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Observations/Relevant Findings

Final Report to Congress on the Joint Resolution to Establish a National Policy on Permanent Papers

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Environmental issues

During the 5-year period covered by Pub. L. 101-423, a number of pertinent events have occurred. First, the trend has continued in the paper industry to convert mills from acid to alkaline papermaking. This conversion can be attributed primarily to EPA regulations 40 CFR 430 - "Pulp, Paper, and Paperboard Point Source Category" that govern the amount and kinds of effluent that paper mills can discharge (Federal Register, 1993). Once conversion was underway, the lower cost of raw materials for alkaline papermaking made the change a profitable one.

A second development within the monitoring period was the issuance of Executive Order 12873, "Federal Acquisition, Recycling, and Waste Prevention." This order followed a number of earlier EPA regulations, the most significant of which was the "Guideline for Federal Procurement of Paper and Paper Products Containing Recovered Materials" that was published in the Federal Register (Vol. 53, No. 120) on June 22, 1988. EO 12873 addresses recycling in general and places some very specific requirements on Government purchasers of paper. Section 504 sets minimum content standards for postconsumer recovered materials in printing and writing papers, with a 20 percent requirement as of December 31, 1994, and 30 percent as of December 31, 1998 (for most of these papers), which have been incorporated as a basic requirement in Government Paper Specification Standards (No. 10).

Section 505 directs agencies to revise or eliminate sections of standards or specifications that contain brightness or other specific pulp requirements if these requirements are not needed for a particular grade of paper to be functional. These two requirements appear to conflict with the policy set out in Pub. L. 101-423. However, the Federal Environmental Executive in a July 19, 1994, letter to the Director of the New York Public Library (Appendix 7) stated that all agency environmental executives would be notified that "the requirements for use of recycled paper are not to conflict in any way with the concurrent requirement for permanent paper use." Thus, provided that the requirements for permanent paper are met, any amount of postconsumer recovered material can be incorporated.

The purpose of section 505 is to eliminate unnecessary requirements for paper that result in the production of harmful byproducts such as dioxins. Dioxin is of particular concern because it has been shown to be a byproduct of papermaking when pulp is bleached with elemental chlorine (chlorine gas). For those not versed in industry technology or recent research, section 505 might appear to eliminate the purchase of bleached paper. This interpretation is erroneous for two reasons.

First, in the absence of research that provides other options, fully bleached pulp is a necessary component of permanent paper at this time. Bleaching removes the lignin from the pulp, which is necessary for permanence because lignin-containing papers have been shown to darken with age and light exposure. Librarians, archivists, and records managers are concerned that such discoloration could impede future reformatting procedures. Thus, the requirement that permanent paper be fully bleached cannot be eliminated because it is directly related to its long-term performance.

Second, the paper industry is gradually using more elemental chlorine-free (ECF) bleaching, with the result that the dioxin levels in fish near pulp and paper mills have been dropping (McDonough, Proceedings of the Fourth China Paper Technical Conference, 1995). Data show that by the end of 1994 ECF and TCF (totally chlorine-free) bleached pulps comprised about 54 percent of the bleached pulp produced. Of that 54 percent, 85 percent (about 20 million tons) was ECF pulp. However, when pulp is ECF bleached, the process is not totally free of chlorine. Most manufacturers are using chlorine dioxide instead of elemental chlorine. Despite this continued presence of chlorine, the dioxin levels decline. This leads many U.S. producers to question the need to go "totally chorine-free." Another factor in their reluctance is the cost. Currently, virtually all TCF production is in Europe. The one U.S. producer, Louisiana Pacific at Samoa, California, has met with weak demand for its pulp. For this reason, North American producers believe that the market is unwilling to pay more for TCF pulps (McDonough, Tappi Journal, 1995).

The effect of recycling on paper performance and longevity was the topic of the September 28, 1994, meeting of the NARA Advisory Committee on Preservation. The meeting included representatives from several Federal agencies as well as standards and testing professional organizations, librarians, paper manufacturers and associations, and other interested organizations. Most representatives agreed that it is possible to produce paper that contains postconsumer waste while satisfying permanent paper specifications; however, it will not be easy or inexpensive. The postconsumer wastepaper supply eventually will contain paper that has been previously recycled perhaps for the third or fourth time. Several participants predicted that after a period of time recycled paper containing postconsumer waste will fail the strength requirements for permanent paper.

Three manufacturing practices contribute to the weakness of recycled paper containing postconsumer waste: (1) repulping paper fibers reduces the length of fibers and thus decreases the strength of paper; (2) drying and rewetting pulp for re-shipment between recyclers and manufacturers reduces bonding strength among fibers; and (3) removing groundwood and lignin exacerbates the reduction of fiber and bonding strength even further. A change of these practices may help manufacturers produce more long lasting paper containing a high proportion of recycled fiber content, but the consumer must tolerate a less bright sheet of paper and a degree of eventual yellowing. As discussed elsewhere in this report, the American Society for Testing and Materials and the paper research institutions of Canada are researching these concerns.

During 1994, a paper made by an alkaline process, but containing a high percentage of groundwood, entered the Federal marketplace. This grayish paper, natural shade recycled plain copier xerographic paper (JCP O-70), was being used widely in copiers and laser printers, and, as a result, it was used to create some permanent records. Concern was first expressed about the paper in a "Meeting on Groundwood Paper in Federal Offices," sponsored by the Office of the Federal Environmental Executive on October 11, 1994.

The meeting discussed primarily how JCP O-70 would recycle when entering the waste stream (a topic outside the scope of this report), but concerns regarding the longevity of this paper were raised. In direct answer to these concerns, the USDA Forest Products Laboratory presented results of research done on this paper. They studied the optical and physical properties of three different paper mixes which they recycled.

The control mix was a fully-bleached paper which contained 50 percent recycled content, of which 10 percent was postconsumer fiber. The second paper was the grayish paper under discussion at the meeting, which had 100 percent recycled content, of which 50 percent was postconsumer fiber. The third was a 50/50 mixture of these two papers. The 50/50 mixture was studied to demonstrate what would happen when the higher percentage postconsumer fiber content became mixed with the white office paper and recycled.

This study showed, as might be expected, that the strength properties of the 50/50 mix paper were midway between those of the two papers from which it was made. However, the optical properties of the mixed paper were much closer to, not midway between, the properties of the 50 percent postconsumer fiber paper. Thus, they concluded that the introduction of a higher percentage postconsumer fiber paper into a recycling mix would "degrade both the physical strength and brightness of the final product" (Abubaker & Cropsey, n.d.). This could be overcome, of course, by adding stronger fiber, and additional bleaching steps, both of which appear counter to the intended purposes of the Executive Order.

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