02/12/2004 03/12/2004 06/08/2004

Also, the replacement schedule needs to be clear. It is ambiguous whether this means we must replace all Ā½ā€¯ X 1/32ā€¯ by 2008, or does it mean we can keep in service those Ā½ā€¯ X 1/32ā€¯ shredders purchased before XX/XX/XX until they can no longer be repaired or produce those results. There is a significant difference.]]> Also, the replacement schedule needs to be clear. It is ambiguous whether this means we must replace all Ā½ā€¯ X 1/32ā€¯ by 2008, or does it mean we can keep in service those Ā½ā€¯ X 1/32ā€¯ shredders purchased before XX/XX/XX until they can no longer be repaired or produce those results. There is a significant difference.]]>

Paragraph c (2)(b), which requires replacement by December 31, 2008, of all shredders grandfathered under previous requirements, should be eliminated. Most crosscut shredders that meet current destruction requirements are well-built and will likely last much longer than the end of calendar year 2008, if given proper care. The cost of a small office shredder that meets current residue output requirements is often more than $2,000, with higher-capacity shredders proportionately more expensive. Shredders that meet the requirements proposed in the page change will likely be even more expensive. For example, at present replacement values it would take approximately $10,000 to replace the three shredders in the Oak Ridge Operations Office Federal Building alone. Insofar as implementation of this page change could hamper the Department's ability to perform economically, we recommend that shredders that continue to meet current residue output requirements be permitted to remain in use until they become unserviceable.

The purchase date specified in paragraph c (2) should be consistent with the final implementation date of the page change. ]]>