Submission Number: 00113
Received: 12/2/2010 11:56:54 PM
Commenter: Cynthia Beal
Organization: Natural Burial Company
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
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Please add "cemetery" to the sentence "For solid waste products other than those destined for landfills, incinerators, _________(cemeteries) or recycling facilities, the proposal clarifies that the “reasonably short period of time” for complete decomposition is no more than one year after customary disposal.
We produce, market and sell biodegradable coffins and urns ( SEE ATTACHED - see also http://funerals.naturalburialcompany.com ) - and we educate the public on the options of using these products to replace the burial of metal, polyester, and other non-degradables in our nation's cemeteries.
The average interment period for a coffin or urn in a cemetery in the US is currently indefinite and presumed perpetual. We anticipate that eventually the interment period will be limited, as is done in the UK and Europe, perhaps to a period of 15-75 years, replicating what is practiced there, but it is unlikely that cemeteries in the foreseeable future will permit the re-use of grave spaces within a single year. Therefore we think that our ability to market a coffin or urn as "biodegradable" should not require decomposition within a one-year time frame.
To avoid being in conflict with the law, we would like to see cemeteries included in the category of disposition options that can exceed the one year time frame as 1) consumers are not relying on the compostability of the product in order to engage in reusing the by-product of the original item in one year or less, 2) the official term for the placement of human remains is "final disposition" - i.e., permanent disposal - and most closely replicates a managed landfill, and 3) some of the materials used in biodegradable coffins - i.e., hardwoods, even if they are sustainably produced and harvested, and incidental fasteners such as staples and screws that may comprise less than 1/1000th of the overall mass of the product - will not completely biodegrade in cemeteries within a year.
We think that consumers will NOT be misled by the term "biodegradable" if used to describe a coffin, shroud, or an ash-burial urn because they are not currently expecting the coffin or urn material to decompose in less than a year.
Additionally, if necessary, we would support a time frame for the decomposition of coffins and urns that make the biodegradable claim to be a time period of 25 years in proper soil conditions. This is still an arbitrary rate imposed on the product, however, and simply a best-guess based on our experience with composting in organic agriculture.
We realize that cemeteries are a largely unexamined part of the "green" movement and want to register our interest in collaborating with the FTC to ensure that marketing claims are accurate, while at the same time highlighting the unique and usually unexamined conditions that cemeteries face as distinct from other arenas of activity where the public's concerns about claims are warranted.
As a company concerned with making only substantiated claims, yet also introducing new concepts to the conventional marketplace, we agree that the arena is ripe for misunderstanding and welcome this opportunity to comment.
We are actively pursuing the establishment of decomposition trials in conjunction with Oregon State University in Corvallis, Oregon and the public non-profit natural burial research organization called Natural End. Any encouragement you can supply this team as to the usefulness of such research will be beneficial in gathering support for it and if you plan to convene a sub-committee to provide further input on the most practical and useful shape of marketing standards for green burial claims we will be happy to participate.
Thank you for considering the merits of our input.
Natural Burial Company