Volume 20, Number 7
Dec 1996

Final Report to Congress on the Joint Resolution to Establish a National Policy on Permanent Papers
Part 2

Part 1 of this abridged transcription appeared in the September issue of the Abbey Newsletter. All the appendices and the first three of the tables in the original text have been omitted, along with some of the passages that refer to government forms and regulations.

The document does not bear a date or publisher, but it was supposedly issued in December 1995 by the Librarian of Congress, the Archivist of the United States, and the Public Printer. The National Archives can supply copies on request. Contact Bonnie Rose Curtin in the Office of Records Administration (301/713-7100).

Observations/Relevant Findings

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.⁵ 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."… 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).…

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.⁶…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 chlorine-free." Another factor in their reluctance is the cost [as well as a weak demand].…

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."⁸ 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.

Continuing changes in technology

Although the trend towards elemental chlorine-free (ECF) bleaching poses no problems to the production of permanent paper, other new technologies may. Driven by the rising cost of pulp, manufacturers are looking towards thermomechanical and chemithermomechanical pulping processes to increase yield and lower costs. At least for the short term, these new pulping processes pose a threat to the legibility of books and documents because much of the original lignin remains in the pulp, even after bleaching. The lignin causes the resulting papers to darken upon artificial aging by light or heat. Such discoloration is unacceptable in a paper used for printing or writing that is to be retained indefinitely.

With this knowledge, manufacturers of these pulps are researching additives that will prevent the pulps from darkening. This work is still in the research stage, but no doubt in the next few years chemicals will be found which, when added to these pulps, retard the color change. Some of the compounds currently under investigation are sulfur-containing, which could pose a problem to photographic records. The presence of increased amounts of reducible sulfur are excluded by some box and board specifications, but are not currently addressed in the existing specifications for permanent paper.

Cost issues

Both prior to and since enactment of Pub. L. 101-423 in October 1990, a challenge to its full implementation has been encountered because of the high cost of paper that meets the specifications of JCP A270 (uncoated permanent book)-the only permanent paper available through GPO prior to Government Paper Specification Standards (No. 10). Federal consumers argued that it could not be used as the prime paper for documents of enduring value because its high cost made it economically unfeasible, particularly if multiple copies were required. During consideration of the legislation, the cost of JCP A270 was estimated to be 30 percent above that of offset book paper (JCP A60), the predominant paper used in Government printing, regardless of whether JCP A60 was manufactured by an acidic or an alkaline process. In fact, investigation of GPO paper catalog prices of the time reveals that, for the quarter February through April 1989, A270 was 187 percent more expensive than A60.… Despite the general rise in paper prices during 1994 and 1995, the price differential between A270 and A60 had narrowed somewhat. The prices that GPO charged agencies during the first three quarters of 1995 are shown in Table 5.

…The monitoring agencies reaffirm their recommendation that, as stated in NARA Bulletin 95-7:

Federal agencies are advised to procure either permanent or alkaline paper grades when creating all federal records. Permanent paper is recommended for routine use in offices that create and file a high proportion of long-term and permanent records, whereas alkaline paper is recommended for routine use throughout agencies for all other documents.

This is in keeping with the intent of Executive Order 12873 ("Federal Acquisition, Recycling, and Waste Prevention," October 20, 1993) and Environmental Protection Agency (EPA) guidance. The bulletin also states that any paper is suitable for mass production as long as a record copy is produced on permanent or alkaline paper, microform, or electronic medium.

Availability and use

Procurement of blank paper. …Most paper suppliers do not, as a common practice, label their paper products. Thus, the consumer cannot identify them as alkaline, permanent, or acidic. Therefore, when Federal employees procure paper from sources other than GPO or GSA, in most cases they do not know the degree of permanence of the paper they are procuring. The monitoring agencies propose to continue working with JCP, GSA, and paper suppliers to develop common labeling practices, and to encourage GSA to continue their marketing efforts to promote procurement of paper through GSA's Federal Supply Service.

SF-1 and decentralized printing. Sections 501 and 502, title 44, U.S.C., state that:

All printing, binding, and blank-book work for Congress, the Executive Office, the Judiciary, other than the Supreme Court of the United States, and every executive department, independent office and establishment of the Government, shall be done at the Government Printing Office … unless approved by the Joint Committee on Printing.

Since a large amount of printing service is obtained through GPO, Standard Form 1, GPO Requisition for Printing and Binding, will include blocks indicating alkaline or permanent paper requirements when next revised. Once an agency indicates permanent or alkaline paper on the printing requisition, GPO or their contractors must comply with the request.…

Use of appropriate paper in agencies. …NARA statistics indicate that 3 percent to 5 percent of the records created by an agency are permanent. The majority of permanent records are created within a few distinct agency offices, usually policy-making offices. Because it is sometimes difficult at the time of creation to determine whether a document is permanent or temporary, the NARA Bulletin 95-7 recommends that permanent paper should be used routinely in offices that create a large majority of permanent records. Other offices should use alkaline papers as a normal practice. Permanent papers will last for several hundred years under normal conditions of storage and use and alkaline paper will last at least 100 years. These time frames are much longer than those associated with the longevity of acidic papers.…

Conclusion

…Even as we enter the electronic age on our way into the 21st century, the legacy of acidic paper from the 19th century still threatens the survival of our cultural heritage, and efforts to preserve existing collections still exceed the $100 million dollar cost Senator Pell cited [when he brought Sen. Joint Res. 57 to a vote in 1990]. The production and use of alkaline and permanent papers on a worldwide basis is the only sure way of stemming the tide of brittle paper records flooding government offices, libraries, and archives of this Nation.

Although much has been accomplished since Pub. L. 101-423 was signed in October 1990, important work remains to be done. For example, GPO's Standard Form 1, Printing and Binding Requisition, should be revised to enable designation of an alkaline option on agency printing requests. Also, appropriate labeling by paper suppliers of alkaline and permanent papers should be assured; continuing education programs about the use of permanent paper should be developed; and information about the procurement of alkaline and permanent papers should be distributed. Further, LC and NARA will continue to contribute to the important research being conducted by ASTM and will ensure that it is observed closely and reported widely.

Thus, although this report marks the end of our responsibilities as set forth in Pub. L. 101-423, the Librarian of Congress, Archivist of the United States, and the Public Printer agree to continue, on an ad hoc basis, monitoring the progress of the Government's permanent paper policy.

⁵Proposed improvements to these regulations appear in the Federal Register, V. 58, No. 241 (December 17, 1993), under the authority of sections 301, 304, 306-308, and 501 of the Clean Water Act and 33 U.S.C. sections 1311, 1314, 1316, 1317, and 1361. The proposal identifies and describes previous studies and guidance that helped to propel mill conversion.

⁶McDonough, T.J., Proceedings of the Fourth China Paper Technical Conference, TAPPI PRESS, Atlanta. 1995.

⁸"A Comparison of Upcycled and Recycled Paper," S. Abubakr and K. Cropsey (USDA Forest Products Laboratory, Madison, WI), presented at the "Meeting on Groundwood Paper in Federal Offices" Oct. 11, 1994.