled 
content and (2) purchase environmentally preferable and bio-based
products. EPA accelerated its efforts in the 1990s to identify	 
recycled-content products, but the status of agencies' efforts to
implement the RCRA purchasing requirements for these products is 
uncertain. The four major procuring agencies report that, for	 
many reasons, their procurement practices have not changed to	 
increase their purchases of environmentally preferable and	 
bio-based products. One reason for the lack of change is that EPA
and the U.S. Department of Agriculture have been slow to develop 
and implement the programs.					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-430 					        
    ACCNO:   A01028						        
  TITLE:     Federal Procurement: Better Guidance and Monitoring      
             Needed to Assess Purchases of Environmentally Friendly Products  
     DATE:   06/22/2001 
  SUBJECT:   Environmental policies				 
	     Federal procurement				 
	     Federal procurement policy 			 
	     Recycling						 
	     Reporting requirements				 
	     EPA Resource Conservation and Recovery		 
	     Act Program					 
								 

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GAO-01-430
     
Report to Congressional Requesters

United States General Accounting Office

GAO

June 2001 FEDERAL PROCUREMENT Better Guidance and Monitoring Needed to
Assess Purchases of Environmentally Friendly Products

GAO- 01- 430

Page i GAO- 01- 430 Federal Procurement Letter 1

Appendix I Objectives 27

Appendix II Comments From the Office of Management and Budget 28

Appendix III Comments From the Office of the Federal Environmental Executive
29

Appendix IV Comments From the General Services Administration 32

Appendix V Comments From the National Aeronautics and Space Administration
35

Appendix VI Comments From the Department of Energy 36

Appendix VII Comments From the Department of Defense 40

Figures

Figure 1: EPA?s Designation of Recycled- Content Products, 1983 Through
2000. 8 Contents

Page 1 GAO- 01- 430 Federal Procurement

June 22, 2001 The Honorable Max S. Baucus The Honorable Tom Harkin The
Honorable James M. Jeffords The Honorable Carl Levin United States Senate

The federal government buys about $200 billion of products and services each
year to conduct its operations. Through its purchasing decisions, the
federal government has the opportunity to affirm its environmental policies
and goals for preventing pollution, reducing solid waste, increasing
recycling, and stimulating markets for environmentally preferable products
and services. Recognizing this potential, the Congress, in the Resource
Conservation and Recovery Act of 1976 (RCRA), directed the Environmental
Protection Agency (EPA) to identify products made with recycled waste
materials or solid waste by- products and to develop guidance for purchasing
these products. The act also requires procuring agencies to establish
programs for purchasing these products. Procuring agencies, which can
include contractors and state and local government grantees, are exempt from
this requirement only under certain conditions and must document their
reasons for not purchasing the recycled- content products (commonly called a
waiver).

In a further effort to use federal purchasing power to promote environmental
goals, the President issued an executive order in 1998, replacing a similar
executive order issued in 1993, to encourage federal agencies to buy
products that are environmentally preferable and/ or biobased.
Environmentally preferable products are those that have a lesser or reduced
adverse effect on human health and the environment when compared with
competing products that serve the same purpose- for example, paints that
release lower levels of toxic vapors. A biobased product is a commercial or
industrial product, other than food or feed, that is made from biological
products or renewable domestic agricultural (plant, animal, and marine) or
forestry materials- for example, soy ink. EPA is responsible for developing
guidance to help agencies identify environmentally preferable products,
while the U. S. Department of Agriculture (USDA) is responsible for
compiling a list of biobased products.

Other federal agencies have related oversight or coordination
responsibilities under RCRA or the executive order. The Office of Federal

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 01- 430 Federal Procurement

Procurement Policy in the Office of Management and Budget (OMB) is
responsible for coordinating the RCRA requirements with other federal
procurement policies and for reporting to the Congress every 2 years on
federal agencies? progress in implementing these requirements. Under the
1998 executive order, the Federal Environmental Executive, who is appointed
by and reports to the President, is responsible for recommending initiatives
for governmentwide procurement preference programs for products with
recycled content and for environmentally preferable products. In keeping
with this responsibility, the Office of the Federal Environmental Executive
prepares a biennial report to the President on agencies? actions and has
developed a governmentwide strategic plan to prevent the accumulation of
unnecessary waste and to encourage the purchase of these environmentally
friendly products. 1 According to the 1998 executive order, major federal
procuring agencies that are responsible for purchases of more than $50
million annually of goods and services are to appoint an agency
environmental executive to translate the strategic plan into specific agency
plans, implement the plans, and report to the Office of the Federal
Environmental Executive on their progress. The Office of Federal Procurement
Policy and the Office of the Federal Environmental Executive coordinate
their information requests from the major procuring agencies and issue a
joint report to the Congress.

Interested in whether federal procuring agencies are fully implementing the
relevant requirements of RCRA and the 1998 executive order, you asked us to
determine the status of, and barriers to, federal agencies? efforts to (1)
implement RCRA requirements for procuring products with recycled content and
(2) purchase environmentally preferable and biobased products. In conducting
this review, we surveyed the four agencies that account for about 85 percent
of all federal procurements- the departments of Defense and of Energy, the
General Services Administration (GSA), and the National Aeronautics and
Space Administration (NASA). In addition, we surveyed two major
grantawarding agencies- the departments of Transportation and of Housing and
Urban Development. Detailed information on the scope and methodology for our
review is provided in appendix 1.

1 The strategic plan, ?Greening the Government Through Waste Prevention,
Recycling, and Federal Acquisition,? was issued March 12, 1999, by the White
House Task Force on Greening the Government Through Waste Prevention and
Recycling, which is chaired by the Federal Environmental Executive.

Page 3 GAO- 01- 430 Federal Procurement

EPA accelerated its efforts in the 1990s to identify recycled- content
products, but the status of agencies? efforts to implement the RCRA
purchasing requirements for these products is uncertain. Thus far, EPA has
identified 54 products with recycled content. However, we could not
determine the extent to which the large procuring agencies are purchasing
these products because most lack reliable and complete data on such
purchases. The agencies lack data primarily because their procurement
systems are generally not designed to track these purchases- particularly
those made through contracts (which account for at least 90 percent of
federal procurement dollars); with federal purchase cards (used like credit
cards); or by grantees. Instead, to meet their reporting requirements, most
of the agencies provide estimates of recycled- content purchases to the
Office of Federal Procurement Policy and to the Office of the Federal
Environmental Executive. In addition, the agencies have not adequately
monitored their purchases, and several studies indicate that the success of
their efforts to promote awareness of the RCRA requirements has been
limited. Although the four agencies have efforts under way to promote the
purchase of recycled- content products, these may not reach all staff,
contractors, and grantees that make purchasing decisions. We are making
several recommendations to improve the agencies? programs to purchase EPA-
designated recycled- content products.

The four major procuring agencies report that, for a number of reasons,
their procurement practices have not changed to increase their purchases of
environmentally preferable and biobased products. One reason for the lack of
change is that EPA and USDA- the federal agencies responsible for managing
programs to purchase environmentally preferable and biobased products- have
been slow to develop and implement the programs. EPA?s guidance on
purchasing environmentally preferable products, issued in 1999- 5 years
later than the executive order required- recommends that agencies? assess a
product?s ?cradle- to- grave? effect on the environment. However, all four
agencies we reviewed indicated that it would be easier to purchase
environmentally preferable products if EPA identified a list of such
products as it did for recycled- content products under RCRA. The agencies
report that identifying products to purchase using the guidance is difficult
and time- consuming. Recognizing this, EPA is developing additional tools to
help agencies make these purchases. USDA, which is responsible for
developing a list of biobased products, does not currently have resources
dedicated to this task. However, it has set a goal for completing the list
by fiscal year 2002- 3 years later than the executive order required. In
general, federal procuring agencies are waiting for USDA to publish a list
before making any final decisions or modifications to their procurement
programs. Results in Brief

Page 4 GAO- 01- 430 Federal Procurement

We requested written comment from 10 agencies on a draft of this report. We
received written comments from six of these agencies- all essentially
agreeing with the facts we presented.

The use of federal procurement to promote environmental goals has gained
increasing emphasis since the 1976 RCRA legislation. Under RCRA section
6002, each procuring agency 2 purchasing more than $10,000 of an item (in a
fiscal year) that EPA has designated as available with recycled content must
have an affirmative procurement program in place. This program is to ensure
that the agency purchases recycled- content products to the maximum extent
practicable. This requirement applies both to purchases made directly by the
agency and to purchases made indirectly by their contractors and grantees.

To comply with RCRA and the executive order, an agency?s affirmative
procurement program must consist of four elements:

 a preference program that requires the agency to institute practices and
procedures favoring the specification and procurement of recycledcontent
products;

 internal and external programs to actively promote the purchase program
for recycled- content products;

 procedures for obtaining pre- award estimates and post- award
certifications of recovered materials content in the products to be supplied
under any contracts over $100, 000 and, where appropriate, reasonably
verifying those estimates and certifications; and

 procedures for monitoring and annually reviewing the effectiveness of the
affirmative procurement program to ensure the use of the highest practicable
percentage of recycled- content materials available.

The 1998 executive order strengthened the RCRA requirements for an effective
affirmative procurement program for recycled- content products and added two
new product types- environmentally preferable products and biobased
products. The 1998 executive order further clarified some previous
requirements and defined more clearly the duties of the Federal
Environmental Executive and the responsibilities of agency environmental
executives in implementing certain initiatives and actions to further

2 Procuring agencies are federal agencies, state and local agencies using
appropriated federal funds, and their contractors. Background

Page 5 GAO- 01- 430 Federal Procurement

encourage the ?greening? of the government through federal procurement. The
order did not require agencies to purchase environmentally preferable and
biobased products, but encouraged them to do so. A recent change to the
Federal Acquisition Regulations 3 (FAR) formalized the 1998 executive order
by making it a requirement for all executive agencies and contracting
officers to follow when buying products, including supplies that are
furnished under a service contract. The changes to the FAR also emphasized
executive branch policies to purchase products containing recycled content
material and other environmentally preferable products and services when
feasible.

The Office of the Federal Environmental Executive has overarching
responsibilities to advocate, coordinate and assist federal agencies in
acquiring recycled- content, environmentally preferable, and biobased
products and services. In 1999 the White House Task Force on Greening the
Government, chaired by the Federal Environmental Executive, issued a
strategic plan that calls upon all executive agencies to demonstrate
significant increases in the procurement of recycled- content products from
each preceding year through 2005. Each agency?s environmental executive is
responsible for overseeing the implementation of the agency?s affirmative
procurement program and for setting goals to increase purchases of recycled-
content products in accordance with the White House Task Force?s strategic
plan.

Although all procuring agencies are required to have an affirmative
procurement program and to track their purchases of recycled- content
products, the Office of Federal Procurement Policy and the Office of the
Federal Environmental Executive limit their annual reporting requirement to
the top six procuring agencies. These six agencies are the departments of
Defense, Energy, Transportation, and Veterans Affairs; GSA; and NASA. Two of
these agencies, Defense and GSA, have a dual role- first, as procuring
agencies subject to RCRA and the executive order and second, as major
suppliers of goods and services to other federal agencies. 4 As such, both
use recycled- content products and supply other federal

3 The Federal Acquisition Regulations specify rules that agencies must
follow in their procurement actions. On June 6, 2000 the Civilian Agency
Acquisition Council and the Defense Acquisition Regulations Council
published a final rule amending the Federal Acquisition Regulations to
implement Executive Order 13101, ?Greening the Government through Waste
Prevention, Recycling, and Federal Acquisition,? dated September 14, 1998.

4 The Defense Logistics Agency and GSA maintain central stock inventories
and vendor supply lists for use by all federal agencies.

Page 6 GAO- 01- 430 Federal Procurement

agencies with recycled- content products. The Office of Federal Procurement
Policy and the Office of the Federal Environmental Executive issue a joint
report to the Congress every 2 years on these agencies? progress in
purchasing the EPA- designated products.

Federal agencies must also comply with acquisition reform legislation
enacted during the 1990s. In response to concerns about the government?s
ability to take advantage of the opportunities offered by the commercial
marketplace, these reforms streamlined the way that the federal government
buys its goods and services. 5 For example, the reforms introduced
governmentwide commercial purchase cards, similar to corporate credit cards,
to acquire and pay for goods and services of $2,500 or less. The cards,
known as federal purchase cards, are issued to a broad range of personnel.

EPA accelerated its efforts in the 1990s to identify and issue guidance on
procuring products with recycled content, but the extent to which the major
federal procuring agencies, with the exception of Energy, have purchased
these products cannot be determined because they do not have data systems
that clearly identify purchases of recycled- content products. In addition,
these agencies do not receive complete data from their headquarters and
field offices or their contractors and grantees. As a result, they generally
provide estimates, not actual purchase data, to the Office of Federal
Procurement Policy and the Office of the Federal Environmental Executive.
According to three of the major procuring agencies- including Defense, which
accounts for over 65 percent of federal government procurements 6 -even
these estimates are not reliable. In addition, agencies? efforts to promote
awareness of purchase requirements for recycled- content products have had
limited success, and their efforts to monitor progress have principally
relied on the estimated data they report. A White House task force has made
a number of

5 The Federal Acquisition Streamlining Act of 1994 authorized federal
agencies to enter into multiple award contracts and introduced the micro-
purchase threshold for purchase cards up to $2, 500. The Clinger- Cohen Act
of 1996 allowed agencies to authorize more employees to make purchases up to
$2, 500.

6 This figure includes all Defense procurements- including weapons systems
and research and development funds, which are unlikely to include the
purchase of recycled- content products. The figure also includes service
contracts- which may or may not involve the purchase of these products.
Federal Purchases of

Recycled- Content Products Cannot Now Be Determined Because of Incomplete
Reporting and Lack of Monitoring

Page 7 GAO- 01- 430 Federal Procurement

recommendations to improve data collection, particularly from federal
purchase card users and contractors.

In the early 1980s, the Congress directed EPA to issue guidance for five
products with recycled content, three of which the Congress designated:
cement and concrete containing fly ash, 7 recycled paper and paper products,
and retread tires. Between 1983 and 1989, EPA issued guidance for these
three products and also issued guidance for re- refined lubricating oil and
building insulation. 8 EPA did not issue guidance for any more products
until 1995. Between 1995 and 2000, EPA increased the total number of
designated products to 54 and issued comprehensive procurement guidance to
use in purchasing these products. Figure 1 shows the increases in the number
of designated products with recycled content.

7 Fly ash is the residue that results from the combustion of pulverized
coal. 8 See Solid Waste: Federal Program to Buy Products With Recovered
Materials Proceeds Slowly (GAO/ RCED- 93- 58, May 17, 1993). EPA Has
Accelerated the

Designation of Products With Recycled Content

Page 8 GAO- 01- 430 Federal Procurement

Figure 1: EPA?s Designation of Recycled- Content Products, 1983 Through
2000.

EPA has identified eight categories of recycled- content products. These are
listed below, with examples of products in each category.

 Construction products: building insulation containing recycled paper or
fiberglass; carpeting containing recycled rubber or synthetic fibers; floor
tiles made with recycled rubber or plastic.

 Landscaping products: landscaping timbers and posts containing a mix of
plastic and sawdust or made of fiberglass; hydraulic mulch containing paper;
compost made from yard trimmings and/ or food waste.

 Nonpaper office products: trash bags containing recycled plastic; waste
receptacles containing recycled plastic or steel; and binders containing
recycled plastic or pressboard.

 Paper and paper products: copier paper, newsprint, file folders, and paper
towels and napkins, all of which have recycled fiber content.

 Park and recreation products: picnic tables and park benches containing
recycled plastics or aluminum; playground equipment containing recycled
plastic or steel; fencing using recycled plastic.

 Transportation products: parking stops containing recycled plastic or
rubber; traffic barricades containing steel or recycled fiberglass; traffic
cones containing recycled PVC or rubber.

54 36 24

5 4 1 0 10

20 30

40 50

60 1983 1988 1989 1995 1997 2000 Number of products

Page 9 GAO- 01- 430 Federal Procurement

 Vehicular products: engine coolants (antifreeze), re- refined motor oil
and retread tires, all of which contain recycled content materials.

 Miscellaneous products: awards and plaques containing glass, wood, or
paper; drums containing steel or plastic; signs and sign posts containing
plastic steel or aluminum.

EPA officials have also identified 10 additional recycled- content products
for designation and expect to issue purchasing guidelines for them in 2001.
They also plan to designate more products as they become available.
According to EPA officials, the list of possible products continues to
evolve because new products are always being developed and existing products
may be changed, adding more recycled material.

RCRA outlines criteria for determining which items to designate as recycled-
content products. EPA?s guidance expands on these criteria, which include
the following:

 the availability of the item, including whether it is obtainable from an
adequate number of sources to ensure competition;

 the effect of the procurement on the amount of solid waste diverted from
landfills;

 the capability of the item to meet the agency?s needs and the item?s cost
in relationship to products that do not have recycled content; and

 the determination of whether the item will have a negative impact on (1)
other recycled- content products by displacing one recovered material for
another recovered material- resulting in no net reduction in materials
requiring disposal; (2) the supply of recovered materials due to the
diversion of recovered materials from one product to another- resulting in
shortages of materials for one or both products; and (3) the availability of
supplies to manufacture the product- resulting in insufficient supplies over
time.

In reviewing EPA?s files for all products designated since 1995, we found
that EPA had considered these criteria. Furthermore, EPA had not failed to
list any major product containing recycled materials that was likely to be
purchased by federal agencies, according to the four major procuring
agencies and the National Recycling Coalition, an organization that
represents recycling groups, large and small businesses, and federal, state,
and local governments.

However, the four major procuring agencies said that the list contains more
items than they can feasibly track the purchases of and that targeting their
tracking efforts on the major items they purchase would be a better

Page 10 GAO- 01- 430 Federal Procurement

use of their resources. For example, NASA officials told us that they
annually purchase only about 100 traffic cones- one of the designated items-
but have to bear the burden of tracking these purchases to prove that they
do not exceed the $10,000 threshold, which would trigger the annual
reporting requirement. The four agencies also told us that it is costly and
burdensome to update their tracking programs each time EPA adds new items
and to document whether or not their purchases of these products meet the
$10,000 threshold. Defense and GSA officials added that instead of
continuing to add products to the designated list, EPA should work with the
agencies to assist them in buying products already identified. Although EPA
has a Web site that provides some information regarding a product?s
availability, agency officials indicated that the information is not easily
accessible or kept up to date. For example, Defense and GSA officials said
that (1) EPA should provide more information on the availability of the
individual products, since listed products may not be available in all
regions of the country, and (2) EPA should identify the manufacturers and
costs of the recycled- content products and take the lead in promoting them,
thus making it easier for federal agencies to buy these products. Officials
at the Office of the Federal Environmental Executive agreed with Defense?s
and GSA?s assessment regarding purchasing difficulties.

Three of the four major procuring agencies do not provide credible and
complete information on their purchases of recycled- content products
because (1) they do not have automated tracking systems for these products,
and (2) the information they do collect and report does not include a
significant portion of their procurements, such as those made by
contractors. As a result, they estimate the extent of their purchases in
reporting to the Office of Federal Procurement Policy and the Office of the
Federal Environmental Executive. However, agency officials acknowledge that
these estimates are not reliable.

Defense, GSA, and NASA reported that they cannot use their automated
procurement systems to track recycled- content products purchased by
officials in their headquarters and field offices and by their contractors
and grantees. As a result, they collect information manually, a process they
find costly and time- consuming. This is particularly the case for agencies
with large field structures. For example, Defense said that to satisfy the
Office of Federal Procurement Policy and the Office of the Federal
Environmental Executive reporting requirements, it must collect Information
on

Agencies? Purchases of Products With Recycled Content Is Largely Unavailable

Agencies Lack Automated Tracking Systems for Recycled- Content Products

Page 11 GAO- 01- 430 Federal Procurement

information manually from the thousands of installations managed by the
Army, Navy, Air Force, and Defense Logistics Agency. Defense requests the
necessary information from these units, but does little if they do not
provide the data. Similarly, GSA reported that it manually collects purchase
data on recycled- content products from its headquarters and field offices.
However, Defense and GSA reported that they can electronically track actual
purchases of recycled- content products made through their automated central
supply systems, which also records purchases made by other agencies, if the
products are included in Defense and GSA stock inventories. The systems do
not track items purchased from vendor lists.

According to Defense and GSA officials, recent improvements to these central
supply systems include electronic catalogues of environmentally friendly
products linked to an automated shopping system, which will allow the
agencies to better track and report on other agencies? purchases of
recycled- content products.

NASA and Energy offices also manually collect purchase data on
recycledcontent products but enter the information into automated systems
for tracking and reporting. However, they have not integrated these
automated systems with their agencywide procurement systems. Despite this
lack of integration, Energy officials indicated that, with their current
tracking system, they are able to determine the extent to which most of
their offices and contractors are purchasing recycled- content products.
NASA officials reported that their system provides more limited data on some
contractors.

Defense and GSA officials acknowledged that their data collection would
improve if they had on- line electronic systems for recycled- content
products linked to agencywide procurement systems. However, the additional
cost of developing such an integrated system would not be worthwhile,
according to these officials. For example, Defense believes that the cost of
developing and maintaining a reliable system to produce the data needed to
comply with current reporting requirements would far exceed the value of the
information produced.

The data the agencies collect and report to the offices of Federal
Procurement Policy and of the Federal Environmental Executive generally
exclude several sources of information. One source is federal purchase card
acquisitions, which are increasing and now account for about 5 percent of
all federal purchases. The four procuring agencies reported Major Purchase
Sources

Are Excluded From the Agencies? Reports

Page 12 GAO- 01- 430 Federal Procurement

that they cannot track federal card purchases of recycled- content products
made in the private sector, such as desk accessories, tires, and lubricating
oil, unless they establish an internal system that relies on the card users
to keep records. Defense and GSA reported that they do not have such
systems. Defense officials noted that requiring purchase card users to keep
logs is in conflict with acquisition reforms intended to simplify the
procurement process for purchases below $2,500 (micropurchases). 9 Energy
and NASA officials stated they do track and report purchases of recycled-
content products through federal purchase cards and have established
processes for staff to keep records for entry into their database for the
recycled content program.

The agencies? data are also incomplete because they may exclude information
on purchases made by some of their component organizations. For example,
Defense reported that the military services provide mostly estimated data,
which they do not verify to determine accuracy and completeness.
Furthermore, these estimates do not include all of the services. For
example, the Army provided no information for Defense?s report to the Office
of Federal Procurement Policy and the Office of the Federal Environmental
Executive for fiscal years 1998 and 1999, and the Air Force and Navy
provided limited purchase data. The lack of reliable data from Defense is of
particular concern in evaluating the effectiveness of the RCRA program
because Defense?s procurements account for over 65 percent of total federal
procurements reported for fiscal year 1999. Defense reported that it
purchased recycled- content products worth about $157 million out of total
fiscal year 1999 procurements of about $130 billion. (The total fiscal year
procurement figure of $130 billion includes $20 billion for research and
development and $50 billion for major weapons systems, which are unlikely to
involve the procurement of recycled- content products. In addition, $53
billion for service contracts may or may not involve the purchase of
recycled- content products. Defense officials indicated that some of these
figures may overlap.)

Finally, the agencies lack complete data on purchases made by contractors
and grantees. This data gap is potentially significant because

9 The use of federal purchase cards was encouraged in 1993 by the National
Performance Review, which identified the purchase card as a major
acquisition reform and recommended that all federal agencies increase their
use of the card to cut the red tape normally associated with the federal
procurement process.

Page 13 GAO- 01- 430 Federal Procurement

contracts over $25, 000 account for almost 90 percent of all federal
procurements. The agencies reported the following:

 Defense has no information on contractors? purchases.

 GSA has limited information on some contractors? purchases.

 Energy, which spends about 94 percent of its appropriations on
contractors, collects purchase information from about 86 percent of its
contractors.

 NASA collects purchase data from on- site contractors but receives little
or no data from off- site contractors.

RCRA requires federal contractors to estimate the percentage of
recycledcontent material used to fulfill their contracts (not the specific
products) and to certify that they have met the minimum requirements for
recycled content. The Federal Acquisition Streamlining Act established that
the estimation requirement under RCRA applies only to contracts exceeding
$100,000. However, for individual purchases by federal agencies that exceed
$10,000, the Office of Federal Procurement Policy requires the agencies to
track and report the total dollar amount by product and, in some cases, to
report the volume of recycled- content products. The agencies reported that
it is difficult, if not impossible, for them to separate information on
products with recycled content from information on other products without
such content (virgin materials). For example, according to GSA, when it lets
a contract for remodeling offices, the contract does not necessarily
distinguish between the cost of carpeting containing recycled content and of
virgin- content carpet. It may provide information on only the total cost of
carpeting. The contractor might have to purchase virgin- content carpeting
for certain areas (e. g., high- traffic hallways) and might be able to use
carpeting with recycled content in other areas (e. g., staff offices). In
such a case, GSA would provide only an estimate to the Office of Federal
Procurement Policy of the value of carpet with recycled material.

GSA officials also pointed out that performance- based contracts do not
include detailed product estimates. For example, a contract to construct a
building may not indicate either the amount or cost of the recycledcontent
concrete used.

Finally, the agencies lack data on grantee purchases. State and local
agencies receiving federal grants may be ?procuring agencies? under RCRA. If
they meet the $10,000 threshold- that is, if they spend more than $10,000 on
a designated item- they are subject to the affirmative procurement program
requirement and to buying the recycled- content

Page 14 GAO- 01- 430 Federal Procurement

products on EPA?s list. However, grantees are not required to report their
purchases of EPA- designated products with recycled content. Also, executive
orders do not apply to grantees. Because of overall federal efforts to
reduce the paperwork (reporting) burden on grantees, federal agencies stated
that they cannot request information from grantees without OMB approval.
Consequently, six of the agencies we reviewed, including the major grant
making agencies- DOT and HUD- reported that they do not obtain any
information on grantees? purchases.

A White House task force workgroup on streamlining and improving reporting
and tracking, cochaired by the Federal Environmental Executive and OMB?s
Office of Federal Procurement Policy, has made a number of recommendations
to improve data collection from federal purchase card users and contractors.
It recommended that it begin a pilot project with banks and willing vendors
to identify and report recycled- content product purchases made with federal
purchase cards. We believe that this effort would provide useful additional
information regarding purchase card users? compliance with the RCRA
requirements.

With respect to contractors, the task force workgroup and various agencies
recommended revisions to the Federal Procurement Data System- a system that
collects information on procurements on a governmentwide basis for contracts
over $25, 000. 10 The revised data system would require the procuring
official to indicate whether the contract includes (1) recycled- content
products and identifies the reasons for granting waivers, and (2)
appropriate language from the Federal Acquisition Regulations to ensure that
the contractor is notified of the requirements for purchasing recycled-
content products. These proposed revisions are currently being circulated to
the agencies for comment. If these changes are implemented, the agencies
will no longer have to manually collect and report on their individual
purchases of recycledcontent products. Although the revised system will not
provide information on the products themselves or of the dollar amount
associated with them, it would allow agencies for the first time to identify
contracts subject to purchases of recycled- content products and to measure
their

10 This data system, operated by GSA on behalf of the Office of Federal
Procurement Policy, has been in operation since 1978. It has undergone
numerous changes over the years and is considered by some agency officials
to be outdated. A multiagency task force is currently considering replacing
or reengineering this system to take advantage of newer technologies. White
House Task Force

Has Recommended Improvements in Data Collection

Page 15 GAO- 01- 430 Federal Procurement

annual progress in increasing the percentage of contracts containing
affirmative procurement clauses.

The four major procuring agencies have ongoing efforts, and are developing
strategies, to promote awareness of the requirement to purchase recycled-
content products, but several studies indicate that the success of these
efforts to date has been limited. In addition, although RCRA requires
federal agencies to review and monitor the effectiveness of their RCRA
program efforts, only Energy has taken any steps beyond the data collection
efforts discussed earlier.

Studies of the agencies? affirmative procurement programs report that the
agencies are not effectively educating procurement officials about the
requirement to buy EPA- designated recycled- content products. This lack of
awareness is a major or contributing factor to inaccurate data and
noncompliance with implementing affirmative procurement programs, according
to our survey of the agencies, as well as the reports by the GSA and NASA
inspectors general, the Air Force?s Internal Audit Agency, and a fiscal year
2000 EPA survey of 72 federal facilities. 11

Efforts to promote the purchase of recycled- content products by government
agencies, their contractors, and grantees can occur government- or
agencywide. Governmentwide efforts include those conducted by the Office of
the Federal Environmental Executive, which actively promotes, coordinates,
and assists federal agencies? efforts to purchase EPA- designated items. For
example, the Office of the Federal Environmental Executive has helped
increase agency purchases of EPAdesignated products by encouraging GSA, the
Defense Logistics Agency, and the Government Printing Office to
automatically substitute recycledcontent products in filling orders for
copier paper (begun in 1992) and lubricating oil (begun in 1999). This
effort has increased sales of recycled

11 The three audits include the NASA Inspector General?s Final Report on the
Audit of Kennedy Space Center?s Recycling Efforts, IG- 98- 017, June 12,
1998; the GSA Inspector General?s Review of GSA?s Affirmative Procurement
Program, A71503/ P/ 5/ R97016, March 28, 1997; and an Air Force Audit
Agency?s report in its Affirmative Procurement Program, Project Number
99052016, June 1999. Agencies? Efforts to

Promote RecycledContent Products Have Generally Not Increased Awareness, and
Only One Agency Reviews and Monitors Purchases

Success of Promotion Efforts Is Limited

Page 16 GAO- 01- 430 Federal Procurement

content copier paper from a level of 39 percent to a level of 98 percent at
GSA and the Government Printing Office, according to the Office of the
Federal Environmental Executive. GSA now carries only recycled- content
copier paper. The Defense Logistics Agency reported that its sales of
rerefined lubricating oil increased over 50 percent from fiscal year 1999 to
fiscal year 2000. Given the success of the automatic substitution program
for these products, the Office of the Federal Environmental Executive is
strongly encouraging agencies to identify other recycled- content products
for which automatic substitution policies might be appropriate. However,
this program does not apply to purchases made outside of the federal supply
centers.

GSA and Defense have also placed symbols in their printed and electronic
catalogues and in their electronic shopping systems to identify
recycledcontent products. Using the electronic catalogue, agencies can then
go directly into the electronic shopping system to order these products.
They will also be able to track and report these purchases- including those
made with purchase cards. Defense and GSA are also working jointly to modify
the Federal Logistics Information System to add environmental attribute
codes to the products listed in that system to more easily identify
environmentally friendly products. 12 The modification?s usefulness may be
limited, however, because this system does not automatically link the user
to a system for purchasing the products identified, according to agency
officials.

In addition to governmentwide promotion efforts, agencies reported using a
variety of techniques to make their decentralized organizations aware of the
RCRA requirements. The agencies provide classroom and computerassisted
training on purchasing recycled- content products and on incorporating the
RCRA purchasing requirements into program manuals. The four major procuring
agencies also reported that they promoted the procurement of EPA- designated
products through such mechanisms as their Web sites, telephone and
videoconferences, videotapes, electronic newsletters, workshops, and
conferences. As indicated by the Inspectors

12 The Federal Logistics Information System is a computerized database that
serves as a centralized, government- wide repository for information on the
more than 7 million items in the federal supply system. In addition to
showing the name and national stock number for each item, the system
provides vendor information, the item?s physical characteristics, and
guidance on acquiring, storing, distributing, transporting, using, and
disposing of the item. Procurement officials use the system primarily to
research which items are most appropriate for them to purchase.

Page 17 GAO- 01- 430 Federal Procurement

Generals? reports and agency studies, and our own analysis, even though the
agencies have used many techniques to inform their staff of these
requirements, staff awareness, particularly in field offices, remains a
problem.

Agencies generally must rely on methods less direct than providing classroom
training, or having workshops or conferences, for making their contractors
aware of the requirement to purchase recycled- content products.
Accordingly, Energy, GSA, and Defense?s Air Force, Navy, and Army Corps of
Engineers have initiated alternative efforts to inform contractors of these
requirements. Energy makes its major facility management contractors part of
its affirmative procurement program team to help implement the program.
Moreover, in May 2000, Energy established ?green acquisition advocates? at
each of its major contracting facilities. Among their duties, these
advocates are to promote the RCRA program to the contractors. GSA and the
three Defense components have developed ?green? construction and/ or lease
programs that promote the use of EPA- designated products. In addition, all
the agencies we reviewed have incorporated the Federal Acquisition
Regulation clauses pertaining to the RCRA program into their contracts. GSA
also reported that it plans to modify its acquisition manual to include a
review of the list of EPAdesignated products with contractors in post- award
conferences. In addition, GSA?s regional offices have begun evaluating the
effectiveness of their affirmative procurement programs.

The agencies we examined have generally not developed agency- specific
mechanisms for advising grantees of their responsibility to purchase
recycled- content products. Instead, they rely on OMB Circular A- 102. This
circular refers to RCRA and contains a general statement on the requirement
for grantees to give preference in their purchases to the EPAdesignated
products. It does not inform them of the specific requirements they need to
follow, such as developing affirmative procurement programs. Three of the
four procuring agencies and the two major grantawarding agencies that we
reviewed- the departments of Housing and Urban Development and
Transportation- rely on either this circular or a similar general statement
to inform grantees of the RCRA requirements. 13

13 Of the two large grant awarding agencies, Housing had about 85 percent ($
28 billion) of its fiscal year 1999 total outlay in grants to state and
local governments, and Transportation had about 69 percent ($ 29 billion) of
its fiscal year 1999 total outlay in grants to state and local governments.
Three of the four major procuring agencies have grant programs; GSA does
not.

Page 18 GAO- 01- 430 Federal Procurement

Only Energy, in its financial assistance regulations, requires its
grantawarding program offices to inform grantees of the RCRA requirement.

According to officials at the Office of the Federal Environmental Executive,
grantees could obtain specific information about RCRA requirements if OMB
included that information in the ?common rule? under Circular A- 102. The
common rule, directed by a March 1987 presidential memo and adopted in
individual agency regulations, provides supplemental information, generally
in the form of more detailed instructions on processes grantees should
follow in implementing the circular?s requirements. However, it does not
mention RCRA?s requirements for an affirmative procurement program.
Officials at the departments of Transportation and Housing and Urban
Development did not know whether their grantees had an affirmative
procurement program or whether grantees were aware of the requirements to
purchase recycledcontent products. Officials said that unless they were
specifically directed by OMB, seeking this information could be interpreted
as an additional burden on grantees and an unfunded mandate. In April 2000,
the Federal Environmental Executive recommended to the President that OMB
revise the Circular A- 102 common rule to ?require recipients of federal
assistance monies to comply with the RCRA buy- recycled requirements.? 14
She added that federal agencies administering grant programs should educate
state and local government recipients about the requirements.

RCRA requires federal agencies to review and monitor the effectiveness of
their recycled- content programs; however, it does not define what this
review and monitoring should consist of. With the exception of Energy, which
has established purchasing goals that its contractors must meet, the major
procuring agencies limit their required annual review and monitoring
functions to compiling data on their purchases of recycledcontent products
in order to report to the Office of the Federal Environmental Executive and
the Office of Federal Procurement Policy. But as the agencies admit, these
data are unreliable and incomplete. Consequently, these data do not allow
the agencies to assess their progress in purchasing recycled- content
products or review the effectiveness of their recycled- content purchase
programs. However, Defense procurement officials believe that legislation
like RCRA, because

14 Greening the Government: A Report to the President on Federal Leadership
and Progress, by Fran McPoland, Federal Environmental Executive, Apr. 22,
2000. Agencies? Review and

Monitoring of Recycled Content Purchases Is Limited

Page 19 GAO- 01- 430 Federal Procurement

of its review and monitoring requirements, is in conflict with the
streamlining reforms that are intended to ease the administrative burden
associated with government purchases.

An indication of the agencies? lack of monitoring is the scarcity of
information on exemptions or waivers. Agencies may waive the RCRA
requirement to purchase recycled- content products if the recycled product
is too costly, does not meet appropriate performance standards, or is not
available. The number of waivers approved, when compared with purchases of
products both with and without recycled content, would tell the agencies how
far they are from meeting the goal of purchasing only recycled- content
products designated by EPA. In addition, a review of these waivers will
allow the agencies to identify the reasons for not purchasing these products
and identify potential problems. Although the four major procuring agencies
said that they do require this justification, only Energy has analyzed the
waivers to determine reasons for not purchasing recycled- content products
and how close it is to meeting the goal of purchasing only recycled- content
products, where appropriate. Energy has concluded that it is making steady
progress in its purchases of recycled- content products. However, as EPA
adds new items to the list, Energy officials told us that progress tends to
level off until staff become familiar with the new products.

The procuring agencies reported little progress in purchasing
environmentally preferable products, in part because both EPA and USDA have
taken longer to issue guidance than provided for by the executive orders.
Moreover, while EPA has issued final guidance to help agencies identify
environmentally preferable products, it is not required to develop a list of
these products. According to the agencies, implementing the EPA guidance for
determining what constitutes an environmentally preferable product is
difficult and time- consuming. In addition, USDA has not published a list of
biobased products for procuring agencies? consideration, as required by the
executive order. USDA plans to have a list available by fiscal year 2002,
but this effort is only one of a number of projects competing for the same
resources. Although the purchase of these products is not required by
statute, the agencies we reviewed plan to modify their procurement programs
to encourage the purchase of such products after the list is published.
Agencies?

Implementation of Executive Orders to Purchase Environmentally Preferable
and Biobased Products Proceeds Slowly

Page 20 GAO- 01- 430 Federal Procurement

EPA published final guidance for federal procuring agencies to use in
purchasing environmentally preferable products in 1999, 5 years later than
directed by the 1993 executive order. 15 EPA?s Office of Pollution
Prevention and Toxics, which is charged with issuing the guidance, stated
that it delayed issuance until it had results from some agencies? pilot
projects. These projects tested concepts and principles for their
applicability to actual purchasing decisions. EPA noted that because an
environmentally preferable product can have multiple attributes- such as
having recycled content, conserving water and/ or energy, and/ or emitting a
low level of volatile organic compounds- defining environmental
preferability depends on the product?s use. The guidance is not intended to
be a step- by- step plan or ?how to? guide for agencies? use in deciding to
purchase specific products; nor is it intended to provide a list of
products. Instead, it is intended to help executive agencies systematically
integrate the purchasing of these products into their buying decisions.

Under the process outlined, the agencies are to use the guidance in choosing
which products are environmentally preferable and meet their needs. This
process involves assessing a product?s life- cycle, which may include a
comprehensive examination of a product?s environmental and economic aspects
and potential impacts throughout its lifetime, including raw material
transportation, manufacturing, use, and disposal.

EPA has also focused on identifying approaches for purchasing
environmentally preferable products by encouraging agencies to participate
in pilot projects. In selecting pilot projects, agencies are encouraged to
use a list that EPA has developed of the top 20 product and service
categories, which represent a large volume of federal procurement or have
significant environmental impacts. For example, a U. S. Army installation
conducted a pilot on paint products, which are on the list and are known to
contain significant quantities of volatile organic compounds. Accordingly,
the intent of the pilot was to identify paints that had a lesser adverse
environmental impact on air quality, which is a particular concern for this
installation.

In addition, EPA has enlisted the assistance of two standard- setting
organizations- Underwriters Laboratory and NSF International- to develop
environmental standards that may be used in federal purchasing. Underwriters
Laboratory is helping to identify consensus- based industry

15 64 Fed. Reg. 45810 (Aug. 20, 1999). EPA and Agencies Have

Had Difficulty Defining and Identifying Environmentally Preferable Products

Page 21 GAO- 01- 430 Federal Procurement

standards for a more environmentally friendly stretch wrap for packing and
shipping, while NSF International is working with EPA to develop standards
for institutional cleaners and carpeting.

Federal agencies? development and implementation of programs to encourage
purchases of environmentally preferable products has not resulted in
significant changes to agencies? procurement practices. The procuring
agencies in our review participated in pilot projects and, with the
exception of Defense, 16 have changed, or are in the process of changing,
their affirmative procurement programs to include the executive order
requirements regarding environmentally preferable products. However, agency
officials said it is difficult to incorporate EPA?s guidance into
procurement activities. This difficulty occurs in part because implementing
the guidance is a time- consuming process that procuring officials are
unlikely to undertake because they lack knowledge in this area. In addition,
EPA has not provided a clear definition or list of environmentally
preferable products. For example, in purchasing environmentally friendly
paint, a number of products are available- one may be a paint with recycled
content, resulting in a reduced environmental impact on the waste stream,
while another may have lower volatile organic compounds and thus lessen the
adverse impact on air quality. Agencies are not statutorily required to
purchase environmentally preferable products and the difficulties associated
with this process are a disincentive.

EPA officials acknowledge that there is a scarcity of information about the
environmental performance of products and services, particularly regarding
the various life- cycle stages of manufacturing, distribution, use and
disposal related to a product. They also acknowledge that progress is
somewhat slow in getting federal procurement agencies to adopt the

?environmentally preferable? process as part of their procurement practices.
However, over time and with the dissemination of more information and tools
for agencies to use, considering environmentally preferable products in
purchasing decisions will become more routine, EPA officials believe. EPA
has developed a Web site to provide some of the support and tools that
procuring agencies need. The Web site provides information on agencies?
pilot projects; environmental standards; product information, such as the
results of assessments of life- cycle and case

16 Within Defense, only the Air Force and the Defense Logistics Agency have
drafted changes to their affirmative procurement programs to include
environmentally preferable products.

Page 22 GAO- 01- 430 Federal Procurement

studies; and lessons learned by agencies that have purchased environmentally
preferable products and services. EPA has also developed an interactive
training module and a guide with examples of specific contract language that
purchasing agencies have used.

USDA has not published a list of biobased products for agencies to consider
in their purchasing practices, as directed by the 1998 executive order. It
has, however, published a notice for comment (in the August 1999

Federal Register) on suggested criteria for listing biobased products.
Agency officials explained that the delay in publishing the list is due, in
part, to the lack of funding for this effort and that the work to develop
the list must compete with other projects for the same resources. A list
should be available in fiscal year 2002, according to USDA officials.

All four procuring agencies said that they will include the published list
of biobased products in their affirmative procurement programs. However,
although a list of biobased products will make it easier to identify these
products for purchasing, officials at Defense, GSA, and NASA indicated that
the list will not necessarily ensure that staff will purchase them.
Officials noted that these purchases are not mandatory under the executive
order, which only calls for agencies to modify their affirmative procurement
programs to give consideration to the biobased products. The officials added
that the lack of knowledge and education about biobased products is a major
barrier to ensuring that staff will consider and purchase these products. As
a result, they have not made any significant changes in their procurement
practices. However, Energy, GSA, and NASA have taken steps to amend their
regulations to include the updated Federal Acquisition Regulations published
in June 2000, which, among other things, encourages the purchasing of
biobased products. Also, both GSA and Energy have included information on
these products in their training programs to make staff aware of biobased
products and the upcoming list.

USDA officials told us that they would like the biobased program to be
statutorily based, like the recycled- content program. Agencies would then
be mandated to purchase these products. In addition, they believe that the
program will be much more effective if there is an assessment of a product?s
life- cycle and such products are required to meet performance standards set
by independent standard setting or testing organizations. The officials
believe that the absence of life- cycle and performance information will be
a major barrier to the agencies? purchasing biobased products unless they
have the information to show the long- term benefits USDA Has Not Published
a

Biobased Products List for Procuring Agencies?

Page 23 GAO- 01- 430 Federal Procurement

of the items. However, because of resource constraints, USDA is instead
relying on manufacturers to self- certify their products. The officials
added that biobased products are considered risky purchases by federal
agencies because of the lack of information available on their performance
and are generally purchased by agencies only after they hear about the
product anecdotally- an inefficient way to bring products to the market.

Twenty- five years after RCRA was to launch a revolution in federal
purchases of recycled- content products, the success of this effort is
largely uncertain. For many years, until the 1990s, little action was taken
to promote such purchases on a governmentwide or agencywide basis. Even
today, many procuring officials and other federal purchasers either do not
know about or implement the RCRA requirements for establishing affirmative
procurement programs, particularly promotion and review and monitoring.

Although some progress in implementing the RCRA requirements has occurred,
such as EPA?s accelerating its designation of recycled- content products,
procuring agencies report that EPA?s designation of these products, by
itself, is not sufficient to ensure that they are purchased. The agencies
told us that staff often are either not aware of these products or not able
to locate them in their area. Furthermore, the agencies have made little
effort to ensure that grantees are aware of their obligations to purchase
recycled- content products.

Even if recycled- content products were more widely available and promoted
more effectively, most agencies- with the exception of Energy- cannot
determine the success of their efforts to increase the purchases of such
products. They have not developed systems to track their purchases of such
products, relying instead on inadequate estimates. Nor have they put
programs in place to review and monitor progress. Moreover, most agencies
lack data about purchases of recycled- content products by contractors and
grantees. These agencies do not have any reliable means of even identifying
contracts that call for the use of recycled- content products. In this
regard, we support the White House task force recommendation to revise the
Federal Procurement Data System to identify such contracts. While this
revision will not provide agencies with information on specific purchases,
it will enable them to periodically review and monitor their contractors for
compliance with the RCRA requirements. Conclusions

Page 24 GAO- 01- 430 Federal Procurement

Demonstrating that an agency is meeting the RCRA requirements can be
administratively difficult. The major procuring agencies noted that it is
costly and burdensome to update their purchase tracking programs each time
EPA designates recycled- content products; each relies on costly and time-
consuming manual data collection. Defense, the largest procuring agency,
believes efforts to monitor and report on recycled- content product
purchases conflict with the streamlining goals of procurement reform. We
recognize that review and monitoring of recycled- content products entails
administrative costs. Nonetheless, RCRA requires such information.

 To help agencies purchase recycled content products, we recommend that the
Federal Environmental Executive and the Administrator of EPA work with
officials at the major procuring agencies to develop a process to provide
the procuring agencies with current information on the availability of the
designated recycled- content products. In addition, these officials should
determine how these products can be more effectively promoted.

 To help agencies implement the RCRA requirement to annually monitor and
review the effectiveness of affirmative procurement programs, we recommend
that the Director, OMB, instruct the Director of the Office of Federal
Procurement Policy to provide procuring agencies with more specific guidance
on fulfilling the RCRA review and monitoring requirements and, in
conjunction with the Federal Environmental Executive, use the results of the
agencies? efforts in their reports to the Congress and the President.

 If the White House Task Force recommendation revising the Federal
Procurement Data System (or its replacement) is implemented, then the
Director, OMB, should instruct the Director of the Office of Federal
Procurement Policy to provide guidance to the federal procuring agencies on
using the information added to the system to periodically review
contractors? compliance with the RCRA requirements for purchasing recycled-
content products.

 To ensure that grantees purchase recycled- content products as required by
RCRA, the Director of the Office of Federal Financial Management, OMB, in
coordination with federal agencies, should amend the common rule so that it
incorporates the RCRA requirements, as recommended in the Federal
Environmental Executive?s Report to the President entitled Greening the
Government.

We provided a draft of this report to the following agencies for their
review and comment: EPA, OMB, the Office of the Federal Environmental
Executive, GSA, NASA, and the departments of Agriculture, Defense, Energy,
Housing and Urban Development, and Transportation. EPA and Recommendations

for Executive Action Agency Comments

Page 25 GAO- 01- 430 Federal Procurement

the departments of Agriculture, Housing and Urban Development, and
Transportation declined to formally comment on the report. However, some of
these agencies provided technical suggestions that we incorporated into the
report as appropriate. The remaining agencies generally agreed with the
facts presented in the report. Specifically, with the exception of Energy,
they agreed that the current data systems do not identify the extent of
their purchases of recycled- content products. OMB, to whom three of the
four recommendations are directed, expressed general agreement with them.
However, Energy pointed out that in several instances in the report, we did
not make clear that it does have a data system that identifies actual data
purchases of recycled- content products made by the agency or its
contractors. We have clarified the report where appropriate.

OMB, the Office of the Federal Environmental Executive, GSA, NASA, and the
departments of Energy and Defense?s comments and our responses are in
appendixes II- VII.

We conducted our review between June 2000 and April 2001 in accordance with
generally accepted government auditing standards. A detailed discussion of
our objectives, scope, and methodology is presented in appendix I.

As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution of it for 30 days. We
will then send copies of this report to appropriate congressional committees
and other interested Members of Congress; the Administrator of EPA; the
Director of OMB; the Office of the Federal Environmental Executive; the
Secretaries of Agriculture, Defense, Energy, HUD, and Transportation; and
the Administrators of NASA and GSA. We will also make copies available to
others upon request.

Page 26 GAO- 01- 430 Federal Procurement

If you or your staff have any further questions about this report, please
call me at (202) 512- 6878. Key contributors to this report were James
Donaghy, Patricia Gleason, Maureen Driscoll, William Roach Jr., Paul
Schearf, and Carol Herrnstadt Shulman.

David G. Wood Director, Natural Resources and Environment

Appendix I: Objectives Page 27 GAO- 01- 430 Federal Procurement

In January 2000, Senators Max Baucus, Tom Harkin, James Jeffords, and Carl
Levin sent us a series of questions related to federal government agencies?
purchases of recycled- content products, environmentally preferable
products, and biobased products. After discussing these issues with their
offices, we agreed to address the status of, and barriers to, federal
agencies efforts to (1) implement the Resource Conservation and Recovery
Act?s requirements for procuring products with recycled content, and (2)
procure environmentally preferable and biobased products.

In conducting this review, we focused on four agencies that account for
about 85 percent of all federal procurements- the departments of Defense and
Energy, General Services Administration, and the National Aeronautics and
Space Administration. In addition to interviewing appropriate officials at
these agencies, we conducted a written survey in which we asked them a
series of questions related to their purchases of products with recycled
content, environmentally preferable products, and/ or biobased products. We
also surveyed two major grant- awarding agencies- the departments of
Transportation and of Housing and Urban Development- to determine the extent
of such purchases made by their grantees.

In addition, we contacted the Environmental Protection Agency (EPA), the
Office of Federal Procurement Policy within the Office of Management and
Budget, and the White House Office of the Federal Environmental Executive to
determine their effectiveness in managing and overseeing the agencies?
implementation of the programs for procuring products with recycled content
and environmentally preferable and biobased products. We also reviewed EPA?s
progress in designating products with recycled content and in issuing
guidance on environmentally preferable products to other agencies, as well
as the Department of Agriculture?s progress in identifying and publishing
information on biobased products. We obtained and analyzed information on
the procurement of products with recycled content, as designated by EPA, and
barriers to full implementation of the affirmative procurement programs of
the four largest federal procuring agencies. We also contacted the Office of
the Inspector General for each of the federal agencies in our review to
identify whether the offices had conducted any formal reviews or audits of
the agencies? affirmative procurement programs. Finally, we contacted
industry and environmental groups to obtain their perspectives and to
identify whether any additional data existed related to the procurement of
the EPA- listed products with recycled content. Appendix I: Objectives

Scope and Methodology

Appendix II: Comments From the Office of Management and Budget

Page 28 GAO- 01- 430 Federal Procurement

Appendix II: Comments From the Office of Management and Budget

Appendix III: Comments From the Office of the Federal Environmental
Executive

Page 29 GAO- 01- 430 Federal Procurement

Appendix III: Comments From the Office of the Federal Environmental
Executive

Note: GAO comment supplementing the report text appear at the end of this
appendix.

See comment 1.

Appendix III: Comments From the Office of the Federal Environmental
Executive

Page 30 GAO- 01- 430 Federal Procurement

Appendix III: Comments From the Office of the Federal Environmental
Executive

Page 31 GAO- 01- 430 Federal Procurement

The following is GAO?s comment on the Office of Management and Budget?s
letter dated May 17, 2001.

1. This section of the report has been revised to include the latest
information on the changes to the FPDS system. GAO Comment

Appendix IV: Comments From the General Services Administration

Page 32 GAO- 01- 430 Federal Procurement

Appendix IV: Comments From the General Services Administration

Note: GAO comments supplementing those in the report text appear at the end
of this appendix.

Appendix IV: Comments From the General Services Administration

Page 33 GAO- 01- 430 Federal Procurement

See comment 3. See comment 2. See comment 1.

Appendix IV: Comments From the General Services Administration

Page 34 GAO- 01- 430 Federal Procurement

The following are GAO?s comments on GSA?s letter dated May 15, 2001. 1. On
p. 11 of the report, we state that GSA can electronically track purchases of
recycled- content products made through their automated central supply
system.

2. This information has been included in the report on p. 17. 3. The report
has been clarified to identify the difficulties that procurement officials
face in assessing a product?s life cycle. GAO Comments

Appendix V: Comments From the National Aeronautics and Space Administration

Page 35 GAO- 01- 430 Federal Procurement

Appendix V: Comments From the National Aeronautics and Space Administration

Appendix VI: Comments From the Department of Energy

Page 36 GAO- 01- 430 Federal Procurement

Appendix VI: Comments From the Department of Energy

Note: GAO comments supplementing those in the report text appear at the end
of this appendix.

Appendix VI: Comments From the Department of Energy

Page 37 GAO- 01- 430 Federal Procurement

See comment 1. See comment 1. See comment 1.

See comment 2. See comment 1.

Appendix VI: Comments From the Department of Energy

Page 38 GAO- 01- 430 Federal Procurement

See comment 1.

Appendix VI: Comments From the Department of Energy

Page 39 GAO- 01- 430 Federal Procurement

The following are GAO?s comments on the Department of Energy?s letter dated
May 21, 2001.

1. The report has been revised as appropriate to clarify that Energy tracks
and reports actual purchases of recycled- content products for the agency
and its contractors.

2. The word ?toxic? has been added as suggested. GAO Comments

Appendix VII: Comments From the Department of Defense

Page 40 GAO- 01- 430 Federal Procurement

Appendix VII: Comments From the Department of Defense

(160533)

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