Request by: Anonymous Consumer

Key Findings

• Some current dental guard products contain phthalates, BPA or other chemicals of concern.
• Dentists often do not have information on the chemicals used in products they purchase for patients.
• Data provided by a dental laboratory listed dialkyl phthalate in the materials used to make the guard.
• Suppliers may offer technical data, such as Material Safety Data Sheets, but these won’t necessarily contain the full list of ingredients used in a product.

Background

PPRC occasionally receives inquiries on the safety of specific products. A recent inquiry on the safety of chemicals in night guard materials was prompted by our 2009 Rapid Response “Safety of Plastics in Dental Appliances.” This consumer was concerned about bisphenol-a (BPA) and wanted help understanding chemical information provided by his dentist.

In common practice, a dentist only makes a mold of the patient’s teeth. Using the mold, a separate dental laboratory prepares the custom appliance for the dentist. In this case, the dentist requested information from the appliance maker (the offsite laboratory), who complied by forwarding a Material Safety Data Sheet (MSDS) from the material/ chemical supplier, Henry Schein, Inc. MSDSs for various products are available at the Henry Schein, Inc. website.

As required, the Schein MSDS for “Easy Flow Acrylic Powder” listed three hazardous ingredients: Dialkyl Phthalate (CAS# 84-66-2), Titanium Dioxide (CAS# 13453-67-7), and Mineral Pigments (CAS# 57453-37-5), but made no mention of BPA, the chemical of concern to the consumer.

Limitations of Material Data Safety Sheets

Unfortunately, MSDSs are not designed to convey chemical safety information to consumers, but rather to inform workers in occupational settings. Chemicals or mixtures are typically identified by CAS numbers (CAS#), which are often used as an identifying index in chemical information databases. MSDS sheets are only required to list hazardous ingredients, so they won’t necessarily include chemicals of concern which are not yet regulated by OSHA. Furthermore, there is no requirement to list hazardous ingredients present at less than 1% (less than 0.1% for carcinogens), so ingredients could be missing from an MSDS, but still present in the product.

While many dental polymers may use BPA as an ingredient, most polymers are not considered hazardous. New polymer materials are also mostly exempt from the Toxic Substances Control Act, due to a presumption of safety. Roughly speaking, because the size of the polymer molecule prevents their absorption by the bodies systems, they are assumed to be essentially inert. Health concerns are sometimes associated with the monomers (the small molecules that are put together to make the polymer and which remain at some level in all polymers) and additives or contaminants.

In this case, the MSDS product name suggests use of acrylic plastics (acrylates), but they are otherwise not specifically listed as ingredients. There are many types of acrylates, some of which incorporate bisphenol A (BPA) and similar chemicals. While bisphenol A is currently under scrutiny by federal agencies, it is not currently listed as hazardous under US regulation, and would not generally be listed on an MSDS. Information on BPA content may be listed on some manufacturer material brochures or websites, but most likely consumers will need to contact supplier technical staff directly. In this case, Henry Schein, Inc., a very large company, likely has staff available to respond to consumer inquiries.

Easy Flow Hazardous Chemicals

As mentioned above, the Easy Flow Acrylic Powder MSDS lists three hazardous ingredients, Dialkyl Phthalate (CAS# 84-66-2), Titanium Dioxide (CAS# 13453-67-7), and Mineral Pigments (CAS# 57453-37-5). Dialkyl phthalate, also called diethyl phthalate, has been listed as a potential endocrine disruptor by TEDX (The Endocrine Disruptor Exchange). Chemicals of concern are listed on the TEDX website via a downloadable Excel spreadsheet indexed by CAS number. Washington State has also identified diethyl phthalate on its list of “Chemicals of High Concern to Children,” due to the potential for endocrine effects. There are varying opinions about whether diethyl phthalate is a risk for adults in this or other applications, but those most concerned about safety might choose to avoid these products if there are BPA- and phthalate-free alternatives available.

Two standard databases of chemical information that we typically use, eChemPortal and the Hazardous Substances Data Bank (HSDB) had no information for the CAS numbers provided by Henry Schein, Inc. for either titanium dioxide or the mineral pigments. Searching the database for materials similar to titanium dioxide might reveal some relevant safety information, but given the potentially significant risk from phthalates, no further analysis was pursued.

Conclusions

Without further information from the supplier, it is not possible to determine whether the products in question contain BPA. As described in the 2009 Rapid Response, there is reason for concern about BPA in dental products, but no black and white answer regarding health effects of chemicals in dental applications.

The MSDS lists hazardous chemicals, but no information could be identified using the CAS numbers provided for two of the specific chemicals. On the other hand, dialkyl phthalate has been identified as a potential endocrine disruptor. Those concerned about phthalate exposure should inquire about the availability of phthalate-free alternative dental materials.

Resources

• Original 2009 PPRC Rapid Response “Safety of Plastics in Dental Appliances.”
• Resources Environmental Working Group article on BPA in plastics: http://www.ewg.org/key-issues/toxics/bpa
• Industry article on BPA in dental composites: http://iaomt.org/bisphenol-a-dental-composites/
• American Dental Association statement on BPA (this site originally contained a full statement, but is now listed as “Under review as of Jan. 30, 2013”: http://www.ada.org/1766.aspx
• New York Times article on dental sealants and BPA: http://www.nytimes.com/2008/10/21/health/21well.html?_r=3&

Can plastic chemicals used in a sous vide (SV) wrap product migrate into food during cooking? Are there any associated toxicity concerns?

Request by: a culinary school

Background

There are many uses of plastics in cooking, including using plastics in the microwave, baking turkeys and hams in plastic bags, using plastic liners in crock pots, and pre-prepared foods in boil-in bags intended for one-time use (e.g., rice and other items). One company, Lekeu, even offers a reusable silicone “boil-in” bag.

Sous-vide (SV) is a lesser known method of cooking wherein a product is vacuum-sealed in a food wrap bag or pouch. In French, Sous-vide means “under vacuum.” Compared to typical cooking methods like boiling or baking, the vacuum-sealed food is cooked in lower temperature water baths and for longer periods of time. Little data exists indicating whether any of the resins or additives used in these SV plastics, or their degradation products, migrate from the plastic into the food during cooking.

All end-use plastics include base polymer(s) along with different types of additives used to enhance the product and/or performance. Additives serve as antioxidants, stabilizers, plasticizers, lubricants, antimicrobials, anti-static and anti-blocking agents, “slips,” or heat resistance agents. While unconfirmed by SV packaging manufacturers, it is highly probable that SV packaging contains additives to allow it to withstand heated water and food contact, for extended time periods.

Two plastic additives in recent media coverage are bisphenol-A (BPA) and phthalates. BPA is used in rigid plastic such as polycarbonate. While many plastic manufacturers have gone “BPA free”, there is always a question of how safe the replacement additive for BPA truly is. For more information on BPA and possible alternatives, see PPRC’s Rapid Response report on BPA in Receipt Papers or the EPA’s Design for the Environment report on BPA Alternatives in Thermal Paper. Phthalates are often used as plasticizers to make polyvinyl chloride (PVC) more pliable. Like BPA, some of the substitutes for phthalates may not significantly reduce the toxicity threat over the original phthalate(s).

Plastics and Food Contact Regulation

The FDA does not “approve products” containing any of the regulated polymers; it only regulates use of individual polymers and additives in food contact materials per the Inventory (above) and/or appropriate CFRs. The two resins likely to be used in SV packaging are low density polyethylene (LDPE) and nylon, with corresponding CFR references below.

• Sec. 177.1500 Nylon resins
• Sec. 177.1520 Olefin polymers

To be used in food contact articles or products in commerce in the U.S., any polymer and each individual additive must be authorized by the U.S. Food and Drug Administration (FDA), with limitations or specifications for its intended use. These stipulations often include concentration of the additive in the final product, end uses, and which FDA-defined “conditions of use” (e.g., temperatures during use) are acceptable, per Title 21 of the Code of Federal Regulations (CFR), Section 176.170(c), Table 2. Indirect Food Additives: Adjuvants, Production Aids, And Sanitizers (21 CFR Part 178) includes regulatory information about certain plastic additives.

While it may seem comforting to know that FDA regulates what can be added in plastic food-contact products, the actual Inventory of Effective Food Contact Substances (FCS) Notifications currently lists 963 different chemicals that can be used in food contact packaging. This inventory includes questionable compounds such as BPA, certain phthalates, and urea-melamine-formaldehyde resins. (The latter is only acceptable in small concentration for use in food washing pallets).

The FDA’s Guidance for Industry: Preparation of Premarket Submissions for Food Contact Substances: Chemistry Recommendations [6], Section 10, provides migration testing methods for individual food contact material per various use conditions (Uses A through G). This protocol also refers to “boil-in bags” but does not specifically refer to materials used in SV cooking. Within this non-mandatory protocol, and the FDA regulations, it appears that “Use D” (defined below, including the testing method) may be most applicable to SV cooking, although “Use C” could also be applicable when SV bath temperatures are above 150 dF. The definitions for the Conditions of Use are below. Recommended testing protocols for these conditions are found in the guidance.

Use C.  Hot filled or pasteurized above 66°C (150°F).   

Use D.  Hot filled or pasteurized below 66°C (150°F).     

What plastics and additives are used in SV pouches and wraps?

SV packaging suppliers have not been transparent about the additives found in their products. Also, no specifications or MSDS’ have been provided by manufacturers, or found online. Two manufacturers did disclose that their base resin materials are LDPE or LDPE/nylon layers.

One supplier, when asked, defensively stated, “Our material is FDA-approved, BPA and phthalate free.” First,  BPA should not be found in film products, as the compound is used in rigid (#7) plastics. Second, calling a product “FDA-approved,”is a misnomer because, as explained above, the FDA does not approve products. Finally, listing a chemical on the FCS inventory does not guarantee its safety, and many of the FCS Notifications are chemicals of concern from a toxicity standpoint. It is unknown whether the limitations on use, as stipulated in each FCS, are tight enough to protect consumers from these chemicals of concern.

Another supplier claimed that their material is “100% LDPE.” However, LDPE requires additives to provide necessary functional attributes.

Do chemicals migrate from the plastic during SV cooking?  

This answer to this question is unable to be confirmed due to lack of data and studies on migration of chemicals from plastics in simulated SV cooking conditions (e.g., 120 to 180 dF for an hour or more).

It has not been confirmed by the literature, but acidic or oily foods would conceivably increase the amount or concentration of any migration.

With suppliers unable to provide any information on these additives, and no existing studies on migration of contaminants specifically from SV packaging, uncertainty remains about any health impacts. Impacts of these chemicals depend on the amount of chemical migration from the plastic into the food during SV cooking, as well as their toxicity, and the susceptibility of anyone consuming the food cooked via SV.

A few studies may provide insight into the potential for migration from plastic during various cooking methods, and some of the health impacts. These are briefly described in Table 1 below.

Table 1

Conclusions

-          It is difficult to find the true composition of SV products. Manufacturers have mentioned two resins (nylon and polyethylene) that are used in their SV plastics, but have been unwilling to disclose the full formulations and additives.

-          No studies were found in the literature evaluating migration of chemical additives from plastics in simulated SV conditions.

-          For heated plastics in contact with food, several studies have shown migrated contaminants or additives that would be present in or on the contacted food. The amount or potency is unknown and dependent on many variables.

-          Testing (Yang et al, Barkby et al, Soto-Valdez et al) has shown migration of plastic additives from various ‘’food wrap” plastics, including additives that have estrogenic or hormonal affects.

-          Available study results provide information on the chemicals that migrate from the plastic, but have not provided any toxicity or health impacts.

References

[1] Begley , Gay , Hollifield.  1995. Determination of migrants in and migration from nylon food packaging.

[2] Crompton, 2007. Additive Migration from Plastics Into Foods: A Guide for Analytical Chemists

[3]  National Academies Press, 1999. Hormonally Active Agents in the Environment. (Reproduced from a naturopathic approach to health).

[4] Sheftel. 2000. Indirect Food Additives and Polymers: Migration and Toxicology.

[5] Yang, et al 2011. Most Plastic Products Release Estrogenic Chemicals: A Potential Health Problem That Can Be Solved.

[6] FDA’s Guidance for Industry: Preparation of Premarket Submissions for Food Contact Substances: Chemistry Recommendations

Additional Information: 

[a] Canada Domestic Substance List (DSL): 

Toxicity Findings for nylon 6, polyethylene, and caprolactum (a chemical known to migrates from nylon).

CAS Number      Material                               Findings in DSL

25038-54-4          Nylon 6                                 Persistent in environment

9002-88-4          Polyethylene                 Persistent in environment

105-60-2               Caprolactam                       Categorized for human and environment health toxi

[b] U.S.  FDA Packaging & Food Contact Substances (FCS)   Webpage

[c]  From:  Schellers, 1993, FLAIR (FOOD-LINKED AGRO-INDUSTRIAL RESEARCH)

** Excerpt  from:  SOUS VIDE” COOKING

Testing of PVC film (“cling film”) plasticized with di-(2-ethylhexyl)a dipate (DEHA) was carried out in the UK (Startin et al., 1987) for a variety of foods which were either cooked or reheated in microwave ovens. They found that migration of the compound did occur, that it increased with the length of contact time and temperature of exposure, and that levels of migration were highest where there was direct contact between the film and foods with a high fat content at the surface. Highest levels of migration were observed for cheese, cooked meats, cakes and for microwave-cooked foods. An assessment of the DEHA migration from these films in such situations led to the recommendation that this type of film should not in future be used under any circumstances in conventional ovens, nor should it be used for lining of dishes or wrapping of foods in a microwave oven (Ministry of Agriculture, Fisheries and Food, 1987).

Request by: City of Portland, Oregon

Introduction

The city of Portland, Oregon wanted to understand more about oxo-degradable bags with respect to using them as receptacle liners.  Specifically:

• Do they cause problems for plastics recyclers
• Under what conditions do the material biodegrades?
• Can they be included in the city’s commercial composting program?
• If used oxo-degradable bags that end up in the landfill, do they offer an environmental benefit over traditional plastic bags?

Background

Degradable bags and plastic films are readily available and marketed by producers for environmental benefits, such as biodegradation.  There are at least four different types of “degradable bags”.

Starch-based films and bags (heretofore referred to as “biobags”) are made of a starch or fiber, typically corn, soy or potatoes.  These decompose in a controlled composting environment in 10-45 days.   Bio-based plastics meet standards set by the American Society for Testing and Material (ASTM) for compostability, breaking down 60 percent or more within 180 days or less.   In order to do this, bio-based plastics need water, heat, and aeration.  Biobags are used in many food waste collection programs; oxo-degradable bags are not compostable.

Oxo-degredable bags, the subject of this document, are different than biobags.  They are additive based biodegradable films/bags (including oxo-degradable) rely on additives to the resin to hasten degradation upon exposure to different conditions. Oxo-degradable films degrade by oxidation; hastened by the chemical additives.  Degradation of oxo-degradable plastic begins with a chemical process followed by a biological process.   Examples of product that may use oxo-degradable plastic include: agricultural sheeting, blister packaging, bottles, caps/closures, carryout bags, clamshells, labels, landfill covers, lids, milk pouches, pallet and shrink wrap, and trays.

Two other types of degradable plastics, also additive-based, include, hydro-biodegradable plastics which degrade by hydrolysis, and thermal-based biodegradable plastic which degrade with exposure to heat.

At the time of the initial request for information on the oxo-degradable bags, the City of Portland had compiled some information about oxo-degradable bags and plastics.   They had worked with hydro-biodegradable plastics but not yet with oxo-degradable suppliers. The oxo-degradable plastic manufacturers claim the material is recyclable and compostable, and degradable in the landfill.  However, studies show these bags are not compatible with recycling or composting.  Thus, the City was looking for answers regarding use of these bags

Findings

Do the oxo materials cause problems for plastics recyclers?

A 2007 study [1] which evaluated two brands of oxo-degradable and hydro-degradable bags, indicates that neither type of bag are perfectly compatible with the traditional plastic grocery bag recycling stream, which is typically low-density polyethylene (LDPE).

Another study by the Loughborough University in 2010, concluded the following:  “Oxo-degradable plastics are not suitable for recycling with main-stream plastics. The recyclate will contain oxo-degradable additives that will render the product more susceptible to degradation. Although the additive producers suggest that stabilisers can be added to protect against the oxo-degradable additives, it would be problematic for recyclers to determine how much stabiliser needs to be added and to what extent the oxo-degradable plastic has already degraded. On this basis it seems unreasonable to claim recyclability of oxo-degradable plastics in existing recycling streams” [2].

A study commissioned by the California Integrated Waste Management Board (CIWMB), Performance Evaluation of Environmentally Degradable Plastic Packaging and Disposable Food Service Ware [3] states, “Degradable plastics can negatively affect the quality and mechanical properties of recycled plastics if they are mixed with the recycled plastics. The contamination of degradable, biodegradable, and oxo-degradable plastics can be treated as other contamination to plastics. The effects of the degradable contamination can be evaluated by measuring physical properties and mechanical properties of the plastics.” One specific test conducted was on the effects of mixing oxo-degradable material with post-consumer low-density polyethylene (LDPE) at a ratio of 1:5. Researchers found that the introduction of the additive containing oxo-material increased specific gravity of the LDPE and altered the melt index of the LDPE.

A rebuttal, on the CIWMB study results, comes from the Chairman of the Scientific Advisory Board of the Oxo-biodegradable Plastics Association, and claims that “The studies referred to above [in the CIWMB 2007 report) show that oxo-biodegradable polyethylene(PE)  can be collected with regular PE waste for recycling without any adverse effects on the quality of the recycled products. [4]

The industry group’s (Oxo-Biodegradable Plastic Association) Scientific Advisory Board argues that combining post consumer oxo-materials with other plastics is feasible, with rationale that recycling post-consumer oxo-degradables with virgin or recycled resins effectively dilutes any additives, rendering them ineffective [5].  This position paper suggests they are recyclable “without significant detriment the newly formed plastic product.”

These differing claims and study results, that the material is recyclable with PE streams, or is not compatible and may affect the properties of the final product, are not fully resolved in the literature.  Further, the Biodegradable Plastics Institute (BPI) says that the formulation of additives in oxo films varies greatly [6], which introduces even more variability in the recycling process.

Since processing conditions and quality or property requirements of reprocessed PE varies at every processor, the most real and local answer will be identified by the recycled plastic processor that may be taking that material.  They can test samples in their process to see impacts on the final product.

Here is one company’s story, that started using oxo-bags, and returned to non-oxo-degradable plastic:

Dave’s Killer Bread researched oxo-degradable bags for their bread products, and knew that many oxo-degradable plastics are not recyclable.  However, they did find one film that had been verified by a third party to be recyclable.  After also verifying that this plastic would have no effect on the food product it was enclosing, and that the FDA had approved it for packaging, they switched to oxo-biodegradable bags in early 2009.   After finding out that plastic recyclers had concerns about their bags, because of concerns over their unknown effects on the long term viability of products containing recycled oxo-biodegradable plastic, along with other new information about oxo-degradable plastics, they discontinued use of oxo-degradable bags in 2012 [7].

Here is another company’s statement on using oxo-bags in their recycled-content wood:

TREX plastic lumber company, a large volume user of recycled PE films, stated in 2008, “Unless and until the long term durability testing concludes that the oxo-biodegradable polyethylene plastic (OBPE) will not have an adverse effect on our product, Trex cannot support the introduction of OBPE materials into traditional recyclable polyethylene streams.” [8]

More recently, Trex told us that it is still their position that biodegradables are, by definition, non-recyclable.  They offer a 25 year Residential Warranty on their composite lumber.  If the raw materials used to manufacture this product are designed to disintegrate, they are uncertain whether their boards will bare that impact.

Should oxo plastics be included in our commercial composting program?

The literature, again, has differing study results on whether oxo-degradable bags are compostable.  As an example, see the citations in this Intertek (May 2012) report, (pages 10 – 11) [9].

Currently, oxo plastics are not approved by the Biodegradable Products Institute (BPI) because they do not meet the ASTM specs for compostability (ASTM D6400 – “Specifications for Compostable Plastics”). This standard requires that a product degrade within 180 days.  The oxidation process for oxo-degradable bags tends to take longer in most conditions.  While the bag may fragment within this time period, full degradation is not likely to occur.

Cedar Grove (a large commercial composter in the Pacific Northwest) does not accept, nor even typically test materials for suitability in their process if they are not BPI Approved for compostability to ASTM D6400.   For those composting with companies other than Cedar Grove, the question of the suitability for composting of a particular product will be dictated by the compost operation in the area.  If Cedar Grove is considering accepting an incoming material for composting, (in this case, oxo-degradable bags), they will test the material in their exact process before approving the material for compost collection.

An additional challenge that composters face is determining plastic type as plastic shoots down the conveyor belt at 50 tons per hour.  If an oxo-degradable bag looks like LDPE (e.g., grocery bag), the operator is hard pressed to be able to tell the difference in the time given, and may just pull the material off the line for other disposal whether it is LDPE or oxo-degradable.

If the bags just end up in the landfill (as in trashcan liners) is there an environmental benefit to it degrading in the landfill?

Based on the literature, there seems to be no significant benefits to degradation in the landfill.  Oxo-degradable products require oxygen to degrade, so decomposition deep in a landfill, with anaerobic conditions, is not likely to occur due to the absence of oxygen and UV light, where these bags are completely inert .

Conceivably, most commercially available oxo-biodegradable plastics will begin to disintegrate in the surface layers of a landfill if oxygen is present.  Oxygen levels will vary according to factors such as how loose or compressed the waste was when it was buried, how much ultraviolet light is available, and how quickly additional waste materials or daily cover is added on top of the bag.   One potential advantage of landfilling these, over traditional bags, is that the oxo-degradable bag will fragment sooner when conditions allow (such as loose upper layer conditions).  It would then settle more easily than an ordinary plastic bag with trapped contents or air, and occupy less space.

A landfill study carried out by the University of California [10] reported that oxo-biodegradable plastic did not undergo anaerobic biodegradation during the study period of 43 days, while a control sample of paper did biodegrade under the same anaerobic conditions, and produced methane. Thomas at al (2010) concluded that these findings supported the claims from the producers of oxo-biodegradables that these products will not emit methane in anaerobic conditions in landfill sites.

Under what conditions does it decompose, and how long does it take?

Oxo bag degradation depends heavily on the surrounding conditions.  According to Powell & Leineweber’s article [11], many manufacturers promote oxo-degradable products based on the assumption that full decomposition occurs between 18 and 24 months, but other studies indicate it may take five years to decompose. Critics of oxo-bags say that the oxo-degradable bonds require a hot arid environment to break, and the polymeric fractions require a warm, wet, microbe-rich environment to decompose.

Although the exact brand or resins studied are unknown, the CIWMB study [4] tested degradation rates of biodegradable plastic samples in lab, landfill, and compost settings and found that the biodegradable samples decomposed within 180 days, but no measurable degradation occurred for the selected oxo samples, using ASTM D6400 standard specifications.

One company, EcoSafe Oxo-Biodegradable Trash Bag products are said to be engineered to degrade and totally fragment in 90 to 120 days and 60% mineralize / biodegrade in a further 12 to 24 months after disposal [12].  Another company, EcoBio® products are engineered for disposal in a landfill and under these conditions will degrade and fragment at a slower rate (12 to 18 months) [13].

References

[1] Grenier, D., and Cote, L. 2007. Evaluation of the Impact of Biodegradable Bags on the Recycling of Traditional Plastic Bags.

[2]  Loughborough University.  2010.   Assessing the Environmental Impacts of Oxo-degradable Plastics Across Their Life Cycle.

[3] California State University, Chico Research Foundation. June 2007. Performance Evaluation of Environmentally Degradable Plastic Packaging and Disposable Food Service Ware – Final Report. June 2007.

[4] Scott, G.  2008.  Comments on “Performance Evaluation of Environmentally Degradable Plastic Packaging and Disposable food Service Ware – Final Report”.  California State University for CIWMB

[5] Oxo-Biodegradable Plastic Association .  2012.  “Recycling of Plastics”

[6]  BPI.  2003.  BPI Assessment of Oxo-Degradable Films

[7] Dave’s Killer Bread.  2012.  Press release.

[8] Greener Package.  2009.  Feedback on Oxo-Biodegradables

[9] Edwards & Parker.  Intertek.   May 2012.   A Life Cycle Assessment of Oxo-biodegradable, Compostable and Conventional Bags

[10] California State University, Chico Research Foundation. 2007. Evaluation of the Performance of Rigid Plastic Packaging Containers, Bags, and Food Service Packaging in Full-Scale Commercial Composting

[11] Powell & Leineweber, 2009. Breaking Down Oxo-Degradables. Resource Recycling. April. Iv

[12] Eco-Safe Bags (website)  http://www.dirtworks.net/Biodegradeable-Plastic-Bags/EcoSafe-Information-Dirt-Works.html

[12] EcoBio® (website)  http://www.all-greenjanitorialproducts.com/EcoDegradable-Garbage-Bags-33-Gallon-p/1075.htm

Additional Resources

OxoBiodegradable Plastics Association FAQs:       http://www.biodeg.org/faq.htm#1

The Biodegradable Products Institute:                     http://www.BPIworld.org

Can you Provide an Introductory Toolkit for Conducting Community E-Waste Collection Events?

Requested by: Anonymous

Introduction

Electronic wastes (e-wastes) include spent electronics, computers, cell phones, printers, and so o,n and is a problem waste stream if not managed properly.

E-waste collection events around the country are a useful service to communities, that help prevent hazardous materials from being improperly disposed of. The variety and types of materials collected at an event vary depending on the hauler and recycler.

Why should community or business groups host e-waste collection events?

• Good public relations and outreach about the host organization as well as proper disposal of e-wastes
• E-wastes contain hazardous constituents and need to be disposed of properly (to a certified electronics recycler)
• Benefits to community to be able to drive through and drop items off in one place and not have to search for a local location that accepts e-waste
• Ultimately, recovery of the metals and materials (as compared to illegal dumping or landfilling) reduces the potential for constituents to release to water, air, or soil, and it reduces the need for mining and extraction of virgin materials

Steps

Typically, a minimum of two to three month(s) are needed to plan an event and conduct effective outreach to attract donors.

Here is a list of recommended steps for holding an e-waste collection event.  Details for each step follow this list.

• Set goals for collection
• Find a reputable electronics recycler in your community to help with collection and conduct the disassembly/recycling of the collected items
• Secure sponsors (if desired)
• Set a date
• Check with and notify government entities
• Plan the day/event
• Plan/conduct outreach
• Conduct the event
• Measure and promote success

1.       Set an estimate and/or goals for collection

Goals are dependent on the host organization, but should include (but is not limited to):

• Amount of waste (pounds/truckloads)
• Number of households to reach with outreach messaging
• Number of households dropping off material

The local e-waste recycler may have an estimating tool or past experience to help estimate the collection volume expected. 

2.    Find a certified recycler in your area  

It is recommended to partner with an e-Steward® certified.  Determine if the recycler is physically present to collects materials in trailers onsite at the collection event.  If not, find out who they use for collection events  to load and haul collected items to their recycling facility.

If there is no e-steward certified  in their area, another search page for e-waste recyclers is at Earth911. 

3.    Secure sponsors.

Since these events are typically a community service, the host organization may want to have other local businesses help with outreach, covering costs, providing volunteer help on the day of the event, or be included on the outreach materials if the organization will draw more e-waste donors.   Local businesses, sports teams, scouts, churches, community centers, and environmental non-profits are potential candidates for partnering on such events.

4.    Set a date. 

Work with recycler and facility manager at the collection site to determine a date AND hours of operation.

5.   Check with and notify government entities

While it may not be required in every city, local government should be notified of collection events dealing with e-waste, to determine if there are any restrictions or special requirements, including stormwater control if it is raining that day.  For instance, see California Department of Toxic Substances Control (DTSC) Guidance for hosting a collection event.

If you are uncertain who you need to contact with respect to government agencies, contact PPRC (info@pprc.org) to determine which agency needs to be contacted.

6.    Plan the event. 

a.   Devise a brand or logo, and advertising mantra

b.  Work with the recycler/collector to:

• Put together lists of the allowable and unacceptable materials.    Emphasize that household hazardous wastes will not be accepted.

Note:  Neither the host organization nor the e-waste recycler wants the liability of collecting, handling, and taking responsibility for proper transport of  any fluorescent bulbs (mercury release if breakage occurs), fluids such as pesticides or solvents, PCB transformers, etc.. 

• Determine if there is a limit of e-waste (by volume or number) per car?
• Determine if electronics will be accepted from small businesses, large businesses, or only from citizens/residential donors?

c.  Determine how much support the collector/hauler will provide on the day of the event, along with other requirements.

• Will they do 100% of the sorting and truck loading?
• Do they direct traffic ? And provide traffic signage/cones, etc? Or is that
• Do they need a donor form filled out by any donors?

d.  Based on goals and selected hours of operation and the level of participation from the onsite collection vendor, determine who and how volunteers or other outside hired staff are needed to run the event.   

e.  Determine a schedule for the day, including set up crew arrival through clean up crew.

f.  Plan a short training/safety meeting before the actual start of collection. Safety issues include but are not limited to:

• What materials are accepted and where they will be placed
• Flow of traffic and crossing traffic paths
• Wearing gloves if handling any materials
• What materials are of concern in case of drop/breakage (old monitor glass contains lead, toner ink, highly flammable lithium batteries,  etc.)
• How to clean up any drops/breakage
• Hand out any fliers or other event info or trinkets

g. Plan a designated place where volunteers and event staff will park.

h. Establish a drive-through procedure including number of lanes, exit driving path, etc.  including posters, driving arrows, other signage.  Important considerations are number of drop-off lanes, ensuring that handlers and donors do not cross traffic paths, how to remove full trucks during the day if needed, and trying to ensure that there is enough room and lanes on the lot so that cars are not lined up onto streets/blocking traffic.   See an example plan.

h.   Develop plan for signs and arrows directing people toward the event.    Make or purchase the signs.

i.    If you want to media or local community blog coverage of the event, let them know via press release, phone call, or other means.

j.   Will you provide handouts or gimmicks/info to customers?   In the interest of less waste, maybe handouts are not preferred.   If you see value in additional messaging to the e-waste donors, things that might be of interest to include are:  how/where to recycle e-waste and different commodities in the future, interesting tips about recycling and pollution prevention relating to electronics, thanking them for stopping by, and/or something to this affect:

NOTE: Any and all Electronic Waste collected at these events is sent to an e-Steward® certified facility within the State of xx that certifies that it is 100% demanufactured and recycled in a stringent and environmentally acceptable manner to the commodity level in the United States. No Electronic Waste collected at these events is sent overseas.

k.  Plan for other onsite needs on event day

• Cones
• Caution tape
• Protective gloves for all staff
• Scissors, large markers, tape, string,
• Garbage bags or receptacles (Inevitably, some things will be dropped off that will not be accepted by the recycler)
• Brooms and dustpans (for clean up of small items or any breaks)
• First aid kits
• Canopies in case of rain
• Hand flags (for traffic directors)
• If it is raining, are there any special stormwater collection or diversion devices?
• Other?

Summary of Potential Staffing /Volunteer Needs (Unless provided by collection company)

• Event managers
• Traffic directors (unless professionals/security staff/police to direct traffic?)
• Set up crew
• Two staff or volunteers per drop-off lane (or more depending on expected size of event?)
• “Greeter” at entrance
• Any sports celebs attending /helping?
• Collection/hauling company
• Final grounds clean up crew
• Optional:  photographer
• Media?
• Security if event is expected to be large

7.    Plan and conduct the outreach

Who is the target audience?  How will you reach them?

• Website posting
• Radio advertising (especially local sports stations)
• TV
• Advertising at games
• Local community blogs
• Facebook, Twitter
• City/County (possibly a bill stuffer)
• Ask sponsors to send out messages to their local customers
• Other?

Example ideas for presentation or handout materials

• Ecology Center’s E-Waste FAQ

• Announcement of event with message that it is illegal to dispose of electronics in landfills.  http://ojaivalleygreencoalition.com/Ewaste_flyer.pdf

8.    Conduct the event

9.     Measure and promote success

Work with the event hauler and/or recycler to be able to document the number of truckloads and pounds of waste collected.   Compare to estimates and goals established above.

Share your event successes with a local blog, or newspaper and learnings with GSA members.

Electronic wastes (e-wastes) include spent electronics, computers, cell  phones, printers, etc…and is a problem waste stream if not managed properly. 

E-waste collection events around the country are a useful service to communities, that help prevent hazardous materials from being improperly disposed of.   The variety and types of materials collected at an event vary depending on the hauler and recycler.

Do you have an easy yet specific method to calculate transfer efficiency for spray paint operations?

Requested by: Washington Department of Ecology (on behalf of cabinet maker)

Introduction

Very simply, transfer efficiency (TE) of a spray operation or finishing process is the amount of material that adheres to the substrate compared to the amount of material that was sprayed through the applicator toward the substrate.  Transfer efficiency is expressed as a percentage.

Ken Grimm, PPRC, who trains facilities and operators in spray efficiency, and is certified in Spray Painting Efficiency Training (STAR®), says that initial reaction from operators is that 37% is a low rate of transfer efficiency. In fact, he rarely sees rates above 50% in automotive painters and almost never sees rates above 37% in industrial facilities.

Transfer efficiency is important with respect to productivity, and cost and environmental savings. A facility had a vendor consultant come in and measure their TE to a specific standard, and the result came in at about 17% TE. This translates to the following:

• For every $100 the company spends on paint as a raw material, they are, in a sense, throwing $83 of that paint away as overspray.
• They are paying to dispose of the overspray (as solid waste or hazardous waste), to take that $83 away from them.
• The lower the TE, the more airborne paint  particles are captured in the air filters, requiring more frequent change of air filters (than a higher TE operation).
• The lower the TE, the more frequently new paint will be needed, increasing labor.
• Lower TE can help achieve compliance with air permits.

There are many variables to transfer efficiency, listed below. Painter technique is believed by many experts in spray efficiency to have more of an affect than any of the other variables.

• Painter technique
• Part size
• Part geometry
• Gun-target distance
• Coating viscosity
• Ease with which coating can be atomized
• Spray gun design and method of atomization
• Fluid pressure
• Atomizing air pressure
• Fan size
• Overlapping of successive spray gun strokes
• Orifice diameter of spray gun cap
• Air velocity in the spray booth
• Air balance in the spray booth
• Lead and lag triggering times
• Conveyor line speed
• Speed of spray gun travel
• Painter fatigue
• Lighting in the spray booth
• Space constraints on the spray booth
• Attitude of management
• Attitude of the painter

For electrostatic guns additional parameters include:

• Coating conductivity (or resistivity)
• Grounding of the parts
• Voltage potential between electrode and ground

Source:  Transfer Efficiency, by Ron Joseph

When training painters, STAR® also addresses build efficiency (BE), related to finished build thickness of the paint on the substrate. This is important because, like TE, it is a measure of wasted paint (or efficient application).  For example, if a customer specification calls for a finish thickness of 3 dry mils, and a part ends up with 6 dry mils of finish thickness, an operator who (theoretically) achieves 100 percent TE, would still have wasted 50% of the paint due to the extra 3 mils of paint coated on the part. All painters will likely exceed the 3 dry mils to be sure the coating thickness is not under spec. However, keeping the coating under, say, 4 dry mils (for a 3 mil spec) can be almost as important as ensuring a good TE rate.

Calculating Transfer Efficiency (TE)

In spray painting operations, a clear and specific description of how to calculate TE depends on desired accuracy of the result. Accuracy may range from a “back of the napkin” calculation to expensive laboratory tests when required to qualify an operator to a specific TE performance, and/or ratings for particular spray apparatus to ensure they meet NESHAP requirements (including methods by the South Coast Air Quality Management District (SCAQMD)[1].

The method below is a simple way to determine an adequately accurate TE for “in-house” use.

Do you have suggestions & tips for making schools healthier environments?

Requested by: school staff and parents

An Oregon client has a high-boiling point substance contaminated with organic solvents. What resources are available to help select the appropriate technology to recover solvents (acetone and toluene) from the mixture?

Requested by: David Kunz, Oregon Department of Environmental Quality

Background

An Oregon manufacturer recovers a high-boiling point product material from an industrial process. The material contains residual acetone and toluene which the manufacturer wants to remove and potentially recover for re-use. Information was requested on methods to recover solvent from the product mixture.

Solvent Recovery by Distillation

Both acetone and toluene are fairly volatile solvents. Their boiling points are substantially different (acetone boils at 56 C and toluene at 110.6 C), which would likely lead to an easy separation and recovery by a simple batch “kettle” still. If the initial product mixture contains other volatile components, fractional distillation may be required to achieve desired individual solvent purity.

Distillation for solvent recovery and reuse is widely practiced. Guidance documents on factors to consider in solvent recovery are provided in the Resource section below. Case studies of commercial implementations and vendor links are also listed. Equipment vendors can provide guidance on the scale and type of equipment appropriate for individual applications. Vendors will typically perform test distillations to verify performance.

Resources

Questions to ask when considering in-house solvent recover:)

• On-Site Solvent Recovery Stills: http://dnr.wi.gov/org/caer/cea/publications/pubs/section3/sw150.pdf
• A Guide For Choosing and Operating an On-Site Distillation Unit: http://www.deq.state.ok.us/lpdnew/pollutionprevention/guiddstl.pdf
• Solvent Recovery Systems (includes a simple economic calculation example): http://infohouse.p2ric.org/ref/12/11493.pdf

Case studies on solvent recovery:

• Solvent recovery case study at Bayer Corporation, North Carolina: http://infohouse.p2ric.org/ref/07/06123.pdf
• Solvent recovery case study at Crumrine Company, Nevada: http://unrbep.org/wp-content/uploads/2009/11/Crumrine.pdf

Commercial vendors of systems or distillation services:

• An Oregon vendor with experience in solvent recovery by distillation (includes considerations of Oregon hazardous waste disposal regulations): http://www.orenviro.com/solvent-recovery-systems-lower-your-EPA-classification.htm
• A California provider of distillation systems: http://www.cal-water.com/pdf/products/Lit%20Distillation.pdf
• Vacuum distillation equipment may be required where the mixture to be separated includes large, complex molecules that would be affected by high temperatures. Oregon Environmental mentioned above makes equipment for this purpose: http://www.orenviro.com/products/vacuum-generator-VAC200.htm
• CBG, a large commercial system provider: https://www.cbgtechnologies.com/case-study-new-jersey-manufacturer.aspx
• NexGenEnviro Systems, Inc., a large commercial system provider: http://www.nexgenenviro.com/category/481/solvent_distillation.html
• Commercial services are also available to purify solvents for recycle, even complicated mixtures: http://www.veoliaes.com/en/services/enterprise/recycling/solvents.html

Disclaimer:  PPRC does not endorse any particular vendor and provides these commercial links as examples only. Be sure to ask vendors for references and consider looking into competitors in the same market before proceeding with any purchase or commercial contract.

Are there possible contributors to zinc in our stormwater, other than atmospheric deposition from a freeway next to our facility? 

Request by: metal welding facility

Key Findings

This question was posed from the perspective of a small metal shop that has found zinc in their stormwater above state benchmark levels.  Because they do not use zinc in their operations, they assume most of the zinc is from source(s) “out of their control”, and mainly airborne deposition from the traffic on an elevated stretch of road around their facility.  Zinc is released from tire use.

While the deposition from this source is not controllable by the facility, some zinc can be removed from runoff or stormwater through readily available stormwater treatment.

Summary

Sources of zinc in urban runoff have been extensively studied.  A contact at the California Stormwater Quality Association (www.CASQA.org) found more than 125 references on this topic in preparing a zinc stormwater source identification study (not yet released as of June 2012).  The author states that preliminary conclusions are that the major sources identified are galvanized surfaces (roofs, gutters, flashing, fencing, guard rail, and downspouts and drainage system/pipes, etc.), and wear debris from vehicle tires.

Other local sources, can be very important if they occur at or near a location, such as:

• Anticorrosion paint (often used on exterior steel) that contains zinc
• Zinc moss killers applied on walkways, decks, and roofing (and sometimes impregnated into non-metallic roofing materials)
• Air deposition from local air emissions sources (e.g., galvanizers, glow-in-the-dark product manufacturers)
• Spewing of material like tire wear debris that is re-suspended from roads (particles are large, so this only applies right next to major roads).
• Fertilizers (most likely if over-applied or an unusually high-zinc material)
• Marine antifouling coatings (usually used primarily in or near salt water)
• Wood treated with preservatives containing zinc (AZCA or zinc naphthenate)
• Zinc-content de-icing chemicals
• Cleaners/surface preparation chemicals used before painting (particularly metal surfaces)
• Sediments in gutters/drainage systems (zinc levels don’t drop until these are flushed)
• Acidic emissions from a plant where the “residue” settles on a galvanized roof and contributes to more etched or release of zinc than normal exterior weather conditions may cause.

While pollution prevention is the best option, control options are available, and zinc tends to be relatively readily removed by typical stormwater treatment devices, including filtration and some drain inserts.   Note that treatment for zinc removal may be ineffective for some other metals like copper.  See references below to find out more on treatment options.

Additional Research and Resources

• A Survey of Zinc Concentrations in Stormwater Runoff (2006), Washington Department of Ecology
• EPA’s NPSINFO, e-Forum Resource Center offers a venue to share practical experiences and discuss nonpoint source pollution (NPS) control issues with others
• Metals Removal Technologies for Stormwater: Filtration (no date), Penn State & University of Alabama.
• Suggested Practices to Reduce Zinc Concentrations in Industrial Stormwater Discharges (2008), Washington State Department of Ecology.
• Stormwater Filtration Media Testing for Metals Removal and Toxicity Reduction (no date), Port of Seattle, Parametrix, and Taylor Associates.
• Stormwater Source Control and Pollutant Removal/Reduction (May 2012), Washington Stormwater Center.
• Literature Review of Existing Treatment Technologies for Industrial Stormwater (July 2011), Prepared by Herrera Environmental Consultants for Science Applications International Corporation and Washington Department of Ecology.

1)       What is the latest understanding of the toxicology of BPS (bisphenol S)?

2)       Can BPS be considered environmentally superior to BPA (bisphenol A)?

3)       Should recycling paper mills be concerned about discharging BPS into the water supply?

4)       Do you know to what extent BPS has replaced BPA in the receipt market?

Request by:  Paul de Block, Bureau of Planning & Sustainability, City of Portland

Key Findings

• A US Environmental Protection Agency (EPA) Design for the Environment (DfE) partnership program has summarized preliminary data on the chemical hazards of BPA, BPS and other alternative chemicals for use in thermal paper. No clear “safe” alternative has emerged from the EPA DfE work to date.
• PPRC reviewed the preliminary hazard evaluations for BPS versus BPA. The picture is complex as there are many hazard criteria, with some criteria worse for BPS with others worse for BPA. The EPA analysis suggests that BPS is less potent than BPA in some tests of endocrine activity.
• Regarding discharges to the aquatic environment, BPS has lower aquatic toxicity than BPA, but is more persistent in the environment. PPRC recommends a more detailed follow-up analysis of the environmental impact of BPS releases from papermaking or recycling facilities.
• PPRC did not find any information on the relative amounts of BPS- versus BPA-based thermal paper in the US market. In 2010, Appleton Papers described a plan to incorporate “easy-to-see” red threads in their BPS-containing thermal paper to help consumers identify their product. This may offer consumers or other parties an opportunity to assess the overall penetration of Appleton BPS papers in the overall market.
• Recent biomonitoring data suggest that consumers are being exposed to BPS. While mainly used in thermal paper, BPS was found in a variety of other paper products, perhaps introduced inadvertently in the papermaking process or via recycled materials.
• No information was found to quantify market penetration of BPS-containing paper, however, BPS has been used domestically by Appleton since 2006.

Background

In 2009 and 2010, following years of controversy on the use of BPA in polycarbonate bottle products, a number of publications identified possible concerns over the use of bisphenol A (BPA) in thermal paper for point-of-sale (POS) receipts. PPRC’s summary of the issue was published as a Rapid Response in 2010 (read it here). In 2010, Appleton Papers, the largest US manufacturer of thermal paper announced that they had changed their process to eliminate BPA from their products beginning in 2006. Later, Appleton reported that BPA had been replaced by 4-hydroxyphenyl sulfone, also known as bisphenol S (BPS). This same fact sheet reports Appleton’s finding that BPS is a better option for thermal paper than BPA:

“We have reviewed the scientific literature about the toxicology of thermal developers and have concluded that BPS is a better choice than BPA for overall product safety. Outside expert opinion, supports our conclusions.”

To PPRC’s knowledge, no additional data on BPS chemical hazards have been released by Appleton.

In 2010, the US Environmental Protection Agency convened a broad range of stakeholders to consider chemical alternatives to BPA for thermal paper manufacture under the Design for the Environment (DfE) partnership program. Appleton, a variety of other thermal paper manufacturers, NGOs and others have been participating in the DfE stakeholder partnership. This voluntary effort has generated significant data on possible alternatives to BPA, including BPS. As the data are in draft form, results should be viewed with caution and may change prior to the formal publication of results expected later this year (2012).

DfE Hazard Evaluations for BPA Alternatives in Thermal Paper

The DfE partnership identified 19 chemicals that might be useful alternatives to BPA in thermal paper. US EPA staff completed draft hazard evaluations for BPA and these alternatives in 2011. The hazard evaluations summarize chemical, toxicological and environmental information and include a comprehensive list of a dozen or so hazard criteria. Among these are carcinogenicity, reproductive toxicity, endocrine activity, persistence, aquatic toxicity, etc. Each criterion is evaluated from existing data or models of chemical properties and assigned a value of High, Moderate or Low (and for some endpoints Very High or Very Low). For a criterion such as reproductive toxicity, a value of High indicates high toxicity relative to US EPA established ranges (see the DfE alternatives assessment criteria available here).

Given the large number of criteria, the complexity of interpretation, and the preliminary nature of the hazard data, we present only a brief subset of the information for BPS and BPA. BPS and BPA are compared against each other as relatively better (+), worse (−) or neutral (0) for the subset of criteria reviewed (ratings assigned by PPRC based on US EPA hazard values), Table 1. For example, if BPA exhibits a High value for a criterion and BPS has a Moderate value for the same criterion, then BPA will be listed here with a “−“, i.e., worse, and BPS with a “+”, i.e., better.

The DfE program has not ranked alternatives as overall better or worse and the data shown in Table 1 for BPA and BPS demonstrate the challenge of ranking chemicals based on hazard traits. BPA and BPS seesaw across the various endpoints showing no consistently higher or lower level of hazard. It’s also important to consider differences in the persistence of these compounds in the environment. For example, BPS has better (lower) acute aquatic toxicity, and in that sense is “safer” for aquatic life, however, BPS has higher persistence in the environment (i.e., it remains in the environment for a longer time) increasing the chances that aquatic life will be exposed to BPS compared with BPA.

Much of the concern about BPA surrounds its well-established endocrine activity and the possible harm from exposure to vulnerable populations during critical periods of development. The DfE assessment reports that BPS behaves as a weak estrogen and provides additional data suggesting that BPS has lower potency when compared with BPA in similar experiments on endocrine activity. These results may change over time as data is further developed by EPA. Authoritative, up-to-date results can be provided by Dr. Cal Baier-Anderson at EPA: baier-anderson.caroline@epa.gov.

The DfE partnership identified 19 chemicals that might be useful alternatives to BPA in thermal paper. US EPA staff completed draft hazard evaluations for BPA and these alternatives in 2011. The hazard evaluations summarize chemical, toxicological and environmental information and include a comprehensive list of a dozen or so hazard criteria. Among these are carcinogenicity, reproductive toxicity, endocrine activity, persistence, aquatic toxicity, etc. Each criterion is evaluated from existing data or models of chemical properties and assigned a value of High, Moderate or Low (and for some endpoints Very High or Very Low). For a criterion such as reproductive toxicity, a value of High indicates high toxicity relative to US EPA established ranges (see the DfE alternatives assessment criteria available here).

Utilization of BPS versus BPA in Thermal Paper and Exposure Potential

In 2010, an Appleton fact sheet announced a plan to incorporate fine red fibers (similar to currency paper) to help consumers distinguish their BPS-containing thermal paper from other papers. If this plan was carried through, it may offer consumers an opportunity to identify BPS-containing products from Appleton. No other information on market penetration of BPS-papers was available for the US. Anecdotal reports suggest that BPS has also been used in Japan as a BPA-replacement.

Two recent publications (see references below) have examined the occurrence of and exposure to BPS in paper products. Consistent with earlier research on BPA, researchers found that BPS has found its way into newspaper, food contact papers and paper towels, among other products probably via the recycling process. The spread to other paper products is likely exacerbated by BPS’s higher persistence. Like BPA, BPS has been identified in urine samples from US subjects. A brief summary of this research can be found in a publically accessible C&E News article or in the original research by Liao et al. (see References below).

Summary

There is no simple way to describe the overall hazard of BPS relative to BPA. The DfE preliminary data confirm that BPS appears to exhibit somewhat less potent endocrine activity versus BPA, however chemicals pose potential hazards beyond endocrine activity. In the comprehensive list of hazard criteria reviewed by DfE, the picture is complex, with some hazards higher for BPS with others higher for BPA. No clear “safe” alternative has emerged from the EPA DfE work (in progress).

Recent research (Spring 2012) shows that consumers are being exposed to BPS. As with BPA, BPS is moving beyond thermal paper into a wider range of paper products likely via the paper recycling process.

References

1. Appleton’s fact sheet on their replacement of BPA with BPS: http://www.appletonideas.com/Appleton/jsps/pdf/thermal/BPA_Statement.pdf
2. Appleton’s fact sheet on red fibers in BPS-containing papers: http://www.appletonideas.com/pdf/Appleton%20Red%20Fibers%20Receipt%20News%20Release%2011-08-10.pdf
3. EPA’s BPA Alternatives in Thermal Paper Partnership” http://www.epa.gov/dfe/pubs/projects/bpa/index.htm
4. EPA’s alternatives assessment methodology: http://www.epa.gov/dfe/alternative_assessments.html
5. EPA’s assessment criteria for hazard evaluation: http://www.epa.gov/dfe/alternative_assessments.html
6. C&E News article on recent publications regarding BPS in thermal paper: http://cen.acs.org/articles/90/web/2012/05/BPA-Replacement-Permeates-Paper-Products.html
7. Liao et al., Bisphenol S, a New Bisphenol Analogue, in Paper Products and Currency Bills and Its Association with Bisphenol A Residues, ES&T 2012, http://pubs.acs.org/doi/abs/10.1021/es300876n
8. Liao et al., Bisphenol S in Urine from the United States and Seven Asian Countries: Occurrence and Human Exposures, ES&T 2012, http://pubs.acs.org/doi/abs/10.1021/es301334j

Request by: Local Hazardous Waste Management Program in King County

This question was posed from the perspective of local government hazardous waste programs for households or small businesses. The research led to awareness of potential opportunities in other related local government programs and commercial recycling services. Through discussions, sharing of ideas, and online research, the following waste materials were identified as possible materials or activities that could impact greenhouse gas (GHG) emissions if not managed properly.

• Foams blown with chlorofluorocarbons (CFCs), potent GHGs, or with carbon dioxide (CO2), could possibly be released during automotive recycling (from seat cushions), from furniture and mattress foams, from insulation in appliances, building insulation, recreational goods, piping insulation, and other products.
• Refrigerants from appliance recycling (notably refrigerators and air conditioners), that still contain historical CFC or currently approved hydrochlorofluorocarbons (HCFC) refrigerants,
• Older, and/or energy-inefficient appliances.
• Food waste and recyclables.

Programs or activities that county or municipal government could consider to address certain wastes and also reduce greenhouse gas releases are listed below:

• Provide education and assistance for auto recyclers. Auto recyclers must comply with Section 609 Refrigerant Recycling Rule refrigerant recovery laws and prohibit venting during refrigerant recovery and disposal from motor vehicle air conditioners (MVAC).
• Provide education and assistance for appliance recyclers. Appliance recyclers must meet Section 608 Refrigerant Recycling Rule of the Clean Air Act, and prohibit venting during refrigerant recovery and disposal from refrigerators, freezers, air conditioners, etc.
• Ensure recyclers involved in the final disposal of appliances are certified (with their EPA Regional Office) and they have obtained and are properly using EPA certified refrigerant recovery equipment.
• Participate in and utilize assistance from the U.S. EPA’s Responsible Appliance Disposal Program.
• Research whether GHG releases are a concern from foam recycling activities (from furniture, mattresses,
  autos, insulation in appliances, etc.), and if so, assist foam recyclers in ways to minimize releases.
• Encourage early retirement, and proper recycling (including refrigerant recovery) of older, energy-inefficient
  appliances that could be replaced with much higher-efficiency units. In addition, discourage donations of older
  equipment, and elimination of secondary refrigerator or freezer units within households. Energy-efficiency
  messaging can be leveraged with local utility involvement.
• Encourage organizational and community/citizen purchasing of non-HCFC blown foam-type products.
• Encourage organizational and community/citizen maximization of composting and recycling, to reduce landfill
  methane generation and/or reduce the amount of energy required to manufacture new products.

Additional Examples, Information and Resources

HCFC and CFC-Blown Foams:

Chlorofluorocarbons (CFCs) and HCFCs have high global warming potential, meaning they are hundreds to thousands of times stronger GHG emitters, per unit of mass, than carbon dioxide.

Traditionally, the most commonly used foam blowing agents were non-flammable, non-toxic CFC’s, such as the well known refrigerants CFC-11 and CFC-12, which are considered “first generation” blowing agents. CFC use was banned in the U.S. because of their ozone depleting potential. No studies were identified that determined the rate of dissipation of CFCs from foam products.

Since the early 1990′s, these were mostly replaced by substances with less ozone depleting potential, the HCFCs, including HCFC-141b and HCFC-22. Then in early 2005, the U.S. Environmental Protection Administration (EPA) issued a ban on HCFC-141b as a blowing agent, regulating both the use and import of foam systems containing HCFC-141b. A complete phase-out of HCFCs, regulated by the EPA (and as a party to the Montreal Protocol) is set for 2030, with scaled back phase-out which started in 2010. While CO2 and other chemicals have or are replacing some HCFC blowing agents, there are still millions and millions of legacy foam goods in use that were blown with CFCs or HCFCs.

Refrigerants:

Autos and old appliances contain refrigerants, and that is one of the reasons it is very important to offer refrigerator and appliance recycling services, to ensure these items are properly recycled, and fluids, toxic materials, and other items are managed and properly disposed of. The Responsible Appliance Disposal Program of the EPA has successfully reduced greenhouse gas emissions (and ozone depleting substance releases). Their accomplishments and reported avoidance of GHG emissions by participating partners and affiliates, by recovery of refrigerant and foam-blowing agent from appliances is 1.41 MMTCO2e for 2010.

What happens to CFCs removed from end-of-life appliances and autos?

Older cars and some older equipment still need CFCs for maintenance and since it is no longer produced-the only source for this market is reclaimed CFC.

EPA safe disposal practices require that the collected CFC and HCFC refrigerant must be reclaimed per EPA regulations (Section 608 Refrigerant Recycling Rule), and only by EPA-certified reclaimers. One exception for direct re-use of refrigerant is if it was removed from a MVAC, and will ONLY be used in another MVAC.

Additionally, voluntary carbon markets buy it and destroy it to gain carbon offsets; this is a growing practice because of the large GHG impact. A description of how this works can be found from Blue Source.

Retiring Inefficient and Secondary/Multiple Appliances

While counties or municipalities typically encourage recycling, they should consider an exception for old appliances. Currently, many utilities and others distribute a message akin to, “Retire old appliances and replace with energy-efficient models.” This practice saves energy (and greenhouse gas emissions). For instance, The Edison Institute for Electric Efficiency – at “Jump-Starting your EE Portfolio” recommends early retirement of inefficient appliances, and elimination of secondary refrigerators and freezers. The Los Angeles Department of Water and Power offers a Low Income Refrigerator Exchange Program to certain customers encouraging them to replace their old, inefficient refrigerators with a new energy saving model.

The Responsible Appliance Disposal Program also promotes early appliance retirement, and their partners report a reduced energy consumption of 2.17 MMTCO2e in 2010, from these efforts.

Compost and Recycling

In landfills, compostable materials undergo anaerobic decomposition and produce significant quantities of methane, up to 80% of which is not captured by a landfill gas system. Composting, on the other hand, is a fundamentally aerobic process, and well managed, aerobic compost facilities produce little, if any methane.

Recycling avoids greenhouse gas emissions from many life cycle aspects, from extraction (which is avoided through recycling), through manufacturing. For more information on these topics, see EPA’s May 2011 report., “Reducing Greenhouse Gas Emissions Through Recycling and Composting.”

The EPA also has a Waste Reduction Model (WARM) calculator, developed to assist solid waste managers in determining the GHG impacts of their waste management practices. WARM compares GHG and energy impacts of landfilling, recycling, incineration, composting, and source reduction.

Conclusion

Certain local government waste management activities contribute to greenhouse gas emissions, which may be minimized with government oversight, management, and messaging to business and citizens. The message of greenhouse gas emission reductions or avoidance, along with the other environmental impacts of these wastes, may provide additional incentive or encouragement to ensure goods and wastes are properly disposed of.