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Materials
Management

Comprehensive Procurement
Guidelines for Construction
Products
EPA designated the following construction products under the Comprehensive Procurement Guidelines
(CPG) program to promote the use of materials recovered from municipal solid waste (MSW). Recycled-
content recommendations for each item are listed below.

On this page:

Building Insulation
Carpet (Polyester)
Carpet Cushion
Cement and Concrete
Consolidated and Reprocessed Latex Paint
Floor Tiles
Flowable Fill
Laminated Paperboard
Modular Threshold Ramps
Non-pressure Pipe
Patio Blocks
Railroad Grade Crossing Surfaces
Roofing Materials
Shower and Restroom Dividers/Partitions
Structural Fiberboard
Proposed: Nylon Carpet and Nylon Carpet Backing

Building Insulation
Insulation made from recovered materials is available for thermal insulating applications. The product
is available in several forms including rolls, loose-fill and spray foam. Insulation also can include a
range of recovered materials such as glass, slag, paper fiber and plastics. One manufacturer grinds

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post-consumer glass bottles into a substitute for the sand used


in glass fibers. Others use slag for rock wool or old newspaper Additional
for cellulose insulation. Resources

EPA's Recovered Materials Advisory Notice (RMAN)


<https://epa.gov/smm/regulatory-background-comprehensive-procurement- Find
guideline-program-cpg> recommends recycled-content levels for manufacturers/supplier
purchasing building insulation as shown in the table below. s of recycled-content
products in our
database
<https://epa.gov/smm/compre
hensive-procurement-
guideline-cpg-
program#directory>

Buy recycled-content
products from the GSA
Advantage! catalogues

<https://www.gsaadvantage.g
ov/advantage/ws/main/start_
page>

EPA's product resource


guides
<https://epa.gov/smm/produc
t-resource-guides-
comprehensive-procurement-
guideline-cpg-program>

Recommended Recovered Materials Content Levels for Building Insulation 1

Postconsumer Total Recovered


Product Material
Content (%) Materials Content (%)

Rock Wool Slag -- 75

Fiberglass Glass Cullet -- 20-25

Cellulose Loose-Fill Postconsumer


75 75
and Spray-On Paper

Perlite Composite Postconsumer


23 23
Board Paper

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Total
Recovered
Sub- Postconsumer
Product Material Materials
Product Content (%)
Content
(%)

Rigid
Plastics -- 9
Foam

Foam-in-
Plastics -- 5
Place

Plastic Rigid Foam,


Glass
Polyisocyanurate/Polyurethane Fiber Plastic/Glass -- 6
Reinforced

Phenolic
Rigid Plastics -- 5
Foam

Recovered
and/or
Plastic, Non-Woven Batt -- -- 100
Postconsumer
Plastics

1The recommended recovered materials content levels are based on the weight (not volume) of

materials in the insulating core only.

Product Specifications
In 1993, the American Society for Testing and Materials (ASTM) issued a standard for the composition of
cullet used in the manufacture of fiberglass insulation, D 5359, "Glass Cullet Recovered from Waste for
Use in Manufacture of Glass Fiber." EPA recommends that procuring agencies reference this
specification in Invitations for Bid and Requests for Proposals.

For more information on EPA's Building Insulation product research, please see the Technical
Background Document for RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-procurement-
guideline-program-cpg>.

Carpet (Polyester)
EPA designated recycled-content polyester carpet for moderate-wear applications. Recycled fiber
polyester carpet is manufactured from PET recovered soda bottles.

EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing carpeting as shown
in the table below.

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EPA's Recommended Recovered Materials Content Levels for Carpet1

Postconsumer Total Recovered Materials


Product Material
Content (%) Content (%)

Polyester Carpet
PET 25-100 25-100
Face Fiber

1
EPA recommends that, based on the recovered materials content levels shown in the table above,
procuring agencies establish minimum content standards for use in purchasing polyester carpet for
moderate-wear applications. This recommendation does not include polyester carpet for use in heavy-
wear or severe-wear applications.

Product Specifications
Procuring agencies should also refer to GSA's minimum density recommendations, as follows:

Cut pile constructions: 5,000 ounces/yard3 minimum density


Loop pile constructions: 4,500 ounces/yard 3 minimum density

While numerous carpet specifications exist, the members of the carpet industry do not utilize any
universal standards. Specifications vary and are determined based on the particular factors of the
installation. The project's designer, architect, general contractor and/or facility manager typically
decide the specifications. Some procuring agencies, such as the Department of the Army and the
Department of Housing and Urban Development, have developed their own specifications for end-use
carpet applications. These specifications should be readily available to procurement officials in those
agencies.

For more information on EPA's Carpet (polyester) product research, please see the Technical
Background Document for RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-procurement-
guideline-program-cpg>.

Carpet Cushion
Carpet cushion, also known as carpet underlay, is padding placed beneath carpet. Carpet cushion
improves the insulation properties of carpet, reduces the impact of foot traffic or furniture indentation,
enhances comfort and prolongs appearance. It is available in a variety of thicknesses-the most
common being ¼- and ½-inch-and is used in both residential and commercial settings. Carpet
cushions made from bonded urethane, jute, synthetic fiber and rubber can be made from recovered
materials.

EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing carpet cushion as
shown in the table below.

Recommended Recovered Materials Content Levels for Carpet Cushion1

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Postconsumer Total Recovered


Product Material
Content (%) Materials Content (%)

Bonded Old carpet


15-50 15-50
polyurethane cushion

Jute Burlap 40 40

Carpet
Synthetic fibers -- 100
fabrication scrap

Rubber Tire rubber 60-90 60-90

1EPA's recommendations do not preclude a procuring agency from purchasing another type of carpet

cushion. They simply require that procuring agencies, when purchasing bonded polyurethane, jute,
synthetic fiber, or rubber carpet cushions, purchase these items made with recovered materials when
these items meet applicable specifications and performance requirements. Refer to Section C-4 in
RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-procurement-guideline-program-cpg> for EPA's
recommendations for purchasing polyester carpet containing recovered materials.

Product Specifications
EPA is not aware of carpet cushion specifications unique to carpet cushions containing recovered
materials. Therefore, EPA recommends that procuring agencies use any appropriate standards set by
the Carpet and Rug Institute <http://www.carpet-rug.org/> and the Carpet Cushion Council
<http://www.carpetcushion.org/> when purchasing bonded polyurethane, jute, synthetic fiber or rubber
carpet cushion containing recovered materials.

For more information on EPA's product research on recovered-content latex paint, please see the
Technical Background Document for RMAN III <https://epa.gov/smm/regulatory-background-comprehensive-
procurement-guideline-program-cpg>.

Cement and Concrete


Coal fly ash, ground granulated blast furnace (GGBF) slag,
cenospheres and silica fumes are recovered materials that are Additional
readily available in some areas for use as ingredients in cement Product
or concrete. Coal fly ash is a byproduct of coal burning at
electric utility plants. Slag is a byproduct of iron blast furnaces.
The slag is ground into granules finer than Portland cement
and can be used as an ingredient in concrete. Cenospheres are
small, inert, lightweight, hollow, glass spheres that are a
component of coal fly ash. They can be added to cement to
produce a specialty, high performance concrete. Silica fume is

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a waste material recovered from alloyed metal production. It Information


can also be added to cement to produce a high performance
concrete.
Learn more about
EPA recommends that procuring agencies prepare or revise specifications for
their procurement programs for cement and concrete or for cement and concrete
construction projects involving cement and concrete to allow containing recovered
the use of coal fly ash, ground granulated blast furnace slag materials
(GGBF slag), cenospheres or silica fume, as appropriate. EPA <https://epa.gov/smm/compre
does not recommend that procuring agencies favor one hensive-procurement-
recovered material over the other. Rather, EPA recommends guidelines-cement-and-
that procuring agencies consider the use of all of these concrete-specifications>
recovered materials and choose the one (or the mixture of Study on Increasing the
them) that meets their performance requirements, consistent Usage of Recovered
with availability and price considerations. EPA also Mineral Components in
recommends that procuring agencies specifically include Federally Funded
provisions in all construction contracts to allow for the use, as Projects Involving
optional or alternate materials, of cement or concrete which Procurement of Cement
contains coal fly ash, GGBF slag, cenospheres or silica fume, or Concrete
where appropriate. <https://epa.gov/smm/study-
increasing-usage-recovered-
Due to variations in cement, strength requirements, costs and
mineral-components-
construction practices, EPA is not recommending recovered
federally-funded-projects-
materials content levels for cement or concrete containing coal
involving>.
fly ash, GGBF slag, cenospheres or silica fume. However, EPA is
providing the following information about recovered materials
content.

Replacement rates of coal fly ash for cement in the production of blended cement generally do not
exceed 20-30 percent, although coal fly ash blended cements may range from 0-40 percent coal fly
ash by weight, according to ASTM C 595 <https://www.astm.org/c0595_c0595m-21.html>, for cement Types
IP and I(PM). Fifteen percent is a more accepted rate when coal fly ash is used as a partial cement
replacement as an admixture in concrete.
According to ASTM C 595 <https://www.astm.org/c0595_c0595m-21.html>, GGBF slag may replace up to 70
percent of the Portland cement in some concrete mixtures. Most GGBF slag concrete mixtures
contain between 25 and 50 percent GGBF slag by weight. EPA recommends that procuring agencies
refer, at a minimum, to ASTM C 595 for the GGBF slag content appropriate for the intended use of
the cement and concrete.
According to industry sources, cement and concrete containing cenospheres typically contains a
minimum of 10 percent cenospheres (by volume).
According to industry sources, cement and concrete containing silica fume typically contains silica
fume that constitutes 5-10 percent of cementitious material on a dry weight basis.

Technical background information on cement and concrete containing coal fly ash was published in the
Federal Register on January 28, 1983 (48 FR 4230) and codified at 40 CFR 247. This product designation
was one of five incorporated in CPG I/RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-

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procurement-guideline-program-cpg>. For more information on cement and concrete containing cenospheres


and silica fume, please see the Technical Background Document for RMAN IV
<https://epa.gov/smm/regulatory-background-comprehensive-procurement-guideline-program-cpg>.

Consolidated and Reprocessed Latex Paint for


Specified Uses
Reprocessed paint is postconsumer latex paint that has been sorted by a variety of characteristics
including type (i.e., interior or exterior), light and dark colors, and finish (e.g., high-gloss or flat).
Reprocessed paint is available in various colors and is suitable for both interior and exterior
applications. Consolidated paint consists of postconsumer latex paint with similar characteristics (e.g.,
type, color family and finish) that is consolidated at the point of collection. Consolidated paint is
typically used for exterior applications or as an undercoat.

EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing reprocessed and
consolidated latex paint for specified uses as shown in the table below.

Recommended Recovered Materials Content Levels for Reprocessed and Consolidated Latex Paints1

Postconsumer Total Recovered Materials


Product
Content (%) Content (%)

Reprocessed Latex Paint:

- White, Off-White, Pastel Colors 20 20

- Grey, Brown, Earth tones, and


50-99 50-99
Other Dark Colors

Consolidated Latex Paint 100 100

1EPA's recommendation does not preclude agencies from purchasing paints manufactured from other,

non-latex materials, such as oil-based paints. It simply recommends that procuring agencies, when
purchasing latex paints, purchase these items made from postconsumer recovered materials when
these items meet applicable specifications and performance requirements.

Product Specifications
EPA recommends that procuring agencies refer to GSA commercial item description (CID) A-A-3185
when purchasing recycled paint. Currently, the CID is not available electronically.

California State CalRecycle Information and Specifications


<https://www.calrecycle.ca.gov/condemo/paint/>

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Green Seal Recycle Latex Paint Standard 43 (PDF)


<https://www.greenseal.org/storage/standards/august2019/60qrhm6aineikwfesoqm.pdf>(13 pp, 214 Kb, About PDF
<https://epa.gov/home/pdf-files>)

Connecticut State Evaluation and Specifications (PDF)


<http://www.ct.gov/deep/lib/deep/reduce_reuse_recycle/rpaint.pdf>(9 pp, 67 Kb, About PDF
<https://epa.gov/home/pdf-files>)

For more information on EPA's product research on recovered-content latex paint, please see the
Technical Background Document for RMAN II <https://epa.gov/smm/regulatory-background-comprehensive-
procurement-guideline-program-cpg>.

Floor Tiles
Floor tiles for heavy duty or commercial specialty applications can contain up to 100 percent
postconsumer rubber. They are made from used truck and airline tires.

EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing floor tiles and patio
blocks as shown in the table below.

Recommended Recovered Materials Content Levels for Floor Tiles ¹

Postconsumer Total Recovered Materials


Product Material
Content Content (%)

Floor Tiles Rubber 90-100 --


(heavy duty/commercial
use) Plastic -- 90-100

1
EPA clarified in the Federal Register (FR) at 62 FR 60995, November 13, 1997, that the use of floor tiles
with recovered materials content might be appropriate only for specialty purpose uses (e.g., raised,
open-web tiles for drainage on school kitchen flooring). Such specialty purpose uses involve limited
flooring areas where grease, tar, snow, ice, wetness or similar substances or conditions are likely to be
present. Thus, EPA has no recovered materials content level recommendations for floor tiles made with
recovered materials for standard office or more general purpose uses.

For more information on EPA's product research on recovered-content floor tiles, please see the
Technical Background Document for RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-
procurement-guideline-program-cpg>.

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Flowable Fill
Flowable fill is commonly used as an economical fill or backfill in road construction. It is usually a
mixture of coal fly ash, water, a coarse aggregate (such as sand) and portland cement. Flowable fill can
take the place of concrete, compacted soils or sand commonly used to fill around pipes or void areas.
Other applications include filling in bridge abutments, foundation subbases or abandoned man holes
and wells. Flowable fill can help put significant quantities of coal fly ash and spent foundry sand, two
types of recovered materials, back to good use.

EPA recommends that procuring agencies use flowable fill


containing coal fly ash and/or ferrous foundry sands for backfill Additional
and other fill applications. Specific content levels will depend Product
on the specifics of the job, including the type of coal fly ash Information
(Class C or Class F) or foundry sand used, strength, set time,
flowability needed, bleeding and shrinkage.
See a list of states with
specifications for
Product Specifications
flowable fill containing
EPA recommends that procuring agencies use ACI229R-94 coal fly ash
and the ASTM standards when purchasing flowable fill or <https://epa.gov/smm/guidan
contracting for construction that involves backfilling or ce-materials-quantities-
other fill applications. mixtures-and-specifications-

No national test methods or specifications exist for flowable flowable-fill-under-

fill mixtures containing foundry sand. Ohio has a comprehensive>.

specification entitled, "Flowable Fill Made With Spent


Foundry Sand," however. In addition, Pennsylvania,
Wisconsin and Indiana are developing specifications.

For more information on EPA's flowable fill product research, please see the Technical Background
Document for RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-procurement-guideline-program-cpg>.

Laminated Paperboard
Laminated paperboard is made from one or more plies of kraft paper bonded together and is used for
decorative, structural or insulating purposes. Examples include building board, insulating foamboard,
sheathing and acoustical and non-acoustical ceiling tile.

EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing laminated
paperboard as shown in the table below.

Recommended Recovered Materials Content Levels for Laminated Paperboard ¹

Postconsumer Total Recovered Materials


Product Material
Content Content (%)

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Laminated Postconsumer
100 100
Paperboard Paper

1The recovered materials content levels are based on the weight (not volume) of materials in the

insulating core only.

Product Specifications
EPA recommends that procuring agencies use ASTM Standard Specification C 208 and ANSI/AHA
specification A194.1.
In addition, EPA recommends that procuring agencies review their specifications for insulating
products and revise them as necessary to obtain the appropriate "R"-value without unnecessarily
precluding the purchase of products containing recovered materials.

For more information on EPA's laminated paperboard product research, please see the Technical
Background Document for RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-procurement-
guideline-program-cpg>.

Modular Threshold Ramps


Threshold ramps are used to modify door thresholds and other small rises to remove barriers that
changes in level landing create, particularly with regards to access by people with disabilities. Modular
threshold ramps are typically used for retrofitting buildings to comply with the Architectural Barriers
Act (ABA) of 1968, the Rehabilitation Act of 1973, the Uniform Federal Accessibility Standards (UFAS)
and the Americans with Disabilities Act (ADA) of 1990. Modular threshold ramps made from rubber,
aluminum and steel can be made from recovered materials.

EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing modular threshold
ramps as shown in the table below.

Recommended Recovered Materials Content Levels for Modular Threshold Ramps

Postconsumer Total Recovered Materials


Product Material
Content (%) Content (%)

Steel1 16-67 25-100


Modular Threshold
Aluminum -- 10
Ramps
Rubber 100 100

1The recommended recovered materials content levels for steel in this table reflect the fact that the

designated item may contain steel manufactured in either a Basic Oxygen Furnace (BOF) or an Electric
Arc Furnace (EAF), or a combination of both. Steel from the BOF process contains 25-30 percent total
recovered steel, of which 16 percent is postconsumer. Steel from the EAF process contains 100 percent

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total recovered steel, of which 67 percent is postconsumer. According to industry sources, modular
threshold ramps containing a combination of BOF and EAF steel would contain 25-85 percent total
recovered steel, of which 16-67 percent would be postconsumer. Since there is no way of knowing
which type of steel was used in the manufacture of the item, the postconsumer and total recovered
material content ranges in this table encompass the whole range of possibilities, i.e., the use of EAF
steel only, BOF steel only, or a combination of the two. These recommendations are for modular
threshold ramps. EPA understands that ramps may also be constructed of cement and concrete. For
these ramps, procuring agencies should follow the procurement guidelines for cement and concrete
containing recovered materials.

Product Specifications
Although the federal government is not governed by ADA,
the Access Board's ADA standards are more current than the Additional
UFAS and are therefore generally used by federal facilities. Product
According to the "Americans with Disabilities Act Information
Accessibility Guidelines for Buildings and Facilities" (28 CFR
Part 36) , published in the Federal Register, July 26, 1991,
American Disabilities
ground and floor surfaces along accessible routes and in
Act (ADA) and American
accessible rooms and spaces including floors, walks, ramps,
National Standards
stairs and curb ramps, must be stable, firm and slip-
Institute (ANSI)
resistant. The guidelines do not define what is meant by
Standards for Accessible
"stable, firm, and slip-resistant," but the Access Board
Ramps
recommends static coefficient of friction values of 0.8 for
<https://www.ada.gov/2010_r
ramps and 0.6 for accessible routes.
egs.htm>
Although the federal government is not governed by the
ADA references
Department of Justice ADA , the ADA Access Board’s
<http://www.ada.gov/2010ada
standards are useful.
standards_index.htm>

For more information on EPA's modular threshold ramps


product research, please see the Technical Background
Document for RMAN IV <https://epa.gov/smm/regulatory-background-comprehensive-procurement-guideline-program-
cpg>.

Non-pressure Pipe
Non-pressure pipe is used throughout the United States as drainage pipe and conduit in construction,
communications, municipal, industrial, agricultural and mining applications. Non-pressure pipe
containing steel, plastic or cement can be made from recovered materials.

EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing non-pressure pipe
as shown in the table below.

Recommended Recovered Materials Content for Non-pressure Pipe

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Total Recovered Materials


Product Material Postconsumer Content (%)
Content (%)

16 25-30
Steel1
67 100

Non HDPE 100 100

Pressure PVC 5-15 25-100


Pipe
Refer to the cement and concrete specifications
Cement <https://epa.gov/smm/comprehensive-procurement-guidelines-cement-and-
concrete-specifications>.

1
The recommended recovered materials content levels for steel in this table reflect the fact that the
designated item can be made from steel manufactured in either a Basic Oxygen Furnace (BOF) or an
Electric Arc Furnace (EAF). Steel from the BOF process contains 25-30 percent total recovered steel, of
which, 16 percent is postconsumer steel. Steel from the EAF process contains a total of 100 percent
recovered steel, of which, 67 percent is postconsumer steel.

Product Specifications
Learn more about specifications <https://epa.gov/smm/non-pressure-pipe-specifications-under-comprehensive-
procurement-guidelines> for non-pressure pipe containing recovered materials.

For more information on EPA's non-pressure pipe product research, please see the Technical
Background Document for RMAN IV <https://epa.gov/smm/regulatory-background-comprehensive-procurement-
guideline-program-cpg>.

Patio Blocks
Patio blocks made from 90-100 percent recovered plastic and 90 to 100 percent postconsumer rubber
are used in garden walkways and trails.

EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing patio blocks as
shown in the table below.

Recommended Recovered Materials Content Levels for Patio Blocks

Postconsumer Total Recovered Materials


Product Material
Content Content (%)

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Rubber or Rubber
90-100 --
Patio Blends

Blocks Plastic or Plastic


-- 90-100
Blends

For more information on EPA's product research on patio blocks, please see the Technical Background
Document for RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-procurement-guideline-program-cpg>.

Railroad Grade Crossing Surfaces


Railroad grade crossings are surfacing materials placed
between railroad tracks, and between the track and the road at Additional
highway and street railroad crossings, to enhance automobile Product
and pedestrian safety. Railroad grade crossings are made from Information
recovered rubber, concrete containing coal fly ash, steel, wood
or
Learn more about
EPA's Recovered Materials Advisory Notice (RMAN) specifications for
<https://epa.gov/smm/regulatory-background-comprehensive-procurement- railroad grade crossing
guideline-program-cpg> recommends recycled-content levels for surfaces containing
purchasing railroad grade crossing surfaces as shown in the recovered materials.
table below. <https://epa.gov/smm/compre
hensive-procurement-
guidelines-railroad-grade-
crossing-surfaces>

Recommended Recovered Materials Content Levels for Railroad Grade Crossings

Total Recovered
Surface Recovered Postconsumer
Product Materials Content
Material Material Content (%)
(%)

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Concrete Coal Fly Ash 1 -- 15-20

Rubber2 Tire rubber -- 85-95

16 25-30
Steel3 Steel
Railroad 67 100
Grade
Wood or wood
Crossings Wood4 90-97 90-97
composite

Plastic or
Plastic5 plastic 85-95 100
composite

1Coal fly ash can be used as an ingredient of concrete slabs, pavements or controlled density fill

product, depending on the type of concrete crossing system installed. Higher percentages of coal fly
ash can be used in the concrete mixture; the higher percentages help to produce more workable and
durable product but can prolong the curing process.
2The recommended recovered materials content for rubber railroad grade crossing surfaces are based

on the weight of the raw materials, exclusive of any additives such as binders or adhesives.
3
The recommended recovered materials content levels for steel in this table reflect the fact that the
designated items can be made from steel manufactured in either a Basic Oxygen Furnace (BOF) or an
Electric Arc Furnace (EAF). Steel from the BOF process contains 25-30 percent total recovered materials,
of which 16 percent is postconsumer steel. Steel from the EAF process contains a total of 100 percent
recovered steel, of which 67 percent is postconsumer.
4Railroad grade crossing surfaces made from recovered wood may also contain other recovered

materials such as plastics. The percentages of these materials contained in the product would also
count toward the recovered materials content level of the item.
5Railroad grade crossing surfaces made from recovered plastics may also contain other recovered

materials such as auto shredder residue, which contains a mix of materials. The percentages of these
materials contained in the product would also count toward the recovered materials content level of
the item.

For more information on EPA's product research on railroad grade crossing surfaces, please see the
Technical Background Document for RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-
procurement-guideline-program-cpg>.

Roofing Materials
A building's roof system and its finished roofing materials shield a structure's interior from natural
elements. Roofing systems generally fall into two general categories: 1) high-sloped or "pitched" roofs
(residential) and 2) low-sloped or flat roofs (commercial). These two types of systems generally are
constructed differently and use different materials, although some materials are used for both
residential and commercial systems. EPA's designation specifically covers roofing materials containing
steel, aluminum, fiber, rubber, plastic or plastic composites, and cement.

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EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing roofing materials as
shown in the table below.

Recovered Materials Content Recommendations for Roofing Materials

Postconsumer Content Total Recovered Materials


Product Material
(%) Content (%)

16 25-30
Steel1
67 100

Aluminum 20-95 20-95

Fiber (felt) for Fiber


50-100 50-100
Composite

Rubber 12-100 100


Roofing
Materials Plastic or
Plastic/Rubber 100 100
Composite

Wood/Plastic
-- 100
Composite

Refer to the cement and concrete specifications


Cement <https://epa.gov/smm/comprehensive-procurement-guidelines-
cement-and-concrete-specifications>

1The recommended recovered materials content levels for steel in this table reflect the fact that the

designated item can be made from steel manufactured in either a Basic Oxygen Furnace (BOF) or an
Electric Arc Furnace (EAF). Steel from the BOF process contains 25-30 percent total recovered steel, of
which 16 percent is postconsumer steel. Steel from the EAF process contains a total of 100 percent
recovered steel, of which 67 percent is postconsumer steel.

Product Specifications
EPA recommends that procuring agencies refer to the 186 standards for roofing products maintained
by ASTM's Committee D08 on Roofing, Waterproofing, and Bituminous Materials.

For more information on EPA's product research on roofing materials, please see the Technical
Background Document for RMAN IV <https://epa.gov/smm/regulatory-background-comprehensive-procurement-
guideline-program-cpg>.

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Shower and Restroom Dividers/Partitions


Shower and restroom dividers/partitions are made of 20-100 percent recovered plastic or steel. They
are used to separate individual shower, toilet and urinal compartments in commercial and institutional
facilities. EPA's designation specifically covers shower and restroom dividers/partitions containing
recovered plastic or steel.

EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing shower and
restroom dividers/partitions as shown in the table below.

Recommended Recovered Materials Content Levels for Shower and Restroom Dividers/Partitions
Containing Recovered Plastic or Steel

Postconsumer Total Recovered


Product Material
Content Materials Content (%)

16 25-30
Shower and Restroom Steel1
67 100
Dividers/Partitions
Plastic 20-100 20-100

1
The recommended recovered materials content levels for steel in this table reflect the fact that the
designated items can be made from steel manufactured in either a Basic Oxygen Furnace (BOF) or an
Electric Arc Furnace (EAF). Steel from the BOF process contains 25-30 percent total recovered materials,
of which 16 percent is postconsumer steel. Steel from the EAF process contains a total of 100 percent
recovered steel, of which 67 percent is postconsumer.

Product Specifications
EPA recommends that procuring agencies use the following specifications when procuring shower and
restroom dividers/partitions:

The American Institute of Architects (AIA) has issued guidance for specifying construction materials,
including plastic and steel dividers/partitions. The AIA guidance is known throughout the
construction industry as the "Masterspec" and is available through the U.S. General Services
Administration.

For more information on EPA's product research on shower and restroom dividers/partitions, please
see the Technical Background Document for RMAN II <https://epa.gov/smm/regulatory-background-comprehensive-
procurement-guideline-program-cpg>.

Structural Fiberboard
Structural fiberboard is a panel made from wood, cane or paper fibers matted together which is used
for sheathing, structural and insulating purposes. Examples include building board, insulating
foamboard, sheathing and acoustical and non-acoustical ceiling tile.

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EPA's Recovered Materials Advisory Notice (RMAN) <https://epa.gov/smm/regulatory-background-comprehensive-


procurement-guideline-program-cpg> recommends recycled-content levels for purchasing structural
fiberboard as shown in the table below.

Recommended Recovered Materials Content Levels for Structural Fiberboard1

Total
Postconsumer Recovered
Product Material
Content Materials
Content (%)

wood wastes, bagasse (sugar cane


waste), overissue newspapers and
Structural
magazines, and postconsumer -- 80-100
Fiberboard
newspaper, corrugated, and office
paper

1The recovered materials content levels are based on the weight (not volume) of materials in the

insulating core only.

Product Specifications
EPA recommends that procuring agencies use ASTM Standard Specification C 208 and ANSI/AHA
specification A194.1. EPA further recommends that, when purchasing structural fiberboard products
containing recovered paper, procuring agencies should do the following:

Reference the technical requirements of ASTM C 208, "Insulating Board (Cellulosic Fiber), Structural
and Decorative" <https://compass.astm.org/standards/historical/c208-72.htm>.

Permit structural fiberboard products made from recovered paper where appropriate.
Permit products, such as floor underlayment and roof overlay, containing recovered paper.

In addition, EPA recommends that procuring agencies review their specifications for insulating
products and revise them as necessary to obtain the appropriate "R"-value without unnecessarily
precluding the purchase of products containing recovered materials.

For more information on EPA's product research on structural fiberboard, please see the Technical
Background Document for RMAN I <https://epa.gov/smm/regulatory-background-comprehensive-procurement-
guideline-program-cpg>.

SMM Home <https://epa.gov/smm>

Basics <https://epa.gov/smm/sustainable-materials-management-basics>

Built Environment <https://epa.gov/smm/basic-information-about-built-environment>

Electric Arc Furnace Slag <https://epa.gov/smm/electric-arc-furnace-eaf-slag>

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hazardous-secondary-materials>

Packaging <https://epa.gov/smm/sustainable-packaging>

Recycled-Content Products <https://epa.gov/smm/comprehensive-procurement-guideline-cpg-program>

Recycling Economic Information Report <https://epa.gov/smm/recycling-economic-information-rei-report>

Resources, Waste, and Climate Change <https://epa.gov/smm/resources-waste-and-climate-change>

SMM Prioritization Tools <https://epa.gov/smm/sustainable-materials-management-prioritization-tools>

Additional SMM Tools <https://epa.gov/smm/sustainable-materials-management-tools>

Past SMM Webinars <https://epa.gov/smm/sustainable-materials-management-web-academy>

Contact Us <https://epa.gov/smm/forms/contact-us-about-sustainable-materials-management> to ask a question,


provide feedback, or report a problem.

LAST UPDATED ON NOVEMBER 3, 2023

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