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Pyrolysis & Gasification Exemption: A BIG Win for Local Communities

Image credit: book cover for “Evolution of a Movement” by Tracy E. Perkins.

By Stephen Lester.

In a major win for grassroots community groups throughout the country, the USEPA decided last week to withdraw its plan to relax clean air regulations applying to pyrolysis and gasification facilities. After receiving 170 comments mostly opposing the agency’s plan to relax its regulations, the EPA said that it needed more time to consider the many complex and significant comments it received. And while it’s being reviewed, the current Clean Air Act rules that apply to pyrolysis and gasification facilities will stay in place.

This mean that these processes will continue to be regulated on equal footing to incinerators, as they have been for nearly 30 years. Pyrolysis and gasification facilities are currently regulated under the Clean Air Act, and are required to meet strict emissions standards that include emissions monitoring and reporting requirements.

The EPA proposed changing the rules that applied to pyrolysis and gasification facilities during the Trump Administration following heavy lobbying from the plastics industry and the American Chemistry Council. The plastics industry has been pushing hard to get the agency to redefine what qualifies as an incinerator and to exclude pyrolysis and gasification facilities from this definition. Currently, these facilities are considered under the same rules that apply to incinerators. Had this change in policy been approved, there would be no air pollution rules or regulations that pyrolysis and gasification facilities would have to follow.

Over the past year or so, the American Chemistry Council has invested billions of dollars into projects that use pyrolysis and gasification to burn waste plastics. This investment is in lock step with the plastic industry that is looking for ways to address the growing quantities of plastic waste that is generated each year. In a report by the Organization for Economic Cooperation and Development (OECD), the annual production of plastic is expected to triple by 2060 to 1.23 billion metric tons yearly, while only a small portion (~9 percent) will actually be recycled.

The American Chemistry Council has also been working at the state level to pass legislation that redefines processes such as pyrolysis and gasification as non-waste. This is so that these facilities could be regulated as “recycling” facilities that manufacture a product, an energy, or a fuel than can be burned. In this way, these facilities do not have to meet the stringent air and water quality requirements that an incinerator has to meet. According to Inside Climate News, 24 states have currently passed laws that recognize these facilities as being manufacturing rather than waste management.

While this is a big win for the many grassroots groups, and statewide and national environmental groups that sent comments to EPA opposing this rule change, the plastics industry and its partners will not let this go easily. No doubt they will continue to push EPA to make this change. They have already invested too much in this effort. We need to continue to be vigilant in opposing efforts to relax the rules that apply to pyrolysis and gasification facilities. Congratulations to all who contributed to this effort!

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Reducing the Reuse of the Recycle Sign

By Hunter Marion.

In 2021, California passed a law restricting the use of the classic recycling symbol upon products that are not truly recyclable. Last May, this law, and substantial complaints over the years, triggered an official comment by the EPA against the Federal Trade Commission (FTC). This comment encouraged the FTC to update its Green Guides to regulate the symbol’s use more stringently amongst plastics companies.

At the heart of this issue, the EPA, several concerned environmental groups like Greenpeace and Beyond Plastics, and even the Biden Administration have found that the use of this symbol perpetuates plastic pollution and misleads consumers. This misleading stems from the linked usage of the recyclable symbol with “resin identification codes” (RIDs) on single-use plastics.

Simplified, RIDs range from 1 to 7, with 1-2 being plastics that are generally able to be successfully recycled, while plastics labelled 3-7 are instead trashed in landfills or incinerated. However, the general recycling populace usually knows nothing about these numbers, identifies the recycling symbol, and throws all their plastic into the same bin. Doing this creates a dramatic chokepoint for waste collection companies who must separate and sort the mixed plastics at their materials recovery facilities (MRFs). Consistently backed up and under pressure, a sizable portion of these plastics are not properly separated and are often dumped or burned.

While banning the recycling symbol for non-recyclable products would help cut down rampant waste and curtail decades of greenwashing, environmental advocates still push for the total reduction in plastics use by consumers entirely. Both Greenpeace and Beyond Plastics reported that in 2021 only 5-6 percent of the total plastic produced by the U.S. was effectively recycled. Over 400 million tons of plastic are produced every year, 42 million tons in the U.S. alone.

Greenpeace’s John Hocevar says that we “have to stop thinking of all this throwaway plastic as recyclable and treat it for what it is: a very problematic type of waste.” This should be the most important takeaway from this issue. Plastic, no matter how recyclable, is not a viable product that should be used on a mass scale. It should not be ubiquitous to almost every aspect of our lives. Instead, like Hocevar and Judith Enck from Beyond Plastics suggest, we should strive to distance ourselves from purchasing or using plastics in our everyday lives. Instead of getting fixated on the recycling portion, we should focus on the widescale reduction and, if possible, safe reuse of plastics rather than making more.

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Toxic Tuesdays

Polyvinyl Chloride

Toxic Tuesdays

CHEJ highlights several toxic chemicals and the communities fighting to keep their citizens safe from harm.

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Polyvinyl Chloride

Polyvinyl chloride, commonly known as “PVC” or “vinyl,” is the second largest commodity plastic in production in the world today, with an estimated 48.8 million tons produced worldwide in 2018. PVC is used in a wide range of products including pipes and tubing, school materials, product packaging, children’s toys, and several building materials.

PVC can safely be considered the worst plastic for our health and environment, as it releases dangerous chemicals that can cause cancer and other serious health effects from manufacture to disposal. The first problematic chemicals that can leach out of PVC products is phthalates. These are a group of industrial chemicals that are added to PVC to promote plasticity and flexibility. Because they are not chemically bound to PVC, these chemicals can leach out due to heat, pressure or simply time. Once they are out in the environment, they can enter our bodies and cause adverse health conditions such as hormone disruption, birth defects, infertility and asthma. Lead is another chemical that is commonly found in PVC. Lead exposure is especially dangerous for growing children, who can suffer from nervous system development problems and learning disabilities.

Aside from direct exposure to PVC, the manufacturing and disposal process of PVC can release harmful chemicals called dioxins. Dioxins are formed and released when PVC is burned (during disposal) or manufactured under high heat and pressure. They are a highly toxic group of chemicals that build up in the food chain, cause cancer and can harm the immune and reproductive systems. Their toxicity is of such concern that they have been targeted for global phase out by the Stockholm Convention on Persistent Organic Pollutants.

As mentioned previously, exposure to PVC through everyday consumer products can be significant. Children’s toys can be substantially bad offenders, although CHEJ’s PVC campaign of the late 2000s made a difference in removing a lot of PVC from the toy market. Other items that remain problematic are children’s backpacks, shower curtains, rain boots, raincoats, vinyl flooring and roofing, plastic food containers, and pet toys.

CHEJ helped develop a resolution from the American Public Health Association (APHA) – a policy statement that has the full backing of the organization – back in 2011. CHEJ was instrumental in convincing the APHA to endorse reducing PVC in facilities with vulnerable populations such as nursing homes and hospitals. This was a monumental statement from the premier public health organization in the country about the dangers of PVC.

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Toxic Tuesdays

Bisphenol A (BPA)

Toxic Tuesdays

CHEJ highlights several toxic chemicals and the communities fighting to keep their citizens safe from harm.

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Bisphenol A (BPA)

BPA stands for Bisphenol A and is a man-made chemical produced in large quantities for use primarily in the production of polycarbonate plastics. It is found in a large number of everyday products such as eyewear, water bottles, and epoxy resins that coat some metal food cans, bottle tops, and water supply pipes.

BPA is a concerning chemical because it is one of those compounds that is in almost everything we use or come in contact with. The National Health and Nutrition Examination Survey (NHANES III) conducted by the Centers for Disease Control and Prevention (CDC) between 2003 and 2004 found detectable levels of BPA in 93% of people sampled six years and older.

While air, dust, and water are possible sources of exposure, BPA in food and beverages is the main source of exposure for most people. BPA has been observed to leach into food from the internal epoxy resin coatings of canned foods. Other items that contain BPA which come in contact with food or drinking water such as polycarbonate eating utensils, food storage containers, and water bottles can also contaminate food with BPA.

Although research into the effects of BPA in humans is not conclusive, there is mounting evidence for classifying BPA as an endocrine-disrupting compound (EDC). EDCs affect human health by disrupt hormones during key developmental stages of growth. For this reason, they can cause many different adverse health outcomes including damage to sperm quality, reduced fertility, abnormalities in sex organs, early puberty, reduced immune function, and certain cancers. BPA, specifically, seems to mirror the hormone estrogen, and studies in animals have shown decreased levels of testosterone, atrophy of male genitalia, and fertility problems.

The National Resources Defense Council put together a few tips on how to avoid BPA products here. Given the uncertainty and potential severity of BPA’s health effects, it is a good idea to be proactive and avoid unnecessary exposures to it.

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Toxic Tuesdays

Artificial Christmas Tree

Toxic Tuesdays

CHEJ highlights several toxic chemicals and the communities fighting to keep their citizens safe from harm.

< Back to Toxic Tuesdays

Artificial Christmas Tree

It’s the Christmas season, and because real pine trees can be cumbersome and high maintenance, many families use artificial Christmas trees. While artificial trees seem like an easy and sustainable alternative, the materials they are made out of can pose health risks. Like many consumer products, artificial trees are often made with a type of plastic called polyvinyl chloride (PVC). PVC releases gases into the air that can cause dizziness and irritation to the eyes, nose, and lungs.

PVC is often treated with plasticizers to make it flexible, and the most common plasticizers are a class of chemicals call phthalates. Phthalates shed off of the plastic products they’re used in, released as gases into the air and dust onto surfaces. Exposure to phthalates in these forms is associated with diabetes, obesity, and reproductive disorders. It is particularly dangerous for the development of children’s brains and may cause permanent cognitive impairment, autistic behaviors, and ADHD.

PVC is also often treated with lead as a stabilizer. Over time this lead sheds off of the PVC, creating lead dust that can accumulate on the surfaces in your home. Inhalation or ingestion of lead is extremely dangerous. In adults it can lead to cardiovascular, reproductive, and kidney dysfunction. Like phthalates, lead exposure is particularly dangerous for children’s development – it can cause permanent neurological damage including sensory loss, learning disabilities, behavioral problems, and anxiety. Because of their small size, even small amounts of toxins that may be innocuous for adults can pose serious risks to children.

How much of a health risk are these PVC trees in the US? A study found that 50 million households use PVC trees and estimated that this means 57,500 children may be exposed to high lead levels because of these trees. Although it may seem like the health risks from artificial Christmas trees is low, because of the potential permanent effects on children’s development, families should avoid using artificial trees made with PVC. Through consumer education and advocacy campaigns, many companies explicitly advertise products as being free of PVCs, and artificial Christmas trees made with alternative materials are widely sold. If you are already using an artificial tree with PVC this year there are some ways to mitigate the risks: limit physical contact with the tree, avoid getting lead dust on presents by putting them some distance away from the tree, and don’t use a household vacuum to try to clean up lead dust as this will cause the lead particles to become airborne.

Merry Christmas and Happy New Year! We all deserve a safe and healthy holiday season free of toxic chemicals.

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Toxic Toys

Toxic Tuesdays

CHEJ highlights several toxic chemicals and the communities fighting to keep their citizens safe from harm.

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Toxic Toys

The holiday season often means more food, family, and shopping. As we look for gifts for our loved ones, we have never had more resources at our disposal to make sure we are making safe, healthy decisions. And even with advances in science and technology, many consumer products are still manufactured with toxic chemicals known to cause serious health problems like cancer, developmental delays, and reproductive defects. These harms are especially concerning when they involve children’s products. Because of the way children play, they are not only exposed to chemicals in their toys through inhalation and absorption, but through ingestion as well. And because of their size, small concentrations of chemicals can have significant effects on children’s bodies, even if those concentrations are deemed safe for adults. These chemicals can have permanent, devastating consequences on children’s developing tissues and organs, For instance, phthalates are a class of chemicals common in many plastic products including toys. Exposure to these chemicals is associated with problems in reproductive development as well as brain development, including ADHD, autistic behaviors, and cognitive impairment.

In some cases, agencies like the Food and Drug Administration have been slow to incorporate new scientific information into their assessments of chemicals. In other cases, agencies like the Environmental Protection Agency have weakened regulations and actions when companies use known toxins in their products. Through this bureaucratic sluggishness and active deregulation, the federal government has failed to ensure that consumer products are only made with safe materials.

Thankfully, there are consumer advocacy groups that investigate the chemicals in common products and educate the public so they can make informed purchasing decisions. For example, the Mind the Store campaign published a retailer report card in 2019 where they rated the overall safety of products from 43 common retailers. It allows people to learn about chemicals that are used in products from retailers in many different sectors including children’s products, apparel, groceries, electronics, beauty products, and furniture. To produce their safety rating for each retailer, Mind the Store used 14 criteria including transparency, oversight, accountability, third-party standards, and continuous improvement over time, and people can see how each retailer fares along each criterion. Similar information on harmful chemicals common in toys is available from the Environmental Working Group and Green America. These consumer guides and educational resources are a powerful way to make informed decisions when buying children’s products.

In response to increased consumer advocacy and awareness about toxins in toys and packaging, many retailers now tout that their products are not made with certain harmful chemicals. While this transparency is a crucial way to keep our kids safe as we buy gifts for the holidays, only federal regulation and oversight can truly ensure that all toys are free of toxic chemicals.

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PFAS

Toxic Tuesdays

CHEJ highlights several toxic chemicals and the communities fighting to keep their citizens safe from harm.

< Back to Toxic Tuesdays

PFAS

Per- and polyfluoroalkyl substances (PFAS) are a class of chemicals that have been used since the 1950s in firefighting foams and many consumer products that includes firefighting foams, stain- and water-resistant fabrics, nonstick cookware and food packaging. PFAS chemicals are highly stable, so when they are released, people can be exposed through air, dust, food, and water resulting in widespread exposure.

Many types of PFAS are known to have adverse health effects on humans including increased cholesterol levels, changes in liver enzymes, decreased vaccine response in children, increased risk of high blood pressure in pregnant women, and decreased birth weight. Epidemiologic studies also suggest a link between exposure to certain types of PFAS and increased rates of kidney, prostate, and testicular cancer.

The Pease Air Force Base in New Hampshire may have exposed area residents to PFAS in their drinking water for decades. The US Air Force operated this base from 1956-1991, and upon its closure the EPA added it to the National Priorities List, a “list of contaminated sites with known or threatened releases of hazardous substances” because of groundwater and soil contamination. This contamination likely came from PFAS in the chemicals the Air Force used to extinguish fires which seeped into the groundwater and water wells servicing the surrounding community. In 2014, the Agency for Toxic Substances and Disease Registry (ATSDR) measured elevated PFAS levels in these wells and in the blood of people who had been drinking from them. In response, one of these water wells was shut down and the remaining ones were fitted with water treatment systems to remove PFAS contaminants.

ATSDR states that these changes will ensure residents are no longer exposed to PFAS, but it offers little guidance for people who may have been exposed to PFAS in the drinking water before 2014. It provides no information about how residents should monitor their health or how long they may have been exposed to PFAS. PFAS levels in the area water wells are now being periodically monitored and ATSDR and the Centers for Disease Control (CDC) are conducting a biomonitoring health study of children and adults exposed to PFAS-contaminated water in the area.

Similar PFAS contamination is occurring at sites across the country including in Alaska at several sites near facilities that used PFAS-containing compounds in fire-fighting chemicals. As of 2019, 10 communities in Alaska have PFAS levels in their drinking water that the EPA deems unsafe. Alarmingly, Alaska is rolling back regulations and testing on PFAS in drinking water. State and federal agencies are failing to fully investigate potential sources of PFAS contamination and the effects on the surrounding areas.

Many things are unclear about the PFAS exposure communities around the country, but what is clear is that more must be done: more scientific studies to understand the health effects of PFAS, more transparent recommendations from health agencies to the community, and more precautions to keep people safe from these chemicals.

Click here to learn more about Testing for Pease, a community action group whose mission is to be a reliable resource for education and communication while advocating for a long-term health plan on behalf of those impacted by the PFAS water contamination at the former Pease Air Force Base in Portsmouth, NH.

Click here to learn more about PFAS contamination in Alaska.

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Backyard Talk

When ‘Safer’ isn’t Safe: BPA and BPS

Two weeks ago on Backyard Talk, I wrote about BPA, a major plastic component that has been linked to number of health impacts, particularly endocrine disruption. The jury is still out on BPA; the European Food Safety Authority has declared that BPA does not pose a health risk at normal exposure levels, while recent studies have emerged showing that BPA affects stem cells and may impact reproductive health later in life. In the face of all this scientific uncertainty, it’s lucky that we have access to BPA-free products. Or is it?

I have a few new water bottles from Christmas sitting in my cabinet, stamped with a leaf design and a guarantee that their plastic is BPA-free. Our eco- and health-conscious readers probably have similar items in their homes. BPA-free products have proliferated since the U.S. Food and Drug Administration banned the sale of baby bottles containing BPA in 2012. Unfortunately, studies over the past few years have shown that even BPA-free products release estrogenic compounds, some of which can even be more potent than those released by BPA-containing products.

One common replacement for BPA, or bisphenol A, is BPS, or bisphenol S, which has been shown to disrupt cell functioning at very tiny concentrations. It’s no surprise that the compounds might have similar effects, because they are close in structure as well as in name. A brief organic chemistry interlude:




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Image from the blog ‘Science Minus Details.




To the right is an image of BPA side-by-side with a particular estrogen, estradiol.

This image highlights the structural similarities between BPA and estradiol, which enable BPA to mimic the hormone and cause disruptions to the endocrine system.

Below is the structure of BPS:




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BPS molecule









Though the two molecules are not identical, BPS contains the essential ring structure, called a ‘phenol’ group, which is highlighted in both BPA and estradiol. Structural similarity between BPA and BPS is what enables them to play a similar role in conferring hardness to plastics. It also enables them to interact with cells in similar ways. According to Scientific American, BPS is thought to be more resistant than BPA to escaping from plastics when they are heated. However, studies have demonstrated that it is prevalent in human urine, and that even small amounts can cause changes to cells.

We are caught between a rock and a hard place when it comes to developing safe, or safer, alternatives to chemicals that have been linked to adverse health or environmental impacts. When replacing chemicals in products, we often first look to chemicals that share properties with the ones we are seeking to eliminate. As in the case of BPA, however, these similarities that preserve the function of a product can also preserve its toxic effects. When health risks are demonstrated for a given compound, is it prudent to bring in a replacement, even if this new player has not been vetted by scientific studies? Should we settle for lesser risk and continue working towards an even safer ideal? What does ‘safe’ mean, anyway? Tune in next time!

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