Recycled Content of Steel from Multiple Suppliers

Jerry, I would contact GBCI directly for an explanation of these two comments. Although it can take them a few weeks, I have had luck getting reviewers to provide minor clarifications to review requirements that are confusing, as these are.

BULL MOOSE TUBING First, use of averages has always been acceptable for claims made. Forcing use of minimums is something new. When I get a claim with a wide range of content values I do use the minimum. Otherwise, average. Bull Moose Tubing provides a recycled content claims letter that you have to analyze to get a useful result. The first thing to note in their letter is the reference to "Steel Recycling Institute" (SRI) study. Bull Moose quotes BOF and EAF recycled content from the study. It is best to use the actual study and rather than the values quoted by Bull Moose. That way you can prove you documented the claim based on the same study used. Bull Moose creates confusion by doing confusing math: BOF = 31.7% Total Recycled Content --Post-Consumer Recycled Content = 65% --Pre-Consumer Recycled Content = 35% For EAF they provide the same total and breakdown. The recycled content total is not 100% (65% + 35%), it is 31.7%. The correct breakdowns are: --Post-Consumer Recycled Content = 65% x 31.7% = 20.6% --Pre-Consumer Recycled Content = 35% x 31.7% = 11.1% Bull Moose Tubing also provides a breakdown of percentage of BOF and EAF materials used at each of their four plants. You can average the BOF and EAF values to get an overall Bull Moose Tubing value. Now, multiple the BOF Plant average by the Pre- and Post- consumer recycled content claims for BOF and you get the Bull Moose BOF contributions. Do the same for EAF. Add BOF + EAF and the end result is the overall Recycled Content claim for Bull Moose based on the percentage of BOF and EAF processes, using the SRI study values. For Bull Moose I ended up with the following results: --Post-Consumer Recycled Content = 13.5% BOF x 20.0% EAF = 33.5% --Pre-Consumer Recycled Content = 7.2% BOF x 13.4% EAF = 20.6%

STEEL DYNAMICS This company provides a very good recycled content letter. It is one of the few I get that references FTC 16 CFR 260 as the claim method, and separately accounts for "home" scrap. Steel Dynamics claims are, based on a letter dated May 16, 2008: --Post-Consumer Recycled Content = 75 - 84% --Pre-Consumer Recycled Content = 10 - 15% The above supports the claim you made for Steel Dynamics. The problem is likely with the claim letter you provided. Contact Douglas A Rees-Evans, Manager of Technical Services at Steel Dynamics, for the letter he wrote that references the above claims made.