Submission Number: 00218
Received: 12/10/2010 12:48:57 PM
Commenter: Danny McCoy
Organization: Darman Mfg. Co., Inc
State: New York
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
Careful examination wording should be made when creating definitions regarding recycled content that will become part of regulations which may inadvertantly exclude a more sustainable "greener" virgin product.
An example of this is an existing government regulation that requires only products made from recycled materials qualify for purchasing by a government agency.
When this existing regulation is used to purchase products, such as; uniforms, hand drying towels, shop towels or many other textile items, it eliminates using the most environmentally friendly products (made from virgin natural fibers). This defeats the intent of the regulation. Textile products made from cotton (or other natural fibers), can be reused up to 100 times (after which they are recycled into other products) and have much less environmental impact than a product made from recycled materials that can only be used once and then disposed of.
The bottom line is: Products made from recycled materials may not be the most environmentally friendly "green" product for the task. Definations that are created should not eliminate the use of "greener" virgin products that do not contain recycled materials, but are much more environmentaly friendly.
An example of this existing regulation is in purchasing gowns used in healthcare. The regulation forces the use of a gown made with recycled materials thus only paper (or recycled non woven synthetic) gowns are specified which are disposable gowns. This eliminates the use of virgin cotton gowns that can be washed 30+ times and then are recycled into other products. It has been repeatedly proven that the cotton gown is far more environmentally friendly "greener" than the gowns made from recycled paper or recycled synthetics. The cotton gown is also much less expensive and has been shown repeatedly to have a much better environmentally friendly Life Cycle Analysis than the gowns made from recycled materials.
Another example is in hand drying. Paper towels made from recycled paper would be specified over a cloth roll towel, because the cloth roll towel is not made from recycled materials. The cloth roll towel lasts 100 washings (replacing 30,000 paper towels), has been shown to have a better environmental life cycle analysis than recycled paper towels. Cloth roll towles are also recycled into other products after 100 washings.
Furthermore, all paper towels are used only once and end up in the dump, because they can not be recycled because of the water resistant binders used to make them. The type of paper used for recycled paper towels can only have been recycled a maximum of 3 times, because the fibers become too short to be used for paper towels. Paper can normally be recycled up to 10 times for other products - thus using recycled paper for paper towels shortens the number of times the paper could have been used in other products.