Members of the Food Packaging Forum (FPF) submitted feedback highlighting aspects of food packaging and chemical safety for the US Environmental Protection Agency (EPA) to consider during development of the draft national strategy to prevent plastic pollution. A shortened version of the comment follows.
Plastic packaging makes up 28% of municipal solid waste in the US (according to EPA figures from 2018), and food packaging strongly contributes to plastic pollution (FPF reported). The creation of a plastics strategy is therefore an important opportunity for effective measures to curtail problematic food packaging.
FPF research has demonstrated 509 chemicals in repeat-use FCMs made of plastic, and 853 chemicals in recycled PET FCMs (FPF reported). Some of these chemicals and chemical families are known to create long term effects that add up to potentially billions of dollars in public health costs (FPF reported also here).
Supporting reuse
The EPA can assist reuse programs across the country by providing guidance to states and municipalities attempting to incorporate these practices into daily life. There are two areas the EPA in particular may be able to advise on – health codes and reuse standards.
Some restaurants are concerned about accepting containers from customers due to potential microbial and other contamination. The EPA could work with or encourage US Food and Drug Administration (FDA) to create clear guidelines to lower health and safety concerns – the state of Oregon is already working on SB 545, which enables and provides guidance for accepting refillable containers at restaurants.
Supporting reuse programs would additionally lead to reducing microplastics that form during normal use of packaging which end up in food, drinks, and the environment (FPF reported). Micro- nanoplastics are also created during the mechanical recycling process.
Government spending decisions could be one component of reducing demand for single-use materials. Good systems require robust infrastructure. The government of France created a national policy focusing on reuse which included a 50 million Euro fund to support reuse projects and related infrastructure in the country.
International regulation
The United States is one of the largest plastic waste producers per capita (FPF reported). If the EPA wishes to “address environmental justice and climate change” one effective way to do so is to limit plastic production from fossil carbon feedstock by clearly supporting a robust and binding treaty before and during the upcoming INC-3 meeting in Nairobi, Kenya (FPF reported). Additionally, the United States government is already a signatory to the Basel Convention, but it has not been ratified in congress to become a Party to the convention (FPF reported). EPA could lend its support to continued federal actions such as ratifying the Basel Convention.
Defining terms
Compostable: The Strategy currently lacks a clear statement that compostable packaging needs to be free of hazardous chemicals to prevent negative impacts on human and environmental health. Additionally, the EPA currently states that decomposition of a plastic must “occur at a rate similar to the other elements of the material being composted (within 6 months).” But this definition is insufficient as it 1) is limited to industrial composting – which confuses consumers, and 2) industrial composting has a turnover rate of 4-12 weeks – which means that even plastics that fit this definition can still be problematic. To avoid the presence of packaging waste and/or its fragments in the finished compost, the time frame and degradation conditions (e.g., temperature, moisture) need to be aligned with established commercial practices.
There are multiple instances of packaging labeled with some decomposition level that when tested does not pass (FPF reported also here). It needs to be the obligation of the compostable packaging manufacturer to provide information on complete decomposition and safety before the product is placed on the market.
Inert: While most food contact materials on the market have overall migration levels well below the current threshold, there is a lack of robust analytical approaches with low detection limits that are suitable for routine measurements and enforcement. Therefore, new approaches are needed for both defining and measuring inertness that are sufficiently protective of human health. The EPA could make an important contribution to this issue by providing a definition of inertness for reusable food packaging, and by investing into research and development on this matter.
Reference
Lindsey Parkinson, et al. (June 2023). “FPF comment on EPA Draft National Strategy to Prevent Plastic Pollution.” EPA
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EPA (2023). “Draft national strategy to prevent plastic pollution.”
