Degradable Additives - What Do You Think?

Below is a policy position statement against the use of degradable
additives. Please let us know what you think? Agree, disagree, not sure...?

DEGRADABLE ADDITIVES – DRAFT POLICY POSITION

BACKGROUND:

There are two categories of materials generally comprised under the
broader term "degradable plastics." The first category includes
bio-based resins, those derived from plant materials such as corn, e.g.,
polylactic acid (PLA) containers. The second includes fossil fuel-based
resins, such as PET or PP, to which degradable additives are added in
order to promote degradation of the resulting package. The statements
and position statement below address only the second of these
categories.[i] <#_edn1>

* * * * *

WHEREAS, new Federal Trade Commission draft guidelines for environmental
marketing claims ("Green Guides") call for products labeled as
"biodegradable" to decompose within a relatively short period of
time.[ii] <#_edn2>

WHEREAS, landfills "entomb" their contents to some degree, but
are nonetheless estimated to be the third-largest source of
human-related methane emissions in the United States; out of 2,300
currently operating or recently closed MSW landfills, only about 510
have landfill gas utilization projects in place; the Environmental
Protection Agency (EPA) estimates that recovery is viable at an
additional 510 sites.[iii] <#_edn3>

WHEREAS, degradation contributes to GHG emissions, whether occurring in
landfills or elsewhere. A recent North Carolina State University study
concluded that the more rapid rate of degradation sought through
degradable additives may exacerbate methane emissions, based on the fact
that many potential methane collection programs are not yet in place, as
mentioned above.[iv] <#_edn4>

WHEREAS, degradation squanders the value of the energy inherent in a
plastic package that would be captured through recycling and
re-converting to a new end-use application.

WHEREAS, degradation provides no nutrient value to the environment in
which it decomposes.

WHEREAS, degradation solves no solid waste management problems,
including litter, since degradation does not necessarily happen quickly
or reliably in likely end-of-life environments, even for products
containing degradable additives. [v] <#_edn5>

WHEREAS, the U.S. recycling infrastructure is robust and continues to
grow: over 1,440 million pounds of postconsumer PET and 981 million
pounds of postconsumer HDPE were recycled in 2009.[vi] <#_edn6>

WHEREAS, degradable additives potentially endanger post consumer plastic
recycling since it remains unclear how these additives might affect the
many next-life products made from recycled materials in terms of
quality, performance, safety, and lifespan.

WHEREAS, data from degradable additive manufacturers has been limited in
its scope, not affording the various concerned constituencies –
whether recyclers, municipalities, manufacturers, etc. – a full
understanding of the potential risk to plastics recycling.

WHEREAS, the recycling industry trade organization, the Association of
Postconsumer Plastic Recyclers (APR), has published a PET Recycling
Compatibility Guidance Protocol for degradable additives; the APR
reports having received very limited data to date. [vii] <#_edn7>

WHEREAS, a variety of diverse organizations have either discouraged use
of degradable additives until more data is forthcoming, or urged prudent
consideration of the environmental harm/benefit ratio. [viii] <#_edn8>

THEREFORE, because the environmental benefit of degradable additives is
at best unclear, as is their potential effect on plastics recycling, the
(Group Name) opposes the use of degradable additives in plastic
packaging at this time.

[i] <#_ednref> Degradable additives are typically added to standard
plastic resins at between one and five percent in order to facilitate
degradation. Triggered by light, heat, or flexing, degradable additives
use either a chemical – or catalytic – process, or a
non-catalytic, biological process to foster degradation. The time to
degradation can vary considerably; plastic molecules are converted to
carbon dioxide, methane, and water.

[ii] <#_ednref> A summary of the Guides:
http://www.ftc.gov/os/2010/10/101006greenguidesproposal.pdf
<http://www.ftc.gov/os/2010/10/101006greenguidesproposal.pdf>

More information at, http://www.ftc.gov/opa/reporter/greengds.shtm
<http://www.ftc.gov/opa/reporter/greengds.shtm>

[iii] <#_ednref> From the EPA's Landfill Methane Outreach Program
(LMOP), http://www.epa.gov/lmop/basic-info/
<http://www.epa.gov/lmop/basic-info/>

[iv] <#_ednref> Dr. Morton Barlaz, N. Carolina State University study
(5/27/11),
http://news.ncsu.edu/releases/wms-barlaz-biodegradable/
<http://news.ncsu.edu/releases/wms-barlaz-biodegradable/>

http://pubs.acs.org/doi/abs/10.1021/es200721s
<http://pubs.acs.org/doi/abs/10.1021/es200721s>

[v] <#_ednref> NSF study (Feb. 2011),
http://www.bpiworld.org/BPI-Public/News/Article.html?mode=PostView&bmi=5\
13259
<http://www.bpiworld.org/BPI-Public/News/Article.html?mode=PostView&bmi=\
513259>

[vi] <#_ednref> Based on published recycling rate report, PET:
http://www.napcor.com/PET/pet_reports.html
<http://www.napcor.com/PET/pet_reports.html>
HDPE:
http://www.americanchemistry.com/Media/PressReleasesTranscripts/RelatedP\
DF/PDF-2009-United-States-National-Post-Consumer-Plastics-Bottle-Recycli\
ng-Report.pdf
<http://www.americanchemistry.com/Media/PressReleasesTranscripts/Related\
PDF/PDF-2009-United-States-National-Post-Consumer-Plastics-Bottle-Recycl\
ing-Report.pdf>

[vii] <#_ednref> Available on the APR web site,
http://www.plasticsrecycling.org/technical-resources/testing/degradable-\
additives-testing-for-pet
<http://www.plasticsrecycling.org/technical-resources/testing/degradable\
-additives-testing-for-pet>

[viii] <#_ednref> NAPCOR:
http://www.napcor.com/pdf/NAPCOR_DegradblAdds2FINAL.pdf
<http://www.napcor.com/pdf/NAPCOR_DegradblAdds2FINAL.pdf>

APR:
http://www.plasticsrecycling.org/images/stories/doc/DegradableAdditivesS\
tatement120308.pdf
<http://www.plasticsrecycling.org/images/stories/doc/DegradableAdditives\
Statement120308.pdf>

EPA: http://www.epa.gov/osw/wycd/catbook/debate.htm
<http://www.epa.gov/osw/wycd/catbook/debate.htm>