Werner Braun: Carpet industry offers input to congressional committee

— Recently, Rep. Darrell Issa, R-Calif., the chairman of the House Committee on Oversight and Government Reform in Washington, asked many of us involved with manufacturing to provide him with information on existing and proposed regulations that we see as threatening job creation and the overall economy.

I was more than happy to share my thoughts on the subject, especially since the carpet industry is among the most progressive in the country in terms of addressing the environmental and sustainability challenges that are associated with manufacturing.

The mission that Chairman Issa’s committee is charged with is to determine the negative impact that overly aggressive government regulation has on the creation of jobs and the impact over-regulation has on American companies’ ability to be economically viable and to create a good economic future for this country.

We feel that carpet manufacturers have voluntarily made major strides in reducing the environmental footprint of carpet through reduced landfill use, as well as lowered carbon dioxide emissions, energy consumption, waste generation, water usage and hazardous air emissions.

As an example of our voluntary stewardship, we’ve reduced by 50 percent the amount of water used in carpet production today, and we’ve reduced the draw on the river by reusing “grey water” in our industrial settings. Grey water is water that has already been used in manufacturing, and by recycling and reusing it, we are able to decrease the demand on fresh drinking water.

That’s one reason we become concerned when government agencies such as the Environmental Protection Agency (EPA) put mandatory regulations in place that threaten to negatively impact the growth of our industry.

The EPA is looking into creating stringent water usage regulations, especially around grey water. We believe, however, that the regulation of grey water is best left to the states where private industry and the states can work together to meet their joint water resource needs rather than reacting to a national mandate.

It’s almost as if the EPA wants to punish the innocent. We’re already doing much of what they envision voluntarily, and we don’t see why additional regulations are necessary or would be economically sound.

Another related issue that we find disturbing is the EPA’s proposed Extended Producer Responsibility (EPR) legislation, which would mandate product stewardship programs and place the cost burden of end-of-life products on the producer.

For example, if your company is the producer of “widgets,” this “framework legislation” would hold your company liable for taking that widget back at the end of its life cycle.

The Carpet and Rug Institute believes that government-mandated EPR programs could stifle product innovation, increase manufacturing costs, and put the onus on the states to pay for compliance and enforcement. The key to product stewardship is the promotion of market-based solutions, particularly for products like carpet that do not pose a toxic threat to human health or the environment.

In this effort, once again, the carpet industry is ahead of the curve. We have already been working with private industries to create solutions to the waste associated with end-of-life carpet products; case in point, the creation in 2002 of CARE, the Carpet America Recovery Effort. During the past decade, through CARE, we have diverted 2.5 billion pounds of carpet waste from landfills, and we expect that this recovery effort will grow exponentially over time.

At a time when the manufacturing sector of our economy is struggling to compete in the global marketplace, we hope Congress will resist the push to legislate a cradle-to-grave responsibility for all product suppliers.

Our written response to Chairman Issa’s request includes our concerns about other issues as well. We are, for example, concerned about the possible mandated use of “green” cleaning products, which are considered to be “environmentally friendly,” but which do not necessarily work effectively and can, in some cases, have a detrimental effect on the products they are designed to clean.

Our concern is that such programs as the EPA’s Design for the Environment will not only become mandatory, but also that the certification will broaden its reach into our industry, which may result in product de-selection among uninformed consumers.

Proposed regulations on coal fly ash, used in carpet backing, also concern us as we believe that this is an issue that should be left up to the states. We believe that energy, a major feedstock in the production of carpet, needs to recognize that coal and natural gas are major contributors to our energy supply, and that efforts to put stricter controls on the use of fossil fuels will result in higher production costs, negatively impacting all kinds of industries and likely raising consumer prices.

These are just a handful of concerns that we have shared with Congressman Issa. We fervently hope that, in the future, we may see some tangible reductions in over-regulation and federal mandates.

Werner Braun is president of the Dalton-based Carpet and Rug Institute.

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Werner Braun: Carpet industry offers input to congressional committee

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