Drain-waste-vent: PVC, ABS no comments Windows: PVC no comments

Disposal Practices – There is very little construction site scrap associated with PVC pipe. Furthermore, as a result of PVC pipes’ long life durability, only a very small percentage of the PVC pipes installed have become available for recycling or disposal. Nonetheless, the PVC pipe industry has taken a very pro-environmental stance with regard to recycling and/or disposal of its products. The Uni-Bell PVC Pipe Association Member Policy on PVC Pipe Recycling reads as follows: “Uni-Bell member companies support the recycling of PVC pipe products. Uni-Bell members will accept for appropriate recycling all clean, non-contaminated PVC pipes and PVC fittings products and parts which the member has manufactured.” Uni-Bell represents the largest producers of PVC pipes and fittings in the United States and Canada. I am not aware of any other pipe industry that has a more proactive policy with regard to pipe recycling or disposal.

Disposal

The U.S. Environmental Protection Agency (EPA) benchmark report, Characterization of Building-Related Construction and Demolition Debris in the United States, prepared by Franklin Associates Ltd., in June 1998, lists the 36 typical constituents in the construction and demolition debris stream. Vinyl siding is not among them. There were about 1.8 billion pounds (900,000 tons) of vinyl siding shipments in 2002, according to VSI statistics. VSI emphasizes proper installation and materials estimation through training, manuals, and videos to reduce the amount of scrap generated during the construction and renovation process. According to “Vinyl Siding Recycling: A How-to Guide,” about 6 percent of that material becomes installation scrap; this equates to about 108 million pounds—or 54,000 tons—available for recycling or disposal. Some portion of this is recycled, but VSI does not have statistics. Compared to the 230 million tons of municipal solid waste—or 135 million tons of building-related construction and demolition wastes, according to the 1998 EPA report—generated annually, 54,000 tons is a very minor amount of material to manage for recycling and/or disposal.

As a member company of the Uni-Bell PVC Pipe Association, National Pipe & Plastics, Inc., has adopted a policy to accept our own clean PVC pipe (including DWV)products back from end users for recycling and/or reprocessing at our manufacturing facilities. Additionally, National has an on-going, long-term program in place to recycle and re-process all of our own in-house PVC recyclable materials generated from our manufacturing process.

As a member of the Uni-Bell PVC Pipe Association, Ipex is dedicated to the manufacturing of safe and reliable PVC pipe systems. Through a comprehensive long-term program, Ipex is dedicated to the recycling and reprocessing of its in-house recyclable PVC material generated by its manufacturing processes.

Ipex will also accept the return of its own PVC products by end-users, for recycling and/or reprocessing at its manufacturing locations.

Michel Cadotte-Ipex Inc.

Disposal practices: As a representitive for the Plastic Pipe and Fitting Association I offer the following. For installation of pipe products in general, pipe scrap is very small. Unlike other building products, pipes can be cut to fit and used as pipe somewhere in the total structure, or on the next project. This practice minimizes the cost and waste for the builder. It is not likely for much household type DWV pipe to be 'abandoned in place', because most built up areas that involve structure tear-downs involve new construction on the same parcel. It is currently unlikely that a large quantity of any pipes would be incinerated or recycled because it would be a very small percentage of the overall building debris and, as such, it would be land filled. While scrap and old PVC pipes can be and have been recycled into new PVC pipes, this is currently limited by the economics of sorting, collecting and transporting the waste. Do to the shear weight, bulk and hazard of sorting demolished building waste, debris would likely be placed into a large scale dumpster and carted off as general landfill type waste. As of today, it is still very unlikely to be sorted.

Vinyl, as a thermoplastic, is an inherently recyclable material. Overall, more than 99 percent of all manufactured vinyl compound ends up in a finished product, due to widespread post-industrial recycling. (Post-Industrial and Post-Consumer Vinyl Reclaim: Material Flow and Uses in North America, Principia Partners, a final report to the Chlor-Vinyl Campaign, December 1998). The Vinyl Institute (VI) has long supported and promoted the recycling of vinyl building products. VI maintains a database of vinyl recyclers on our website at http://www.vinylinfo.com/database/vinyldata2/index.html In addition VI has a very experienced staff person devoted to facilitating recycling of vinyl products by working with recyclers and vinyl product manufacturers to help recycle vinyl products. Several years ago VI funded the development of optical sorters for identifying plastic materials in mixed plastic waste. Currently, VI is partnering with WasteCap Wisconsin on the recycling of vinyl siding scrap from residential construction. Attached is a description of WasteCap's project. The goal of this project is to help develop economically and environmentally efficient ways to recycle vinyl siding scrap at residential developments. Scrap from siding in manufactured housing, which is done at concentrated locations, is routinely recycled.

In considering information on disposal of vinyl building products at the end of their service life, the Task Group should consider the fact that vinyl siding, windows and pipe are new products relative to their expected service life. Relatively little vinyl building products have met the end of their service life and are available for recycling. This fact limits the economic and environmental efficiency of vinyl building product recycling at this time. I will post some VI information on disposal of siding and windows.

Vinyl building products that are disposed of at the end of their useful life are predominantly landfilled according to the US EPA (Franklin Associates study) cited by VSI above. Very little appears to be incinerated.

On behalf of the Resilient Floor Covering Institute the following comments are submitted:

There are no national recycling programs (end of life programs) available for cork flooring, linoleum, vinyl composition floor tile and sheet vinyl flooring. Some vinyl flooring manufacturers do provide for the return of scrap material from installations to a floor manufacturing facility. No national recycling programs for the four flooring materials included in the TSAC draft report have been established because of the manner in which these floors are installed. With the typical full spread adhesive installation, any floor that was removed in scrap pieces would include residue/materials from both the subfloor and adhesive and thus be unsuitable for use in a recycling program.

Typically the disposal of all four types of floors is the same. After removal it is estimated that 90% of the floors would be sent to landfill and 10% sent to a municipal waste combustion facility. For residential removals, the percentage of material being sent to a municipal waste combustion facility may be somewhat higher if the floor was removed by a homeowner and discarded as household waste.

Royal Pipe Systems is a member of the Uni-Bell PVC Pipe Association and as such is dedicated to the manufacturing of safe and reliable PVC pipe systems. Our company has implemented a long-term program dedicated to the recycling and reprocessing of all our in-house recyclable PVC material generated from our manufacturing processes.

Furthermore, Royal Pipe Systems will accept the return of its own PVC products, when sent by end-users, for recycling and/or reprocessing at its manufacturing locations.

Disposal Practices

For each material, what proportion is disposed of by incineration and by landfilling, and what

proportion is recycled? National trends are of interest, as opposed to state or locality-specific data.

Windows: vinyl, aluminum, wood.

• Very few, if any vinyl windows are incinerated; all are likely landfilled

• Because the oldest vinyl windows in the U.S. are approaching 20 years, the number of vinyl windows removed is very small

• This small volume does not justify the investment in the equipment to separate glass and non-rigids for recycle

• An AAMA Task Group has been commissioned to determine the volume of vinyl windows landfilled vs wood and aluminum

• Wood windows removed from service are typically burned on site, incinerated or landfilled

• Aluminum is likely the most recycled window framing material (I will contact AEC for possible data)

For Example how much scrap is generated when the product is installed and what happens to that?

· With the exception of very, very minor trimming of a nail fin, zero scrap is generated during vinyl window installation

· Similarly, there is very little, if any scrap generated by wood and aluminum windows.

Then how much product has reached the end of its useful life currently and what happens to that?

· In the U.S. a very small percentage (<1%) of vinyl windows have reached the end of their service life.

· When they are removed from service, the disposal scenario described above applies