PROJECT SCOPE & STAKEHOLDER INVITATION FOR PARTICIPATION: New Green Seal Environmental Standard for Plastic Resin Film Bags (GS-45)

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1 March 19, 2008 PROJECT SCOPE & STAKEHOLDER INVITATION FOR PARTICIPATION: New Green Seal Environmental Standard for Plastic Resin Film Bags (GS-45) The scoping phase of the Green Seal Environmental Standard for Plastic Resin Film Bags (GS-45) has been completed. The standard is being developed to help consumers and purchasers identify environmentally-preferable products and services. The scoping process was intended to identify specific areas of the standard to be included. Comments were solicited on the scope of the standard revision from diverse stakeholders including producers, users and general interest groups. This document includes a summary of the comments received. By participating in Green Seal s standard setting process, the following organizations played an important role in Green Seal s effort to encourage the design, manufacture and end use of environmentally superior products. Individuals may have also contributed, but their names are not listed for anonymity. Their assistance and involvement is greatly appreciated. Comments received from these organizations: Berry Plastics Control, Inc. Maverick Enterprises Heritage Bag Comments (verbatim): Products in standard ("Scope") Our concentration is on one-time use polyethylene bags used for the transportation and storage of money. The banking industry has moved to one-time use bags over the last 15+ years from locking canvas bags as more of their customers became national and international concerns versus local or regional. Every retail chain store (restaurants, malls, grocery, drug, clothing, etc) use plastic bags of varying thicknesses (2.0mil - 7.0mil) for sending money via armored couriers to the banks cash vaults. It has become very costly and almost impossible for them to accept re-usable bags and incur the cost of mailing them back to the depositor. In like manner, banks ship money to their branches the same way. Although the volume of bags would not be on the scale of trash liners, they are much thicker, so the percentage of poly per bag is much higher. Many of the large banks are anxious to be good corporate citizens and are asking for degradeable films for the deposit bag programs. It is my desire that this be included in your standard. All ranges of industrial and consumer trash bags and can liners should be included in the standard. This ranges from 4-gallon to 60-gallon sizes and consists of garbage, wastebasket, kitchen, trash, and industrial can liners. In addition, the standard should include clear bags and recycling bags. Plastic sheeting, which is used for a variety of painting, repair and contractor purposes, should also be included in the standard since it is also available with recycled content and contains similar plastic resin as the plastic resin film bags. In addition to the product, where plastic resin bags are sold in inner chipboard packaging cartons, the inner carton should also be made of recycled content, namely 100% recycled paperboard.

2 Products in Standard Consideration for this part of the scope should consider general purpose institutional can liners and trash bags made of Low Density Polyethylene (LDPE), Linear Low Density Polyethylene (LLDPE) and/or High Density Polyethylene (HDPE) only. Both polyethylene and biobased liners are from very different materials and require different styles of production, therefore consideration for any type of Biobased or Biodegradable/Compostable bags should not be in this scope. These biobased or biodegradable/compostable bags and liners should have a separate set of requirements and meet specific standards such as defined by American Society for Testing and Materials (ASTM). Biodegradability or compostability should be included. The purpose of a product being called "green" is a very important issue today. San Francisco and other cities have stated that only biobased or paper bags are usable. A paper bag is a bigger threat to our environment than a regular plastic. Green Seal is a guide to green products and can educate consumers as to viable solutions. Recycling is a failure here in the US. We need new options.a compostable plastic is good, but only if it is near a composting facility that takes food scraps.they do not degrade in backyard composts.personally, I would not like corn based plastics to be included. Their use (as well as in ethanol) have resulted in higher food costs, pollution of aquifers and the Gulf of Mexico.Other options such as soybeans, sawgrasses, etc are more sustainable.i think a plastic that is landfill degradable, compostable, and recyclable is the answer to our society that throws everything in the trash. It should also includes tamper-evident deposit bags used by banks and armored couriers. These are made using LLDPE as well Relevant definitions for standard The definitions that are relevant to the standard should be the same terms used in the Federal Trade Commission guidelines. Important definitions to include in the standard are: "pre-consumer material," "post-consumer material," and "recycled content." Each of these definitions should mirror the definitions contained in the FTC Green Marketing Guidelines -- providing a uniform standard for manufacturers, retailers and consumers alike and ensuring a regulated standard for marketplace claims. Total recycled content should include the specific breakout of pre-consumer and post-consumer material. The definitions for "pre-consumer" material and "post-consumer" material should only include material that would otherwise be landfilled or incinerated. Similarly, terms such as "recyclable," "reusable," "degradable," "source reduced," "compostable," and "environmentally friendly" should follow the FTC green marketing guidelines and provide assurance that such claims are not false, invalid, misleading or misrepresented. Relevant Definitions for the Standard Proposed definitions would include: LDPE Low Density Polyethylene LLDPE Linear Low Density Polyethylene HDPE High Density Polyethylene Virgin Resin or Virgin Material Resin or Material for first time use Reprocessed Resin or Material Pre-consumer waste, Post industrial waste, in-plant scrap, etc. reprocessed into resin pellets for reuse Post Industrial Resin - Resin made from manufacturing process scrap that is either recycled into internal operations, or procured from outside vendors. PCR Post Consumer Resin Resin made from recycled plastic products diverted from the solid waste stream. This material is separated from solid waste and is obtained from MURF s or curbside or other recycle bins, or other post consumer gathering locations. Consumers could be industrial facilities, institutions or households. Plastic that is gathered after it has been utilized for its initial purpose when made with Virgin Resin 2

3 Examples: bottle caps, water bottles, grocery carry out bags, etc. Recycled Content amount of non-virgin resin included in the production of the product. Gauge thickness of bag, measured in mil (0.001 ) for LDPE and LLDPE and microns (micrometers) for HDPE. Standards should include ASTM certifications.a consumer looking for a green product can look for this.they should also give short explanations of the standards mean or a link so they can be defined. Everyone "assumes" that a compostable product will degrade in a landfill. That is not true.we should also label if the product is recyclable with mainstream plastics so those who do recycle will know whether or not to include it in the recycle bin. Biobased cannot be included as they will pollute recycled plastics as they do not blend with other plastics. It's like mixing oil and water. Product performance requirements Product Performance Requirements performance should be measured based upon 3 industry standard tests: Dart Drop Test (ASTM D1709) Measures grams of force by dropping a weighted dart from a specified distance until bag fails to prevent dart from passing through Elmendorf Tear Test (ASTM D1922) measures the average grams of force required to propagate a pre-existing tear in the plastic film, typically measured and reported in two directions: MD Tear Test (Machine Direction) Measurement of tear strength along the direction the bag was produced coming through the production machine TD Tear Test (Transverse Direction) Measurement of tear strength of the film perpendicular to the direction the bag was produced coming through the production machine Thickness measurement of the average gauge of the bags These tests are standard within the can liner industry. The performance measures would vary depending upon the thickness (gauge) of the bags as well as the bag raw material (I.E. LLDPE, HD, Repro or PCR). Performance testing and measurements should be accomplished by a facility that is familiar with thin plastic films. There are general testing facilities that do not have machines for testing thin plastic films and the measurements from more general machines may provide faulty measurements. Biodegradability Biodegradability Assuming this standard only addresses polyethylene bags, then biodegradability should be a non-issue. However, this section could include identification of any biobased or natural ingredients such as minerals, etc. added to the liners. In regards to biodegradability, this is a very important issue. However, one has to be careful in defining "biodegradability". ASTM 6400 states a plastic will compost in 180 days in a municipal or commercial compost. It will not degrade in a backyard compost or a landfill. It is not recyclable with mainstream plastics.i think biobased plastics that are certified ASTM 6400 should be certified "compostable under special conditions."oxy or oxo" degradables should not be considered for Green Seal consideration. They fall into pieces and leave heavy chemicals such as cadmium and cobalt. There is an additive that I use in my Green Film that is perfect for our disposable society. It is certified ASTM 5511 which states in will degrade in landfills.normal plastics take 400 years. This product enables the plastic to degrade in 1-5 years. It is also recyclable with mainstream plastics and will compost (meets the ASTM standard ). Prohibited additives 3

4 No added toxic inks or dyes should be allowed in the product. Prohibited additives The plastic film should be free of all toxic compounds and additives. This may be a concern for recycled plastic that has been exposed to such chemicals during its end use (rigid packaging, agricultural film). In addition, the state of California bans the use of heavy metals in all plastic packaging. They also require that bags meet the requirements of Proposition 65. Many facilities that incinerate plastic bags also require they be heavy metal free as described in the CONEG (Council of Northeast Governments) requirements for flexible packaging. Compostable bags have a specific set of elemental limits that vary by region (U.S., Canada, EU, Japan) No heavy metals should be allowed in any bags that could leach into the water or soil. There should be EPA certifications with all biodegradables and compostables proving that there are none present in the bags or film. Plastic resin code labeling Plastic Resin Code Labeling Bags produced from LDPE or LLDPE could be labeled 5, bags from HDPE could be labeled 2 Recycled content In order to encourage the use of recycled material and inspire manufacturing advances, Green Seal should set a standard at the level of recycled content that is doable today but also is at the leading edge. This will allow retailers, consumers and industrial/government users to know that the Green Seal standard is "state-of-the-art" rather than simply a "seal of approval." Green Seal should ensure that the standard represents a true environnmental improvement over the status quo product available in the marketplace. In order to be meaningful, the total recycled content needs to have a signficiant advantage over the typical plastic resin bag. In addition to removing material from entering the wastestream, the use of recycled content includes energy savings and greenhouse gas emissions savings that are meaningful to society. The level of recycled content needed to obtain Green Seal certification should be significant enough to provide those environmental benefits, even if those claims are not publicly noted in advertising or on packaging. Consumers and industrial/government users expect that a Green Seal product is the leading environmental product in the marketplace and Green Seal should set standards for plastic resin film bags that reflect that expectation. With this in mind, Green Seal should set a standard of a minimum of 75% total recycled content for opaque industrial bags and 60% total recycled content for consumer opaque bags. This distinction is necessary due to the standard gauges and uses in the marketplace. Each of these should also include a minimum of 10% post-consumer material. These recycled content standards are currently available in a variety of plastic bags sold through retail, institutional and government procurement channels. For clear bags and blue recycling bags, the standard should include 30% total recycled content, including a minimum of 10% post-consumer material. This level of recycled content for clear bags and blue recycling bags maintains the level of transparency needed in the bags to ensure that contents are truly recyclable while providing enough opaqueness to prevent pilferage. Communities using recycling bags, rather than bins, expect recycling bags to also have an environmental benefit and to contain recycled content. By setting a standard for recycled content in recycling bags, households will recognize the benefit of recycling bags and have a greater incentive to participate in 4

5 curbside recycling programs. In addition, additives that make up a small percentage of trash bag formulas, such as color concentrate and slip, should be counted as incidentals and not be included in the total recycled content tally and calculations that could be used for certification levels. Recycled Content This area could be considered to be three different areas 1. Post-industrial/reprocessed resin used in product 2. PCR used in product The difficulty with bags containing recycled content is the inconsistent performance of the bags caused by the variance of the PCR utilized in production. The performance testing would need to be changed significantly and the standards would have to be created with a much wider range for approval. In fact, because of the performance weakening caused by PCR, the State of California, the only state that requires PCR, does not require its use in bags of 0.7mil or less. The use of PCR to be an advantage to the environment is being questioned currently due to the additional energy and resources used to create the reprocessed resin and the fact that bags containing PCR many times must be nearly twice the thickness as virgin bags to maintain similar performance. This causes nearly twice as much plastic to be deposited into the landfill at the end of the product life cycle. I think that recycled content should not be a standard. It should be included as a description for the consumer looking for such a bag, but not as a requirement.recycled content in high enough perportions can weaken a bag. In 2002, only 6% of all plastic bags was recycled. Plastic waste is the most difficult and expensive component of the waste stream to recycle. According to the Department of Conservation, it costs about $750/ton. Recycling of plastic bags in the US is a failure. We need to look for other options.personally I recycle everything,but the US is a disposable society so making that a standard is a restriction of trade and promoting a concept that just doesn't work. Packaging All paperboard packaging should contain some recycled content. Paperboard/chipboard inner cartons should contain 100% recycled paperboard, including a minimum of 30% post-consumer fiber. Any packaging that is less than 100% should need to detail the specific percentages of pre-consumer and post-consumer waste. Any reference or claims regarding "recycled content" should be specific. Corrugated outer cartons should be exempt from specific recycled content minimums since it is important to ensure integrity of strength and shipping characteristics for the outer shipping units. Dye and coloring use Added toxic inks and dyes should not be allowed for Green Seal certification. Dye and Coloring Use Colors should not contain any heavy metals End-of-Life management End of Life Management no comment Energy consumption 5

6 Energy Consumption no comment Raw material considerations Raw Material Considerations Usage of the amount of resin or other ingredients such as colors and additives should be considered. Consideration should be given to minimizing bag thickness at a given performance level to minimize the bag s impact on the solid waste stream. Consideration should also be given to the use of non-petroleum based ingredients in production of the bags. Consideration should not be included for biobased bags.facts show that corn based plastics use more fossil fuels than polyethylene in their life cycle.please look at "How Green are Green Plastics", Scientific American Aug, 2002; Popular Science, Sept., 2007; and a report done by the Franklin Associates in December, 2007.This report states that HDPE milk containers consume less energy in their manufacture, produce less post-consumer waste, and generate fewer greenhouse gas emissions than containers made from corn-based PLA.(The Franklin Associates have prepared many reports for the EPA, so they are extremely credible.) The Environmental Defense Org. in Nov stated that PLA is creating more global warming than gasoline.there are plastics made with petroleum with additives that are both biodegradable and compostable. (This is not an oxy or oxo additive.) Manufacturing considerations Manufacturing Considerations Considerations could be percentage of scrap produced, efficiency of bag production, and environmental certifications by production facilities Consumer education and label requirements All recycled content claims should be specific and the percentages of total recycled content, preconsumer, and post-consumer material should be listed on the package. In addition, optional statements regarding the fact that material was diverted from the wastestream as well as the environmental benefit of recycling over virgin plastic should be allowed provided such statements are in compliance with the Federal Trade Commission guidelines and are not overstated, misleading or unsubstantiated. Consumer Education and Label Requirements Label information requirements should be: - Net weight of case - Approximate gauge of bags should be specific, not a range - Dimension of bag (Width x Length) - Other specific labeling requirements by customer and/or locality Optional verification claims Optional Verification Claims Any and all claims should be verified by a qualified 3rd party facility. Any claims should have the proof data available on the website or otherwise accessible to customers. This data should sufficiently provide objective proof of the claim. General comments General Comments o [---] has multiple testing results that we would offer to Green Seal to assist in determining the 6

7 performance measures for the different types and styles of bags. o [---] operates one of the largest and best equipped testing facilities in the industry. The facility, located in Atlanta, GA, is used as third party verification laboratory as well as a neutral testing facility for many different companies, including competitors and police investigators across the country. We would offer the use of this lab to Green Seal as a neutral facility for testing and to establish requirements as needed. o Plastic can liners are a unique category that is quite different than any other plastics category. Therefore it takes a special and carefully detailed plan to develop standards for these types of items. Please utilize all available expertise and knowledge to develop these standards. Institutional Can Liners should be able to achieve certification in one of three discrete ways: (1) Minimum Recycled Content To achieve certification a bag must have a minimum of 10% post consumer recycled content and a minimum of 30% total recycled content (e.g. 10% post consumer plus 20% post-industrial recycled content). The 10% post-consumer content meets current EPA guidelines. (2) Compostability To achieve certification the bag must meet ASTM standard (3) Source Reduction Source Reduction is and will continue to be the gold standard for Can Liner sustainability. Using less material to start with reduces the amount of waste heading to the landfill. There should be two source reduction options: a)bag Re-Sizing - To achieve certification the bag must show at least a 7% reduction in plastic used when compared to a standard bag. This reduction can be achieved via reductions in gauge, length, width or a combination of these factors. b)resin Substitution - To achieve certification the bag must show at least a 25% reduction in plastic used when compared to a standard bag. This reduction would be achieved by utilizing superior resins that offer excellent performance characteristics at lower gauges than conventional bags. Additional Requirements: The following additional requirements must also be met to receive certification under any of the above scenarios: (1) Packaging - The corrugated packaging of the bags should have a minimum of 30% post consumer recycled content and a minimum of 60% total recycled content. (2) Packaging Inks If the corrugated packaging is printed; only non-toxic inks can be used. (3) Printed Bags - If the bags are printed; only non-toxic inks can be used. We should be very clear about a bag's degradabilty. How does it degrade and where to safely dispose of the bag should be included as consumers get confused about these facts. We in the US do have little access to the limited number of composting centers that take back compostable bags.a compostable bag that is certified ASTM 6400 will not degrade in a backyard compost nor a landfill. It doesn't do any good to make a compostable bag that ends up in a landfill where it will not degrade.if a bag is landfill degradable it needs to be certified ASTM 5511.So we need to educate consumers and be very clear about what the bags capabilities are in disposal and recyclability. 7