Ms. Jill Scarborough,
Florida Dept. of Environmental Protection,
3900 Commonwealth Bvd.,
Tallahassee,
Florida 32399-3000
Jill.R.Scarborough@dep.state.fl.us
17th February 2010
Symphony Environmental
Technologies Plc
Elstree House, Elstree Way
Borehamwood
Hertfordshire WD6 1LE
England
+44 (0)20 8207 5900 Telephone
+44 (0)20 8207 5960 Facsimile
+44 (0)7917 796444 Mobile
www.degradable.net
dc@d2w.net
Dear Ms. Scarborough,
COMMENTS ON FLORIDA RETAIL BAG REPORT 1ST FEBRUARY 2010
For the reasons explained at http://www.biodeg.org/position-papers/Plastic-bagbans/?domain=biodeg.org we do not think that plastic bag bans are a good idea
There is a failure throughout the Report to distinguish between biodegradable and
compostable plastics.
Our comments on specific issues are in italics as follows:
Page 1
While plastic bags may appear to be the major problem, the solution is not to switch to
paper. [we agree]
Life cycle analyses show a higher level of environmental harm from manufacturing to
disposal of paper compared to plastic bags [we agree, and the same is true of
compostable plastic bags. In June 2009 Germany’s Institute for Energy and
Environmental Research concluded that oil-based plastics, especially if recycled, have
a better Life-cycle Analysis than compostable plastics.
http://www.kunststoffverpackungen.de/en/news/LCA%20waste%20bags%20%20Study%20Extract%20B.pdf) They added that “The current bags made from
bioplastics have less favourable environmental impact profiles than the other materials
examined” and that this is due to the process of raw-material production.” See
http://www.biodeg.org/files/uploaded/biodeg/Hydrobiodegradable_Plastic_Production_Process.pdf
Page 1
A switch to biodegradable or compostable bags is not the answer either. Since Florida
has no solid waste commercial scale composting facility to handle these bags, they
would end up in a landfill just like paper or plastic bags.
[we agree that a switch to compostable bags is not the answer. They are up to 400%
more expensive, they are thicker and heavier
(http://www.biodeg.org/files/uploaded/biodeg/Oxo_vs_Hydro-biodegradable.pdf),
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they would not readily degrade if they found their way into the open environment, they
emit methane deep in landfill, and they compete for land and water resources with food
production (see http://www.biodeg.org/positionpapers/comparison/?domain=biodeg.org
The packaging manager of Tesco (Britain’s largest supermarket) said on 20th October
2009 that the supermarket “does not see the value in packaging that can only be
industrially composted” and that “local authorities do not want to touch it, as it can
contaminate existing recycling schemes.” A few days earlier, Tesco’s head of waste
and recycling had told a conference that the supermarket group was “not taking
compostable packaging any further.”
However, we disagree with the Report in the case of oxo-biodegradable plastics. They
do not need to be composted, and should be re-used, recycled
(http://www.biodeg.org/position-papers/recycling/?domain=biodeg.org, or incinerated
for energy-recovery. They can be landfilled and will not emit methane. If all else fails,
they will self-destruct if they get into the open environment.
On 18th July 2008 Dr, Caroline Jackson MEP, Chairman of the European Parliament’s
Environment Committee said “we need to take account of the fact that we will never
succeed in collecting all the waste and that some may remain to disfigure the
landscape. This is particularly the case with plastic waste, from errant supermarket
bags to agricultural plastic. Where this goes uncollected it can accumulate in the
environment, polluting the land and the oceans for many decades, and perhaps for
hundreds of years. However, technologies have now become available which can
produce plastic products such as shopping bags, garbage sacks, packaging etc. which
are fit for purpose, but will harmlessly degrade at the end of their useful life.”
Oxo-degradation is defined by CEN (the European Standards Organisation) in
TR15351as “degradation resulting from oxidative cleavage of macromolecules” and
oxo-biodegradation as “degradation resulting from oxidative and cell-mediated
phenomena, either simultaneously or successively.”
Plastic is made oxo-biodegradable by including Symphony’s d2w formulation which
breaks the molecular chains within the polymer and makes it degrade then biodegrade
in the presence of air, on land or sea, in the light or the dark, in heat or cold, leaving
NO methane, and NO toxic dust or any other harmful residues. Oxo-bio can be tested
according to American Standard 6954, and is certified safe for food-contact. Plastic is
made from a by-product of oil or natural gas, so nobody is importing extra oil or gas to
make it. Oxobio can be recycled, and made from recyclate, and there is little or no
additional cost.
Biodegradation in the environment is NOT the same thing as composting. Composting
is an artificial process operated to a much shorter timescale than the processes of
nature. Standards (such as ASTM D6400, D6868; EN13432, and Australian Standard
4736) designed for compostable plastic are not therefore appropriate for plastic which
is designed to self-destruct if it gets into the environment.]
Page 7/8
While bags that do not persist in the environment sound like a positive step, there are
serious drawbacks. All types of biodegradable and compostable bags must be placed
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under specific conditions to degrade properly. For instance, a photo-degradable bag
will not break down if it is covered by water or otherwise obscured from light and an
oxo-biodegradable bag requires direct access to oxygen and sunlight to degrade.
[This is not correct. Unlike a photo-degradable bag, an oxo-biodegradable bag does
not require access to sunlight to degrade. It does require access to oxygen, but
oxygen is available almost everywhere in the environment. It is not normally available
deep in a landfill, but under those conditions degradation of anything is undesirable
unless the landfill has been designed to collect gas, which most are not.]
Any consumer who places a labelled biodegradable bag in the home compost pile will
not see the promised degradation because the required high temperatures achieved in
municipal composting facilities cannot be achieved with home composting. [This is true
of bags labelled “compostable” but not true of Oxo-biodegradable bags. Oxobiodegradable bags are not designed for composting, and are labelled accordingly.]
Additionally, some of these bags leave plastic pieces or other residues
when they break down, leftovers that natural systems and wildlife cannot tolerate.
[All plastic (and almost everything else) creates fragments when it degrades, but the
molecular weight of oxo-biodegradable plastics is rapidly reduced to the point where it
is no longer a plastic, and is capable of bioassimilation like straw and twigs. The
fragments therefore subsist for a much shorter time than fragments of normal or
recycled plastic. We are not aware of any credible evidence that natural systems and
wildlife cannot tolerate fragments of oxo-biodegradable plastics].
Finally, biodegradable bags inadvertently lead to litter because consumers assume the
bags will quickly break down or compost, whatever the conditions; they discourage
environmental stewardship. [There is no evidence to support this assertion.]
Page 19 Table Row 2
Oxo-biodegradable plastic (but not compostable plastic) is entirely consistent with instore recycling (http://www.biodeg.org/position-papers/recycling/?domain=biodeg.org)
Page 19 Row 4
[Florida should certainly require biodegradable bags as an option at checkout
Oxo-biodegradable bags are not expensive. Symphony’s d2w additive is included at a
very low rate, and the bags are made with the same polymer and the same machines
as ordinary plastic. The extra cost is no more than about 5%. Oxo-biodegradable
bags will not contaminate plastic recycling schemes. They are not designed for
composting, and this can and should be made clear on the label.
By contrast, compostable bags are much too expensive (up to 400%), they will
contaminate plastic recycling schemes, and they are not suitable for home-composting]
Page 27
BASF www.basf.com - makes ―Performance Polymers‖ aka biodegradable plastics
[BASF does not make biodegradable plastics – it makes compostable plastics]
Registered in England Number 3676824 address as above
Symphony Environmental www.degradable.net - makes degradable plastics
[Symphony Environmental supplies oxo-biodegradable technology]
BPI (Biodegradable Products Institute) www.bpiworld.org – professional association
promoting biodegradable plastics.
[The BPI is a trade association for the compostable (vegetable-based) plastics industry.
Other trade associations for that industry are the “SPI Bioplastics Council” and
“European Bioplastics]
There is no mention in the Report of the Oxo-biodegradable Plastics Association
(www.biodeg.org), which is the Trade Association for the Oxo-biodegradable Plastics
Industry worldwide.]
APPENDIX E
The reference to France is incorrect. The proposed ban on plastic bags by 2010 has
been cancelled, and there is no ban on plastic bags in Paris.
In Argentina, Brazil, Mexico, Barbados, Mauritius, the United Arab Emirates, Slovenia,
Hungary, Romania and Montenegro there is legislation, and proposals for legislation, to
encourage or require the use of degradable plastic (see
http://www.biodeg.org/legislation/).
Regards,
MICHAEL STEPHEN
Director
Registered in England Number 3676824 address as above