Submission Number: 00029
Received: 10/27/2010 11:33:47 AM
Commenter: Robert POCIUS
Organization: GRAYROCKS PACKAGING GROUP
State: Outside the United States
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
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Certifications by B.P.I. are not unbiased as this was founded by Cargill and Innovia to promote their products only. Certifications should only be allowed where the institution has no ties to the product even indirectly.
Degradable should not be limited to products that take only one year to degrade. Various conditions and gauges and types of material do take longer. Alaska vs Florida for example. 1.0 mil vs 20.0 mil., etc.
Dr. Paolo Broglio, Prof. of Environmental Biology, University of Milan, Italy, is one of the world's leading experts in this field. He states that Organic Additive Technology, produced by ECM in USA is the only viable option currently available. It does not cause damage to the Rainforests, use up valuable farmland, or cause increases in world hunger. It is easily manufactured and processed and can be recycled with mainstream plastics. It takes from 1-5 years to degrade but this is far better than normal plastics and should not be eliminated from the marketplace by the restrictions proposed.
Compostable - PLA is only compostable in a highly controlled atmosphere with high heats and moisture along with rich microbial activity which can only be found in a Commercial Compost. Of the 144 commercial composts identified by the B.P.I. very few will take PLA.
most want material that decomposes in 3 weeks. PLA @ 0.8 mil. takes 14 weeks, @ 2.0 mil. perhaps 30 weeks. This is why many of them placed ads in local papers to tell residents not to put PLA in the green bins. They only have to filter it out and take it to a landfill.
The FTC issued a guide to prevent Greenwashing where it was stated that a product's claims must be available to at least 60% of Communities to avoid being labelled a greenwasher. There are over 30,000 communities in the US but only 144 commercial composters.
even if they all took PLA, that is still less than 0.5%. Not 60 %, not even half of a percent. Yet the ads show PLA film being buried in the cold ground and a flower pops up. This leads people to believe in miracles.
Carbon Offsets - When large companies can make misleading claims as to their Carbon footprint by buying up land for Carbon Offsets , while continuing to use up to 90 times as much water and more petroleum energy that regular plastic, this is very misleading and bad for the planet. PLA is the major offender in this.
There are few options for us to choose from at present. We should not destroy some of the most promising technology by following the biased advice of the largest competitors.