Submission Number: 00323
Received: 12/10/2010 9:56:14 PM
Commenter: Ramani Narayan
Organization: Michigan State University
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
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I offer the following comments on the “compostable claims”. Appendix 1 provides a short synopsis of my credentials and expertise.
The FTC proposes to retain the language in the 1998 guide, except to qualify “timely manner” There is no issue with the language. However, problem arises from the statement that the Commission does not propose referencing or recognizing the ASTM standards (D6400, D6800) for substantiating compostable claims. The commission indicates that commenter’s did not explain why these protocols would substantiate compostable claims and thereby meet consumers’ expectations about compostable products. The FTC concluded that these Standards do not provide the scientific substantiation for compostable claims. I trust this document provides a fresh look at the importance and need for these Standards [see Appendix 2].
ASTM D6400 and D6868 standards can substantiate compostable claims in that products meeting these Standards would be completely utilized (biodegradable) by the microbes present in compost in the time period of 180 days or less. The product is transported into the microbial cells where they are oxidized to CO2, releasing energy for the microbial life processes. At the end of the compost period there is no compostable product remaining because they become part of the microorganisms. The Standard requires all of the substrate carbon to be consumed by the microorganisms leaving no persistent or toxic residue [Appendix 3 and 4 introduces the science of composting]
I would respectfully submit that this is in line with consumers expectations about compostable products being completely removed (biodegraded) from the disposal environment with the formation of compost. If the Commission chooses not to recognize or reference the ASTM standards, then it needs to provide guidance on scientific substantiation. Otherwise, the area is open to misleading claims. Example:
Company A makes polystyrene plastic in a brownish soil color, with an additive that makes it friable and “breakdown” into tiny brown fragments, indistinguishable from the compost material under the mechanical operations of composting. Technically, it has now become a “part of the compost”. Company A has met the FTC requirement of a compostable claim. However, those indistinguishable, invisible fragments of plastic are still there (persistent organic pollutants, POP). When the compost is land applied, these POP’s can migrate to the water table and other ecosystems where it absorbs and concentrate toxins and transport it up the food chain causing environmental and human health risks. This has been documented in major peer reviewed journal publications (Appendix 5).
This product will not qualify if ASTM D6400 is in place because the polystyrene fragments will not be consumed by the compost microorganisms. There is a serious misperception that compostable products is somehow transformed into compost because it has entered into the composting process, and broken down into small indistinguishable and even invisible fragments. As pointed out earlier, these have potentially serious human health and environmental risks. Therefore, compostable products must demonstrate completely utilization by compost microorganisms, and ASTM D6400 allows for that evaluation. [See Appendix 4 composting process]
ASTM D6400 is in harmony with EN 13432 (European standard) and ISO 17055. Products meeting these standards have been safely and efficaciously composted world wide with no problems for several years.
The FTC raised the issue of the validity of laboratory scale testing vis-à-vis real world composting environment. ASTM’s Institute for Standards Research (ISR) conducted such a study. The conclusion was that laboratory scale test was more conservative than pilot-scale tests that, in turn, were more conservative than the full-scale tests. So products that meet D6400 specifications would readily compost in real world systems [Appendix 6]