|Received:||5/15/2008 10:03:31 AM|
|Organization:||Steel Recycling Institute|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:Green Packaging Workshop – Comments, Project No. P084200 William Heenan, President Steel Recycling Institute May 15, 2008 On behalf of our member companies (the United States steel-producing industry), I appreciate the opportunity to provide you with some comments in reaction to some of the information that was provided at the workshop on Green Packaging claims held in Washington, DC on April 30, 2008. Recycling Claims We found the comments by Michelle Harvey, with Environmental Defense Fund (EDF), to be breathtakingly misinformed! What Ms. Harvey stated was that those materials or industries (specifically steel) should not be making claims anymore because “everyone already knows that steel is recyclable and is being recycled.” She indicated that our claims are “irrelevant!” In other words, the steel industry cannot and should not take credit for what we already do - - no matter how successful we are, and yet other materials that are just getting started or have lower recycling rates (that’s every other material) can take credit and put such information on their packaging. We take very strong objection to this unenlightened position. We expect that other “established” recycling materials (glass, aluminum, and most other metals) would agree. Industries that are “doing it right” should take credit for being in the lead. Consumers do not always know that this recycling is taking place or that this industry is recycling at very high rates. What is even more stunning about Ms. Harvey’s statement is that it contradicts directly the position that EDF has held over the last 15 to 20 years with regard to the recycling efforts (and success story) of America’s steel industry. Steel is the most recycled material in the United States, and is recycled more than all the other materials combined. It is a fact that should be put before the consumer at all opportunities. The presentation by the National Recycling Coalition (Kate Krebs) included a reference to their recent survey which indicated that 51% of respondents (consumers) rely on the symbol on the package to provide them with recycling information. This reinforces the need for our well-established recycling efforts to be conveyed by stating the fact that steel packaging is recyclable. Recycling Data Several speakers, including Sara Hartwell with the U.S. Environmental Protection Agency (EPA), stated that comprehensive national data on recycling locations is not available. EPA is very much aware that we (Steel Recycling Institute) have created a recycling database that was developed at our own expense over the past 15 years. We continue to update this database and it provides steel recycling information for consumers in all 50 states. It also contains the information on how and where a variety of other materials can be recycled (aluminum, glass, paper, plastics, etc.), along with type of collection systems (curbside, drop off, etc.), locations and contact information. We currently only provide this information to consumers asking about steel, but would be open to providing this information for other materials if we received the necessary EPA funding. We have been discussing this with EPA for several years now, especially this past year, with the hopes of EPA taking over the database if we could convince Congress to provide the funding necessary for maintenance and update. We are relatively confident that Congress is willing to provide modest funding for this effort, however, EPA has chosen to ignore our suggestion and apparently is under the impression that such a system does not exist. We would be happy to demonstrate to the FTC how our database operates at your convenience. Please do not hesitate to contact me if you have any additional questions via email: BHeenanSRI@aol.com or via phone: 412.922.2772 x205.