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On April 7, 2020, the U.S. Environmental Protection Agency (EPA) published a notice in the Federal Register requesting comments on federal procurement guidelines that designate products that are or can be produced with “recovered materials” and set forth recommended practices for purchasing such items. Recovered materials are those waste materials that have been recovered or diverted from the solid waste stream. The procurement guidelines are required under section 6002 of the Resource Conservation and Recovery Act (RCRA), which established the “buy recycled” program to use Federal purchasing power to stimulate the demand for products made with recovered materials. Federal agencies, as well as state and local agencies and government contractors, that use appropriated funds to purchase $10,000 or more of designated items are required to purchase items containing recovered materials to the fullest extent possible.

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Photo of Robert Burton Robert Burton

Robert A. Burton is a partner with Crowell & Moring’s Government Contracts Group in the firm’s Washington, D.C. office. He is a nationally-recognized federal procurement attorney, an expert witness on government contracts issues in federal court and arbitration proceedings, and a leader who…

Robert A. Burton is a partner with Crowell & Moring’s Government Contracts Group in the firm’s Washington, D.C. office. He is a nationally-recognized federal procurement attorney, an expert witness on government contracts issues in federal court and arbitration proceedings, and a leader who assists government contractors with navigating the complex and rule-driven procurement process. He represents a wide range of companies that conduct business with the federal government, from large defense contractors and systems integrators to small businesses.

Photo of Elliott Laws Elliott Laws

Elliott Laws is a partner in the Washington, D.C. office of Crowell & Moring where he is co-chair of the firm’s Environment & Natural Resources Group and is a member of the Government Affairs Group. He provides strategic counseling and legal, policy and…

Elliott Laws is a partner in the Washington, D.C. office of Crowell & Moring where he is co-chair of the firm’s Environment & Natural Resources Group and is a member of the Government Affairs Group. He provides strategic counseling and legal, policy and crisis management advice on environmental and energy policy issues, regulation and litigation, addressing Superfund and Hazardous Wastes; Brownfields Redevelopment; Environmental Remediation; Chemical Regulation; Clean Air; and Clean Water. Elliott is frequently sought for advice regarding site specific, as well as, general issues faced by major corporations in the environmental regulatory and policy areas, as well as internal corporate and operational environmental management matters. With his deep environmental experience, he is able to help guide these clients through complex negotiations and development of innovative resolutions at the highest levels of the federal government.

Photo of Jennifer Giblin Jennifer Giblin

Jennifer Giblin is a senior counsel in Crowell & Moring’s Washington, D.C. office and is a member of the firm’s Environment & Natural Resources Group. Her practice focuses on compliance counseling under federal and state environmental laws and management of environmental risks in…

Jennifer Giblin is a senior counsel in Crowell & Moring’s Washington, D.C. office and is a member of the firm’s Environment & Natural Resources Group. Her practice focuses on compliance counseling under federal and state environmental laws and management of environmental risks in business and real estate transactions. Jennifer also advises clients regarding the transportation of hazardous materials and dangerous goods under U.S. and international regulations and standards.

Jennifer’s environmental compliance counseling practice includes solid, hazardous, and radioactive waste identification, management, and disposal issues under the Resource Conservation and Recovery Act (RCRA); spill reporting and site remediation obligations under federal and state laws, including RCRA, the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)(also known as Superfund), and state voluntary cleanup and Brownfields programs; and, permitting issues under the Clean Water Act and the Clean Air Act. Jennifer also helps clients develop and implement corporate compliance programs, including environmental auditing, record retention, and training components, and defends clients against administrative investigations and enforcement actions.