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 agency2 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 Regulations3

 (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 procurements6

—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

4 5

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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