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BPI clarifies standards statement by oxo-bio industry

Mojo_letter.jpgIn response to a story first reported by FoodProductionDaily.com and cited by GreenerPackage.com (see “Oxo-bio association defends environmental claims”) Steven Mojo, executive director of the Biodegradable Products Institute (BPI), sent a letter to the publications to clarify some information cited by Gerald Scott, Professor Emeritus in Chemistry and Polymer Science of Aston University and chairman of the Oxo-Biodegradable Plastics Association (OPA) on ASTM D6954.

Indicative of the furious state of debate surrounding oxo-biodegradability, Scott’s comments were a response to a position paper published by European Bioplastics (see “European Bioplastics distances itself from ‘oxo-bio’ industry.”)
in which it questioned the claims of the oxo-bio industry.

The full content of Mojo’s letter follows:

August 11, 2009

Rory Harrington—FoodProductionDaily.com

Re: “Oxo-bio industry says product claims are valid”

Dear Ms. Harrington:
This note is in response to the article originally published in FoodProductionDaily.com on August 4, 2009 and reported in GreenerPackage.com, regarding Dr. Scott’s comments on ASTM D6954. While his comments are partially correct, Dr. Scott’s interpretation of the document is incorrect.

As background, I collaborated with Graham Swift (a former Board Member of EPI, an oxo additive supplier) to create this standard, along with other members of the ASTM sub-committee D20.96. We worked for 2-3 years to create this document, which is titled:
• “Standard Guide for Exposing and Testing Plastics that Degrade in the Environment by a Combination of Oxidation and Biodegradation.”

What is important to recognize is that this document is a “Standard Guide” and not a “Standard Specification.” While this document is a recognized ASTM Standard, as a guide, ASTM D6954 does not contain any pass/fail criteria, as are found in specifications such as ASTM D6400 or the CEN Norm, EN 13432. The definitions in the ASTM Form and Style Guide provide insight into the differences between these two types of documents:
• “guide, n—a compendium of information or series of options that does not recommend a specific course of action. DISCUSSION—A guide increases the awareness of information and approaches in a given subject area.”
• “specification, n—an explicit set of requirements to be satisfied by a material, product, system or service. DISCUSSION—Examples of specifications include, but are not limited to, requirements for; physical, mechanical, or chemical properties, and safety, quality, or performance criteria. A specification identifies the test methods for determining whether each of the requirements is satisfied.”

The intended goal of ASTM D6954 was to provide a set of directions for suppliers that were looking for ways to generate and report data (in a consistent format) demonstrating that their additives would in fact foster biodegradation, as claimed. This is clearly stated in the Scope of the Guide:

“This guide provides a framework or road map to compare and rank the controlled laboratory rates of degradation and degree of physical property losses of polymers by thermal and photooxidation processes as well as the biodegradation and ecological impacts in defined applications and disposal environments after degradation.”

The 60% criteria that Dr. Scott refers to is not a “pass/fail” threshold but rather the point after which the testing may be stopped and reported. This criteria was intended to prevent manufacturers from achieving very low levels of conversion to carbon dioxide or methane and then reporting on material performance. Below is the test from Section 6:

6.6.1 “For products consisting of a single polymer (homopolymers or random copolymers), 60% of the organic carbon must be converted to carbon dioxide before ending the test, and the gel content generated in Tier 1 must be no higher than 10%.
NOTE 7—Testing may be continued to determine better the length of time the materials will take to biodegrade.”

If this section is confusing to the additive suppliers, it will be revised in the next update of this standard, which is due shortly.

As stated previously the goal of ASTM D6954 was to provide suppliers a method for generating and PRESENTING data from which the scientific community and customers could draw their own conclusion.

What is disappointing is that so little data has been reported since ASTM D6954 was created. For example, no data has ever been shown to support claims like:
• “With Perf Go Green, In 2 years, 1 bag leaves nothing harmful behind, Nothing”
• “Reverte™ - which when added to the PET plastic resins at the manufacturing stage of bottles, will cause the finished PET bottle to oxo-biodegrade after a specifically programmed shelf life – in landfills/streams/rivers etc.” (Planet Green Bottle)

Additives to traditional resins to promote biodegradation may well have value in specific applications and disposal pathways. Until the community of additive suppliers correctly uses documents, such as ASTM D6954, to generate and publicly report data, their far reaching and unsupported claims of “biodegradability” will continue to be met with skepticism.

Regards
Steven Mojo
BPI Executive Director

Comments: 3

This final "statement" does show that the debate has gone completely wrong.

I like to quote the Article in FoodProductionDaily by Rory Harrington, 03-Aug-2009: "Bioplastics must be more than green to deliver long-term growth" and the study called “Growing Tomorrow’s Green Materials.” The report concludes: “Consumer concerns about conventional polymers will continue to rise, but economic issues will be the primary drivers of green materials’ adoption by corporations and consumers alike.”

Bioplastic actors should understand that you can't make standards or norms and force the market into the use of some technology unless the economic issues, low price, etc. are being fulfilled. Composting is not the final solution; it is just one way to define normal biodegradation.

Admit it Steve – Professor Scott has burst your bubble! For years Steve Mojo has been telling us that the Standards for compostable plastics (EN13432, ASTM D6400, ISO17088 etc.) are the only Standards for testing biodegradable plastic. Prof. Scott has made it clear (www.biodeg.org) that this is not the case. He is one of the world’s most distinguished polymer scientists, and if he is satisfied that oxo-bio plastic is fully biodegradable that’s good enough for me.

Prof. Scott indentifies ASTM D6954, as the appropriate Standard Guide for oxo-biodegradation. Faced with this disaster Steve tries to dismiss 6954 by claiming it is not a “Standard Specification”. Prof Scott says that a Standard Specification is not relevant except for specific applications, and points out that if 60% mineralisation is not achieved, the 6954 test cannot be completed. If that’s not a pass/fail criterion, I don’t know what is. It is not confusing and does not need “clarification” – especially not by Mojo’s organisation.

Even the name of Steve’s organisation is misleading. “Biodegradable Products Institute” – sounds official and independent doesn’t it? In fact it’s a trade association. It is certainly not independent, as it exists to promote the interests of the hydro-biodegradable or “compostable” plastics industry. Please Steve, stop trying to manipulate the standards system, and stick to selling your compostable plastic on its merits - if it has any (though as Prof. Scott points out, it is useless even in compost).

Here are two interesting recent news items related to this debate. It seems to be leaning more toward rational, science-based claims:

1.More questions raised about oxo-degradable claims
By Mike Verespej, Plastics News
Posted 29 January 2010 10:08 am GMT
"The Bioplastics Council of the US-based Society of the Plastics Industry (SPI) has joined the growing number of voices questioning the scientific validity of biodegradability claims made by producers of oxo-degradable and oxo-biodegradable products."

http://www.prw.com/subscriber/headlines2.html?cat=1&id=1264759707

2. from the Federal Trade Commission in December

"... the Commission is reviewing its Guides for the Use of Environmental Marketing Claims, 16 C.F.R. Part 260, including the section on degradable claims. While we have not completed this review, Commission staff has found no evidence (e.g., testing protocols,
public comments, or articles) persuasively arguing that products destined for landfills, incinerators, or recycling centers will totally decompose in a short period of time consistent with consumer expectations of unqualified degradable claims. Thus, it appears that unqualified degradable claims are likely to be deceptive for items so disposed. The Commission may include guidance to this effect in any future announcement relating to the Green Guides review.

http://www.ftc.gov/os/adjpro/d9336/091218dynaletter.pdf

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