Take Action for Reuse: Submit Comments to the EPA
In light of global plastics treaty negotiations—and thanks to years of advocacy from dedicated reuse solutioneers like you—awareness of the plastic pollution crisis at the federal level is rapidly increasing. This spring, the EPA released a Draft National Strategy to Prevent Plastic Pollution—part of a series of EPA plans centered around “building a circular economy for all.” The open comment period ends July 31st.
We are encouraged to see such movement at the federal level, and there are several worthy elements in this draft strategy. However, there is also room for improvement, especially when it comes to emphasizing reuse as a solution to plastic pollution.
This Plastic Free July, we have a huge opportunity to make our voices heard by the EPA. This is our moment to bring home the message that it’s not just single-use plastic, it’s single-use itself that’s driving our throw-away economy.
We encourage you to submit your comments to the EPA by July 31st. To help provide some guidance, we’ve outlined the comments Upstream is submitting below. Feel free to adapt these for your own use. If you’d like some more resources and support, reach out to us at info@upstreamsolutions.org.
Background
In our current throw-away economy, roughly 15% of wood harvested, 22% of aluminum mined, 36% of plastic created, and half of glass produced goes primarily to making single-use packaging that is consumed in a matter of minutes before it gets trashed, recycled, or littered. This system perpetuates the unnecessary extraction of precious natural resources on the front end while creating significant amounts of waste and pollution on the back end.
Too often, the impacts of disposability disproportionately burden people of color and low-income communities who live on the fence lines of extraction, manufacturing, and disposal. Mining hydrocarbons, metals, and trees from the earth and turning them into throw-away packaging pollutes air, water, and habitat with accompanying impacts on human and community health.
We urge the EPA to expand the scope of this strategy beyond plastics. Substituting single-use plastic for other single-use materials will not solve the problems of escaped trash entering the environment, pollution harming communities, or climate change. The challenge we face is bigger than single-use plastic: it’s “single-use” itself.
Bottom line: While we applaud the EPA’s objectives to “support the United States’ shift to a circular approach that is restorative or regenerative by design, enables resources to maintain their highest value for as long as possible, and aims to eliminate waste in the management of plastic products,” we strongly encourage the EPA to place a greater emphasis on waste prevention and reuse throughout the strategy, rather than downstream waste management and recycling.
Most important actions EPA should take
Invest in community-scale reuse to continue supporting the growing local reuse movement, by prioritizing development of reuse systems and capacity across all EPA grant programs—especially over recycling and other downstream/waste management solutions. It is time to align federal investments with the federal waste prevention hierarchy.
Invest in the emerging reuse services sector to build and expand reuse capacity and support economic growth.
The federal government has a key role to play in bringing corporate stakeholders together from across the value chain—to build the corporate sector’s capacity for reuse—in coordination with other federal agencies through the new Interagency Policy Committee on Plastic Pollution. Be sure to engage with other leading organizations who are already bringing industry stakeholders together—including Upstream, the Ocean Plastics Leadership Network (OPLN), the U.S. Plastics Pact, Meridian Institute, the World Economic Forum, the World Wildlife Fund, and more.
Partner with expert organizations and research institutions to provide guidance to state agencies on how best to prioritize reuse in new and emerging laws—such as Extended Producer Responsibility (EPR) for packaging and updated Deposit Return Systems (DRS).
Coordinate with other federal agencies on improved tools and methodologies for measuring the impacts of waste prevention and reuse (i.e., better LCA parameters that account for the human health and toxicity impacts of various materials and the ecosystem impacts of materials escaping waste collection systems into the environment). And, the EPA and other federal agencies should contribute to improved international standards development and adoption.
Notes on other proposed actions
Upstream supports proposed Action B6—Explore ratification of the Basel Convention and encourage environmentally sound management of scrap and recyclables traded with other countries. The United States is woefully behind on ratification of the Basel Convention and this must be rectified to address our country’s role in the perpetuation of waste colonialism and global environmental racism.
We also support proposed Action A1—Reduce the production and consumption of single-use, unrecyclable, or frequently littered plastic products. The EPA should support the elimination of all unnecessary and problematic single-use materials (not limited to plastics), including all of the items identified by the US Plastics Pact.
We support the recommendation from Senator Jeff Merkeley (D-OR), Representative Lloyd Doggett (D-Austin), and their distinguished colleagues for the EPA to adopt an ambitious, time-bound procurement policy to phase out the use of single-use products. As these members of Congress noted, the General Services Administration has already taken a first step toward this outcome through its proposed rulemaking to reduce single-use plastics. We urge the EPA to demonstrate leadership among the federal agencies by establishing its own procurement policies to eliminate all single-use products and packaging.
Other key considerations
The following outlines our responses to questions posited in the EPA request.
What are potential unintended consequences of the proposed actions that could impact communities considered overburdened or vulnerable, such as shifts in production or management methods?
First and foremost, the U.S. must ensure a just transition to the new reuse economy so that all communities benefit and thrive.
Beware of regrettable single-use substitutes like bioplastics, compostables, and paper. It’s important to keep eyes on the prize of systems change toward the new reuse economy. We do not support proposed Action B3—Facilitate more effective composting and degradation of certified compostable products.
We urge caution when considering proposed actions such as C2—Improve water management to increase trash capture in waterways and stormwater/wastewater systems. These systems can harm aquatic ecosystems and are the least impactful approach to solving plastic pollution.
What key metrics and indicators should EPA use to measure progress in reducing plastic and other waste in waterways and oceans?
EPA already offers the Escaped Trash Assessment Protocol (ETAP) for measuring litter and debris, including in waterways. A demonstrated decrease in escaped debris of all material types as a result of local, state, or federal actions and policies to implement reuse will be helpful in further establishing the case for reuse.
However, the most important metrics in a circular economy are reduced demand for virgin materials and reduced manufacturing of single-use goods and packaging—coupled with reduced overall climate emissions and pollution. EPA should coordinate with other federal agencies on improved tools and methodologies for measuring the impacts of waste prevention and reuse. In particular, collaborate to develop new, improved tools such as expanded LCA parameters so that all stakeholders can confidently assess the benefits of the emerging circular economy, reinforcing why waste prevention and reuse have always been at the top of the waste hierarchy.
Additional key metrics for a circular economy include: a decrease in overall municipal solid waste generation; decreased human toxicity, pollution, and community health impacts from production and manufacturing through to end-of-life materials management; and job creation and other community health metrics.
Should specific types of plastic products be targeted for reduction or reuse in this strategy?
Key sectors to target for scaling reuse are foodservice, beverage, consumer packaged goods (CPG), and transport (both business-to-business and business-to-consumer).
Resources
For more, check out our Research Page