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HomeMy WebLinkAboutCOM 0482.323 2024-2026ct—h41f, Aloha, my name is Nicole Larson and I am the founder of Circular Hawaii, an "on the path to zero waste" diversion services company. We work with haulers and recyclers to model how we reduce the volume of solid waste going to our landfill. We've diverted waste from some of the biggest public events on the island, such as the 2024 IVF World Sprints Championships and the KWXX Ho'olaulea. Thank you for the opportunity to comment on Bill 83, and mahalo to all for the hard work and effort that has gone into this bill. I'm also grateful to the DEM, whose comprehensive letter echoes my own concerns. I oppose Bill 83 Draft 2. As written, by restricting all plastic for reuse in Section 3, part D, Bill 83 goes against the county liquor license practices. Currently, for alcohol served within the County of Hawaii, it is recommended that the liquor licensee provides alcohol in a clear container that allows monitoring of alcohol consumption. I believe you have received a statement from the County of Hawaii Department of Liquor Control stating this. Circular Hawai'i has been working towards providing reusable cup and plate service for outdoor events on the island, and we have spoken at length with them about materials. For reuse at outdoor events, Circular Hawaii recommends polypropylene, PP (#5) plastic for alcohol consumption. This plastic is one of the safest forms of plastic for reuse, its double bonded molecular structure makes it less susceptible to breakdown. Not all plastics are created equally. The language in Bill 83 is too broad. Additionally, as someone who has sifted through organics from events with thousands of people here on the island, I can tell you that to the eyes of commercial composters, the type of materials recommended in this bill for serviceware, "compostable" PLA, are a contaminant and Comm. Ref. M, Ref. Date - ?�Z�J must be kept out of compost. We have to hand pick it out. Neither Compost Kauai nor Hawaiian Earth accept the types of foodware or serviceware that bill 83 requires for use. Due to misleading advertising, the public has been led to believe that bioplastics and materials with the BPI certification are compostable on the island. They are not. I urge you to reconsider what will be most effective in helping to achieve solid waste reduction goals. Banning plastic foodware and serviceware to replace it with a slightly different bioplastic or fiberware that also must be landfilled and breaks down to microplastics is not a solution. We urge you to work with waste industry professionals; to develop new goals, that are globally accepted best practices, and demonstrated to reduce landfill volume. Reuse is best, but not always possible, and certainly not with such strict material restrictions. Labeling all plastics as "bad" in one broad stroke is not practical or realistic. Therefore we ask: • Remove (d) from the definition of "Reusables" in Section 3. OR: • Reconsider and postpone Bill 83. Mahalo for an opportunity to share my mana'o. I am happy to provide further technical assistance and references for everything that I have said. Mahalo, Nicole Larson nlarson circularhawaii.com 808-785-6982 circularhawaii.com PeToPLA A meta -study on the persistence and toxicity of PLA, and the formation of microplastics in various environments Technical Summary Report prepared by Christian Lott, Kristina Stemmer -Rau, Miriam Weber HYDRA Marine Sciences, Buhl, Germany info@hydramarinesciences.com sponsored by E, 01 HOLLAND BIOPLASTI(S eve on r�. Corbi"f" NatureWorks futerro�- L Declaration on potential conflict of interest The sponsors had no influence on the outcome of the meta -study and did not interfere with the interpretation of the scientific evidence. The key findings presented here reflect the scientific opinion of HYDRA Marine Sciences' authors based on the available literature and do not constitute an advocacy in favor or against certain materials. Technical Summary This meta -study reflects the current knowledge in the publicly available scientific literature and in institutional and company reports on polylactide, or poly(lactic acid), with focus on the aspects of biodegradation in the open environment, environmental impact and toxicology, and the implications for standard testing, certification, and regulation. PLA is a versatile polymer with properties that can change and can be modulated over wide ranges. On its way from the producer as pellets until it becomes available on the market as a plastic product, and later possibly ends up in the open environment, the neat PLA may experience all kinds of material modifications. During production, the polymer is made with only a few ingredients and with every further step the material may be treated mechanically and with heat, further chemicals may be added, or other materials are combined or come in contact with until the final article is available. All these aspects are not further regarded in depth, and mainly studies on neat PLA as a base material, either self-made on laboratory scale or from industrial production are considered in this report. It must be emphasized that, because of the above -mentioned potential material modifications, a final article made from or with PLA may have different environmental performance and effects than the material that leaves the polymer producer's factory as raw material pellets. Regarding the fate of PLA in the open environment the lead questions of this meta -study were: How fast and to what extent does PLA degrade in the open environment and are microplastics formed, which are persistent? What is known about the ecotoxicity of PLA? Additionally, the policy and regulation on microplastics on EU level were addressed and test methods, standards and certifications regarding biodegradability and biodegradation in the environment were briefly summarized. Hydrolysis is the dominant process for PLA degradation PLA is a polyester and thanks to its polar groups is slightly hydrophilic. Water as moisture or in liquid form is taken up by PLA by diffusion. The presence of water molecules leads to the hydrolytic cleavage of ester bonds. The hydrolysis rate of PLA depends on a number of external factors including moisture level or water availability, time, temperature, pH and internal polymer -related properties such as molecular weight, crystallinity, ratio of L- and D-lactic acid, and the possible presence of accelerators or additives. Hydrolysis is temperature -dependent, and the rate of ester hydrolysis follows Arrhenius behavior within the boundaries of a physical state, i.e., below the glass transition temperature Tg, between Tg and the melting temperature T., and above T.. There are discontinuities in the reaction rate when these boundaries are crossed, but within the ranges the reaction rate is predictable for given conditions. The ester groups within the polymer molecules are cleaved randomly by hydrolysis which leads to a decrease in molecular chain length, thus molecular weight. Each ester group hydrolyzed in the PLA chain generates a corresponding carboxylic acid end group. The occurrence of free carboxylic acid end groups in the PLA polymer matrix accelerates the hydrolysis by autocatalysis and renders the polymer matrix more polar which results in higher water uptake. Once the cleavage products are small enough to become soluble, such as oligomers and lactic acid monomers, they can leave the polymer matrix by diffusion, resulting in mass loss. During hydrolysis of initially high -molecular weight PLA the molecular weight decreases with time, while the polydispersity, which is a measure of the distribution of molecules of different chain length in the polymer matrix, hardly changes. This also explains that, although the molecular weight decreases continuously, at the beginning no or only little mass loss is measurable, and microbial mineralization of the polymer carbon to carbon dioxide is small and may initially not be detectable. This also leads to a substantial lag phase in biodegradation tests where carbon dioxide can only be measured after the soluble hydrolysis products are assimilated by microbes HYDRA Marine Sciences I hydramarinesciences.com 2 and then ultimately mineralized to carbon dioxide. When carbon dioxide becomes detectable, molecular weight reduction of the PLA polymer chains via hydrolysis has been going on for quite some time but remained unnoticed by this method. The observation of significant molecular weight reduction before mineralization commences as a manifestation of the bulk hydrolysis mechanism for PLA. The effect of autocatalysis by acid end groups within the polymer matrix indicates that the hydrolysis of PLA is also influenced by the pH of the environment. PLA hydrolysis is slowest at neutral pH of the surrounding water, faster at very low pH and fastest at very high pH. Natural freshwater and seawater systems usually have a pH between 6 to 9 so here this effect is low. PLA can consist of amorphous and crystalline regions. Hydrolysis occurs preferentially in the free amorphous parts of the polymer matrix and the crystalline domains can only be hydrolyzed from the edges. The reduction of the molecular weight of polymer chains by hydrolysis lowers the inner order and can lead to relaxation within the PLA and a recrystallization of the amorphous parts neighboring the crystallites. This means that during the degradation process the remaining polymeric material is changing its conformation, making PLA microstructure a 'moving target'. PLA also takes up water from moist air and hydrolysis at high humidity can be even faster than if immersed in water. In air, the acidic degradation products cannot diffuse out of the polymer matrix and therefore accelerate the rate of hydrolysis. In water, those acid hydrolysis products of low enough molecular weight (estimated to be <1000 g/mole) can diffuse out of the bulk into the hydrolysis medium and the autocatalytic effect is thereby slowed down. The rate of hydrolysis for PLA immersed in water is slightly lower than in highly humid air. Hydrolysis affects all ester groups in the whole polymer matrix. This leads to hydrolytic degradation throughout the whole PLA article, in a process called bulk erosion. In thicker PLA articles immersed in water, autocatalysis is more pronounced in the core, below an outer layer or 'skin' of about 200 µm (Li et al. 1990a). PLA objects with a thickness or diameter below a threshold estimated to 200-300 µm (Grizzi et al. 1995), thus also PLA films, fibers, and small particles, do not exhibit this accelerated inner erosion pattern. Direct biodegradation of high -molecular PLA by microbes can happen by enzymatic hydrolysis, which has been shown in laboratory experiments with natural microbes, and also with solutions of isolated enzymes. Because enzymes are too big to diffuse into the polymer matrix, enzyme catalyzed hydrolysis of PLA is a surface erosion process. In order to be active in PLA hydrolysis, microbes need to come in contact with the polymer, physically attach (Kimkes and Heinemann 2020; Zheng et al. 2021), and chemically sense the substrate. When signaling molecules have reached a threshold concentration, they induce microbial production and secretion of the enzyme onto the polymer surface (Harapanahalli et al. 2015), such that the enzyme's active site is in proximity to ester groups in PLA chains. Most of the 27 PLA depolymerases described so far are esterases, lipases, cutinases, and proteases from the serine hydrolase group (EC 3) and are characterized by the presence of a signal peptide enabling their secretion onto an insoluble substrate. The activity of some PLA-degrading bacteria can be enhanced by adding traces of protein such as silk fibroin, gelatin, soybean, or keratin to the medium. Microbes identified and confirmed to directly hydrolyze PLA in controlled laboratory experiments were isolated from soil, compost, sludge, garbage, or waste dump sites and comprise 78 bacteria, 27 fungi and two archaea. As some soils were wet soils from e.g., rice fields or dump sites their potential presence in freshwater systems is likely. Few PLA-degraders were isolated from marine samples. So far, no evidence for direct enzymatic hydrolysis of PLA in the open environment has been provided, maybe due to the lack of suitable methods. HYDRA Marine Sciences ( hydramarinesciences.com 3 However, even without direct depolymerization of PLA by microbial enzymatic hydrolysis, it can be assumed that lactic acid and short -chain PLA oligomers produced by chemical hydrolysis do not accumulate in the environment. These low -molecular hydrolysis products are bioassimilated, i.e. used by a variety of microbes as building blocks for biomass and as a source of energy, and eventually completely mineralized. For a comprehensive overview of PLA-degrading enzymes, see Tournier et al. (2023). The occurrence of PLA microplastic in nature has been reported only a few times from environmental samples, with the findings of a single or a few fibers or particles in soil, freshwater, and the marine environments. In large sampling campaigns in the last years, biodegradable plastic materials in general were not in focus, and analytically not considered. As the market volume is increasing and PLA applications for outdoor use also increase, it is likely that findings will increase, at least occasionally. From exposure experiments, PLA is reported to disintegrate in soil, freshwater, and marine settings over the period of several months to years at ambient temperature. Mass loss, along with changes in mechanical properties and molecular weight was used as measure for PLA degradation. However, several short-term field experiments and laboratory tests over several months with PLA articles placed in soil, water, and sediment have been published with the statement that PLA is not biodegradable in the open environment (e.g., Royer et al. 2023). Most of these studies seem to neglect or are not aware of the fact that the molecular degradation of PLA by hydrolysis is a bulk erosion process, which for a longer initial time is not measurable as mass loss but only as a decrease in molecular weight until the molecular fragments are small enough to become soluble and diffuse out of the polymer matrix. Long- term studies that take into account slow degradation rates are rare, and there is no systematic picture yet. Methods for long-term degradation studies and direct analytical methods for field tests are missing. The formation of micro- and nanoparticles is part of the degradation process of natural polymers such as cellulose, chitin, or keratin and degradable synthetic plastic polymers alike. Even rapidly biodegrading plastics do not dissolve but physically fall into pieces and consequently, as a transition stage are present in the form of micro- and nanoplastics before they are completely assimilated and mineralized. Hydrolysis as the basic molecular mechanism of environmental PLA degradation continues as long as there is moisture or water available. Thus, the size of the fragments decreases, passing micrometer and nanometer range until the polymer chains are so short that the material becomes soluble in water and are not particles anymore. The dynamics of PLA micro- and nanoplastic formation and their lifetimes until complete mineralization in different environments are not systematically known and may range from several months to several decades or more. In contrast, non -biodegradable, non-hydrolysable carbon -carbon backbone polymers, such as polyolefins, form micro- and nanoplastics only under the influence of UV light, abrasion, and other mechanical action, which suddenly stops acting on the material when the particles are covered with dirt, overgrown by algae, or trapped in soil or sediment. Micro- and nanoplastics from polyolefins and other conventional plastic polymers are likely to persist and permanently accumulate in the environment. Environmental effects of PLA In this section we refer to plastic in general and point out where PLA is specifically addressed. The physical effects of macro- and microplastics on organisms and ecosystems is widely documented. Many terrestrial, freshwater, and marine species all over the planet are killed, injured, or reduced in fitness by the physical interaction with plastic of various dimensions, with larger effects not only on an individual level but in some cases also on population and ecosystem level. HYDRA Marine Sciences I hydramarinesciences.com 4 The presence of small micro- and nanoplastics (MNPs) within the respiratory and alimentary ducts of humans and animals has been proven and the uptake of a low percentage of ingested particles of-5pm and smaller into other tissues across the gut, gill or lung epithelium seems possible. For a limited number of organisms (daphnids, mussels, crabs, fish), the uptake and translocation of MNPs has been demonstrated in the laboratory. However, it is not clear whether this also occurs in other species and whether it occurs in nature. Findings of large microplastic particles e.g., in liver or brain tissue seem unrealistic and are questionable. Currently, for the detection, identification, and quantification of environmental nanoplastics in organisms, there are no validated analytical methods available. The detrimental effects of micro- and nanoplastics (MNPs) in organisms are documented in some cases, but the overall consequences for plant, animal and human health are not yet clearly defined. The latest high-level reports on this topic (SAPEA 2019; WHO 2022; EC 2023a) are not conclusive but send clear warnings and call for high attention. If microplastic emissions to the environment remain the same, the ecological risks of microplastics may be widespread within a century. The review by Koelmans et al. (2022) is recommended for further reading. Given its slow environmental degradation, the presence of PLA articles and MNPs may range from several months to several decades or more until full mineralization. During this time the effects of PLA in the open environment and on organisms are similar to conventional non -biodegradable plastic polymers in some respects. The pure physical effects of larger objects and articles (e.g., pellet, fork, cup, fibers) are expected to be basically the same. Studies on the chemical effects of PLA rarely refer to the 'neat' (i.e., commercial raw material grade) polymer, but to processed and formulated grades or end products made from or with PLA such as cutlery, shampoo bottles, cups, or straws. In these plastic articles, PLA may be mixed with other polymers and additives, and may be contaminated by chemicals that have migrated from the material present in the packaged product (e.g., shampoo sold in a plastic bottle), for example, which likely blurs the picture of studies on the ecotoxicological effects of neat PLA. Several studies showed no adverse effects of PLA on algae, plants, and animals. In most studies where an effect on organisms was demonstrated, the measured effect could only be described for the totality of the tested material and could not be attributed to the neat polymer or other individual components. The environmental behavior and impact of a final plastic product or its residues, e.g., as waste, on the environment can be drastically different from the original neat polymer. Throughout the life cycle of the product, from polymerization through plastic production, product manufacture and service life, to its entry into the environment, and then during its continued fate in or journey through various environmental compartments, all physical, chemical, and biological interactions influence the properties of the product and thus its degradation and impact. Additives and foreign substances found in articles from the market, or in plastic samples collected from the environment attract high scientific and public interest which must be taken seriously. However, the mere presence of a certain substance detected by highly sophisticated analytical methods might be interesting but should not be specifically alarming at first sight. The actual concentration and thus potential doses should be considered to evaluate a potential risk. The background concentration (e.g., in food, organisms, environment) should be used for comparison and the presence of such substances in the plastic article may be due to migration from the contents of the article rather than a compound of the plastic per se. Effects of plastic articles, also made from or with PIA, usually are assessed with unspecific tests and the effect mechanism remains unknown. This is of special importance for tests with high doses in confined vessels. One material -specific aspect of PLA is that ester hydrolysis increases the acid concentration and eventually those acids will become of low enough molecular weight that they become soluble and mobile to leave the item and enter the environment. A decrease of the water pH HYDRA Marine Sciences I hydramarinesciences.com 5 can be detrimental to sensitive organisms that cannot escape in a small test vessel in contrast to an open system. Interpretations must consider the environmental relevance of such artificial test conditions. Given the low hydrolysis rate of PLA at ambient temperatures, moderate pH changes are expected to be only effective in the immediate vicinity and quickly diluted in open aquatic environments. The chemical effects of PLA-based macro-, micro- and nanoplastic beyond the formation of acidic degradation products comprise all substances that at a certain point of time are part of the particle, regardless of its origin. Plastic particles, being apolar and of low hydrophilicity, provide a space with high affinity and solubility for lipophilic substances in a biosphere which is mainly water -dominated, thus hydrophilic. This results in a steep concentration gradient from the medium to the surface and into the bulk of the particle with diffusion of chemicals with suitable properties into the bulk or adsorption to the polymer surface. Thus, plastic particles of any size can act as adsorbents that enrich certain chemicals to (much) higher concentrations than in the environment. With their spatial dispersal plastic particles are also vectors for all chemicals they contain. Generally, upon changes of the environmental conditions, solubilities may change, and previously adsorbed chemicals can desorb e.g., at the transition from the water phase to the sediment in freshwater and marine systems, or reversely, or upon internalization into organisms. In this sense they temporarily store certain chemicals taken from the environment rather than act as source for such chemicals. There must be a significant change in the surroundings for the plastic particle to later release the lipophilic chemicals. In the extreme, the total hydrolysis of the PLA particle releases all entrained chemicals. MNPs may also adsorb chemicals from highly contaminated organisms when ingested and via egestion clear the organism from toxins. The constant background exposure to natural particles of mineral (e.g., dust, fly ash) and biological origins (e.g., pollen) and the long history of research on man-made nanoparticles in the air show that organisms have evolved countermeasures that are largely efficient. The presence of unwanted MNPs, particularly of PLA, in tissues has not yet been critically studied in detail. As bad as foreign particles may be in organisms'tissues, the intrinsic property of PLA of being rapidly hydrolyzed and subsequently metabolized in warm-blooded animals and humans, and its far-reaching approval as a suture, implant, and scaffold material, suggest a low risk posed by (a few) MNPs from PLA at temperatures prevailing in the body (-37 *Q. Systematic information is lacking for cold-blooded animals and plants. Summarized, the effects of PLA on organisms have been demonstrated both in lab and field tests but the explanations proposed for molecular effect mechanisms that could be PLA-specific are scarce and debatable. Regarding the testing of hydrolysis, biodegradability, and biodegradation rates on the one hand and ecotoxicity tests on the other hand, the environmental relevance and the transferability from one scenario to another or from lab to environmental scale has to be evaluated for each case. Very strict criteria must be applied not to overinterpret or underestimate results and draw environmentally relevant conclusions not backed by the experimental or observational results. The main difference when compared to non -biodegradable polymers is that PLA will eventually be fully hydrolyzed and biodegraded, and no persistent particles will remain and accumulate. The question of accumulation however is a balance between the rate at which MNPs are being produced and the rate at which they are degrading and leaving the environment. Less plastic waste littered should affect and eventually reduce the former rate. As soon as a PLA object is fully mineralized the environmental impact ends and a recovery of organisms, and the ecosystem can start. We are not aware of any studies that look at the impact and recovery in this sense. HYDRA Marine Sciences I hydramarinesciences.com 6 Test methods and standards for environmental biodegradability In laboratory tests, a direct measurement method such as quantifying the conversion of polymer carbon to carbon dioxide must be used to demonstrate biodegradability. The tests are usually done under optimized lab conditions. Subsequently, after inherent biodegradability has been proven, the rate of biodegradation will be estimated by indirect means using proxies such as disintegration, mass loss or surface erosion rate, in mesocosms and field tests under environmentally relevant conditions, while preventing physical deterioration. This 3-tier test scheme has proven to be effective and can be used for soil, freshwater, and marine scenarios. Ultimately the impact of the material on organisms shall be assessed with ecotoxicity tests. The tests should be done according to standards adopted on CEN level for comparability and reliability. Certification serves as an external inspection level to check the accuracy of the measurements carried out. As a rule, the validity of the certificate and the use of the label is limited in time and requires renewal after its expiry, or if changes are made in the tested material. Setting up a catalogue of criteria and an overarching testing scheme will be helpful for the further development and improvement of policy work, as well as certification schemes. To accelerate progress, an overarching Technical Committee (TC) on biodegradability at CEN level is proposed. Although many standards have been introduced in recent years, there are still gaps that need to be closed in a timely manner. The European Commission is requesting a revision of the industrial composting standard EN 13432 (BS EN 13432 2007) to clarify the concepts of biodegradability and compostability. Examples of missing standards are for tests covering anoxic conditions in soil, freshwater, and marine environments, including a feasible way to integrate deep sea conditions. In addition, freshwater and soil tests for all tiers - laboratory, tank, field, and impact - as well as impact assessments for biodegradable plastics at the ecosystem level need to be completed at the standardization level. The main difference when compared to non -biodegradable materials is that biodegradable materials will eventually be fully degraded, and the organisms and ecosystem can then recover. The duration of the impact and the rate of recovery are important aspects for an extended risk assessment, as they make it possible to evaluate the benefits in terms of reduced risk. So far, there are only a few ecotoxicity tests for solid substances such as plastics. Therefore, tests for soluble substances have been applied so far. It must be examined whether the pass levels need to be adjusted to remain environmentally relevant. Conceptually, it is not yet satisfactorily solved how the different environmental conditions and their variability can be taken into account. Furthermore, the integration of different timeframes of "weeks", "months" and "years" (as proposed in the EU Policy framework) into test schemes is still lacking. This however is needed to do justice to those applications that have a longer use life and are thus intended to degrade more slowly (e.g., controlled release fertilizers), or for applications used in less favorable conditions for biodegradation. Therefore, new tests for longer biodegradation times, and also accelerated tests with new ideas and innovative approaches might be needed, potentially deviating from current tests and standards. All these actions will support a consistent adaptation of testing and certification schemes for soil, freshwater, and marine, and so policy recommendations. Finally, the question remains as to what are acceptable timeframes and concentrations that should be allowed for biodegradable macroplastics and MNPs in the open environment. HYDRA Marine Sciences I hydramarinesciences.com The special character of PLA where direct biodegradation in the environment is assumed to play an insignificant role, and environmental degradation is dominated by chemical hydrolysis is not taken into account in the context of testing, certification and regulation. With the currently existing testing and evaluation scheme PLA remains non -biodegradable in the environment and is rather seen as a risk, and its potential as a beneficial material alternative for certain applications cannot unfold. Accurate data on the environmental behavior of PLA, especially its hydrolysis rate under common environmental temperatures, are necessary to lead the discussion and the development of standards into this direction. Policy and regulation concerning microplastic On a policy level biodegradable plastic polymers and additives are seen as a possible solution for specific applications, and against persistent microplastic pollution. However, such materials are treated with caution for two reasons: First, it is considered essential that their introduction does not cause any lasting environmental pollution or other burden, and second, that biodegradation really does take place completely and that it is known how long it will take. For biodegradable polymers and additives, it must be demonstrated that they are biodegradable. The timeframe to biodegrade in the receiving environment must be estimated, and where they are likely to end up if there is the risk to be transferred between environmental compartments, e.g. from agricultural soil to freshwater. The impact on the environment should be minimal and claims must be based on existing standards and certification schemes (EC 2O22a). The adopted EU Action Plan: "Towards Zero Pollution of Air, Water and Soil' aims for 30% less microplastic release to the environment by 2030, showing that means for concrete measures need to be put in place as fast as possible. The Regulation 2019/1009 for safe and effective fertilizing products on the EU market is the first act that legally binds biodegradability to polymers in applications mentioned. For further processes, such as the Microplastic Initiative, negotiations are ongoing. The strategy is to look for measures which provide benefit and are not in conflict with other scopes of the EU Green Deal. As part of the ongoing work, the benefits of additional legislation on the unintentional release of (micro)plastics will be assessed. The focus is on understanding the sources of unintentional release of microplastics from selected product groups and then assessing possible measures and options for action. Data for such assessments is not available or available data is not useful for this purpose. Such assessments are time-consuming and should be carried out with care before proposing a policy measure that could have an impact on an entire industry. They should therefore be prioritized and presented to policy makers as soon as possible. References EC (2023a) FUTURE BRIEF: Nanoplastks: state of knowledge and environmental and human health impacts - Issue 27 EC 12022a) COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE CO MMRTEE OF TH E REGIONS EU policy framework on biobased, biodegradable and compostable plastics. Grizzi, Garreau, LI, Vert (1995) Hydrolytic degradation of devices based on poly DL-lactic acid size -dependence Blomatedals 16:305-331 Harapanahalli AK, Younes JA, Allan E, at al (2015) Chemical Signals and Mechanosensing in Bacterial Responses to Their Environment. PLOS Pathog 31:e1005057.hftps://tloi.org/10.1371/joumal.ppatIO05057 Kimkes TEP, Heinemann M 12020) How bacteria recognise and respond W surface contact FEMS Microbiol Rev 44:106-122. hftps-.//dol.org/10.1093/femsre/fuz029 Koelmans AA, Redondo-Hasselerharm PE, Nor NHM, at al (2022) Risk assessmentof microplastic particles. Nat Rev Meter 7:138-152. http-.//tloi.org/10.1038/s4l578 2l-M431-y Li SM, Garreau H, Vert M (1990a) Structure -property relationships in the case of the degradation of massive aliphatic poly-(B-hydroxy acids) in aqueous media: Part 1: Poly(dl-lactic acid).1 Meter Sci Meter Med 1:123-130. htips://doi.org/10.IW7/8F00700871 Raver S-1, Greco F, Kogler M, Deheyn DO (2023) Not so biodegradable: Polylactic acid and cellulose/plastic blend textiles lack fast biodegradation in marine waters. PLOS ONE 18:eO284681. hftps-.//tloi.org/10.1371/journal.pone.0284681 SAPEA (20191 A scientific perspective on microplastizs in nature and society. Science Advice for Policy by European Academies (SAPEA) Tournier V, Duquesne S, Gu illamot F, at al (2023) Enzymes' Power for Plastics Degradation. Chem Rev acs.chemrev.2c00644. hftps://tloi.org/10.1021/acs.chemrev.2c 44 WHO (2022) Dietary and inhalation exposure to nano- and microplastic particles and potential implications for human health. World Health Organization, Geneva iheng S, Bawazir M, Dhall A. at al (2021) Implication of Surface Properties, Bacterial Motility, and Hydrodynamic Conditions on Bacterial Surface Sensing and Their Initial Adhesion. front Bioeng Biotechnol 9:643722. https://doi.org/10.33B9/fbice.2021.643722 HYDRA Marine Sciences ) hydramarinesciences.com 8 •10aV1Z A life -cycle analysis of reusable and single -use cups Updated Edition: November 2025 0 Upstream reuse veins at events A life -cycle analysis of reusable and single -use cups John Went; PhD, University of St. Thomas This wort was paa for by a grant from Upstream. TM wort was W nouatee by Unirvenity Of St TbOn105 ASWCbte Prafe raor John Went, Ono Univrmity Of St Tnomoe Unaergroowb Raseomn Asshtonts Wayoe CMrging Hawk, Max MBVe$ AIIie POMMOR Ora IOM LundR OOnJ DES ERIN COVEY -SMITH EDR : SAMANTHA SOMMER 6 MATT PRINDIVILLE UPDATED: NOVEMBER 2025, MADWIVI TRIKHA REVEWFRS (20 5): MICHAEL KRAUS, GREEN SPORTS ALLIANCE HILARY NEAR, CITY 6 COUNTY OF SAN FRANCISCO Contents Executive Summary 6 '��� Introduction 10 • LCA Results for State of the United 12 States Recycling Scenarios • LCA Results for Optimal Recycling 27 Scenarios Material Recycling Sensitivity 37 Analysis • Software Data Verification se • Conclusions 42 Executive Summary By Samantha Sommer, Director of Business Innovation G Matt Prindiville, CEO - UPStream (2021) Over fee poet decode -Poe Me sports, enter- unnomm, and live events Industry has searched for alremOMMS W Single -use plastic in food concessions. After COvd bCk-tlOWm, Os RMS returned M sporting trends OW conceit -gas% CekbrolM the return Of musk festivals, Su8- tomobllRy house Of evBnd OM Venues Come bock info focus - spstillcolry, the ever-pnwm disposable plasm Wp. Many attempts at solutions have been InVo- doded, from blopkslk cups to reuse systems aw now single -use aluminum. But msn hoe been no clear onionskineonaM W e as to "i ,peons have megreatest enNrenm tided I mpact a no which opti Ads have the least - untll ones. Upstream commissioned this life-Cycke assess- ment to examine the emiroomentof impacts 01 single .sa den reusable cups mad. from dlgednt madfwls that are used in Olson one stadium events within Me United States during a average event tour season. TM1egoal of the repent is to prevfde unbiased Information and analysis to help venue man - food conaessksmim., and otnerindua- tryleaderslamtnymemartlmynor menially friendly options. The modrials mo nufacture nonspmt and use posses of 18-ounce beverage cups made from polyethylene lemphMaed (PET), polyractic add (PrA),aluminum (AI), and musabe versions made d potypeopyese (PP) and stainless steel (SS) were analysed for energy consumption carbon dionde emissions air acidification, wo for eutropMcatkn and anthill impact. Key Findings eeusoble stainless smi l And polypmpyl- cups inartistically outperform the single-lens cap options across an envlron- mmltai monde. These are the most sus- MinaeNmmedm'doe.for even%and VMML In all Use sCenO rce, stainless steel and pokpropylene cups nova the lawsuit impact compared to single -me cups B they are vmshM am usetl past too'Oreak-even pdnY d six limes. The Moak -even point is the number of limes o mu Wble product Must be used M order to exceBd me envl- ranmendl benefits of a comparoble amoure of tlhpasobleS (e.g. after two uses,a YtOnn- %ss steel fork starts to accrue envimnmea- %of benefits over a ceptsaDle plastic ore). The more a reusable product or package a on. no reused, bast the break-even point, the more environmenloI bernefid accumulate. Polypropylene cups can the washatl aM %used hundreds of timed, am stainless steel cups thousand s of times. x. K youTeetin using single -metope, PEE and PU taps am Fisher eptloso f er the d Imdd. At current recycling rates among single -use cups, Polyethylene terephMordd (PET) had the lowest energy Consumption and global warming potenbok followed cksely by poly- rdctc card (PIA). 3. Single-usrolumseen cups MetMwaat optionfar ton a W eau by dr. Single -use aluminum sups used 4T mare energy over men IRe-cycle and .,noted 86%thou cor- ban dioxide than other single -me plastic optons 9. The Me awgory-ther"tatlM One washing- fa ton mutable tape had. minor linpoa for all ors cases In compori- son to Angle -user cups. S. lee average stadium Mat holes 100 events annually us over nod a million sMus gle-e ccup.-amusing wMpping 6.3e tansd PMem waled it terse were replaced with reusable polypropylene (PP) cups used 300 times and than i iscortlM, that would gen- erate a more 09 tons Of ward. Reusable stainless steel cups used 300 times and than adsorbed would gmterate ).nt.18 tons Of waste. Recommendations, I. VMuesandeventtampanles Moda Mgin shifting owaylmm an sdgle-use cups, not 'lust single -use pbslic. a. Single-utealuminumeupeanknotaeua dDwMe option when e%nperod to ender singer -use cups or mMMlWe sups, eve nh most of the aluminum cups get collected for recycling. Me average recycled content for aluminum cons Is 73av which we extmp- Picard to aluminum cups. Even In the ska, ndnd, roughly 2n 4 virgin aluminum, which is toroidal led with five timer more Carbon pollution than recycled aluminum. Bill mining for aluminum releases per8uodeor- bons that are %WO Most more harmful for the climata than CO, 3. Sminerro stem! letlm pM~ all,ke forest wmnth andeman more times O can the used many more r the3 rwr rn- men plastic and d better around. emiron- men[ and people all orountl. o. Venues arM event Gemponles eon diner A) make Moir awn musable cup systems, b) Ilcmae 3u parry ytstems, or c) hie reuse so mpanf es to pmvlae the sershm fa them. A number of reuse combo ales hove Covel- opea prover, mH-Nlectivesystemsfar dis- tributing, colledirg are washing hundreds d thousands of cups per day Integation Into existing operations K Often Bailer than anticipated, and customer add shows a high level Of imusk ism and participation for reuse systems. S. TMroarowaysd save der mane money than displaying humbeee cup yet.., including: o) savings on tlhposables pro- curement, b) savings on weds manage- ment costo c) savings on clean-up and Baer, d) opportunities Ind brand partnerships and building brand loyalty and B) apparN- nlllas for such integration specol Offers and va uoble customer use data. Background The pllmoly tool WW to assess the emIlan- mental impacts for d'dferent types of materials Is collet Ise -cycle anolfros or Parenthesis (MAS). Researchers plug In Commit, aesump- done regarding haw the musobb packaging will be served (and collected. washed no formed) ano compare the different upstream ano down- stream environmental impacts of each option. For this report, the Ise -cycle inventories of each cup am use case were Compiled using two software packages (DRAMA EcaPoaka d Sustolncbiliry Eco Audit oha IMnOult Systems Solidworks) that were then compared with each other for mauncomy use enema sage Wilt on conservative common and different Component assumptions such as moterbl moss, rMMfoC turng processes, use noses end of fide man ogement, and bansportatdn. The types of events that the oMlys s is desgne l a found are those whew a performing oft group troves from city to city on a muststoptour. The a end sues anolyted ranged from 8,000 seats to 00,000 Peace OM me number of events ranged from 14 ro N evens ,n a given tour season. All cups within the study ore assumed to have the Coale volumebo capacity Of IB ounces In single -use Scenarios, the CUPS were evaluated with varying eves W lecyced content and post -consumer mr clmg, Including up IC 100% as a meamllCal sCBMIb and whew all waste, woyeling and reusable dupe Within an on M me recovered of returned by event goers. In wbb scenarios, the cups are ossumea to be retained by the venue oftef use and sent to an Industrial washing facility for Cleaning before being shipped aM reu,w at Ina nee event. The moterlols, malMacture,tronspan and use phasesof IB-ourde beverage cups mode from PET, Pbl, Ad. PP and SS some analysed lot energy Consumption, Carbon tlbvde emissions, air ocYJIIICOtdn, water outrophica Ilan and IOMI(II impact The muse of polYplopylene aM stain- less Use were Compared with onghe-use5 of the other Moodok to determine break-even Points based on the number of muses Conclusion With all the adention being gob to single -use plastic, venue owners and events companies are fig My looting ic reduce their plastic (act - print Unfortunately, trading am slgle-use product for another generally means trading am set of environmental problems for others. For example, there My not be os much pbs- tit in the ocean but there is now mow climate pollution, more deforestation, more mining for precious MtoI%or increased use of toxic chemicals But the goad news Is that reuse wins for the environment every time, and companes ale Innovating to cream new, house services to get us wort we want orb need without all the waste The events industry Can be o leader in Me new reuse economy by developing am deploying reusable cups systems, your fare and employ - See will love it, and you will have taken 0 s'gnis- canl step toward ter. waste, a I»ashbr planet, and a bigger bottom line introduction Project Overakwr and Background This anoves bob at the environmental impacts of beverage containers (wps) used in Orono am stadium events within the United Stales during on event tour season. The goal is to pro- vide unbiased information Circus energy use requirements am carbon dioxide emissions slat accompany the use of different beveroge containers m that verse managers and other industry leaders can Identify she most err iron- menml y friendly approach. The types of events that she analysis Is des'gned around are Nose where a performing On group advels from city to city on a multi -stop lour. Theorem starts am- lyMd mrgad from 8,000 sears to 80,000 soots and the number of events ranged from 12 events to 90 events. The beverage Containers analyzed were single -use ver tumor mode of pohethybm lerephthobte(PET), Poly iOdd(PIA), Ckn i- hum (AI), 0M reae]ble versions Made OI poly- propylene(PP)onest.inle me (BE). In slrgle-use sCemrbs Ins cup were walks - died with varying levels of recycled Content am post -consumer recycling, Ina W ing up to 100% as o theoretical scenario where all waste within an Orono A reCOHlea. In oasis scenargs the wps ore aesurrletl a ba retained by the venue Otter use and Sam t0 On industrial washing IOciI- fly for Cleaning before being reused OI the next event A literature review wOs cones te001 pai on work that invenigCoul similar use cases Or 1'de-cycle analysis of beverage corminers bde- pement of events. A summary am fun refer- ences of these comparisons can be provided by Contacting imoSESupstreamroluliomog. LCA Methodology fife -cycle Inventories of each cop and use case were compiled using two softwore packages that were than compared with each other for nor manty. The packages used wale GRANTA Edulici M20 fever 3 SOstoimbi5ty Edo Audit am oosmuR Systems Solbworks 2020-2021 SuslOimbillty Module. Rath software packages use mOlerbl and process datOb08es a CAate environmental impact outputs based on mote- mI mode monafadufing prmessem use saii b8 am transportation. The use sCeiorbs am assumptions used to the amlysk are provided below. UMSCENAMM Use scenarios have bath common am different component& The common components am barred on an assumption that all cups, FBI Forks of matera(will be nwrMacturea in opprox- tmalely the some low tan am trarrspone , u&I, the some MetMtls. It IS..gnize0 that there one naccuraiars within these common OBsumptbn& but since Oil Material receive the some treatment the inaccuracy Is minimized. COMMONASBUMPTIONS 1. Cup manufacturing ti place in China 2. Ocean freight transports the cups to fos Angeles, 11,070 km most of 219 far IB At volume 3004 grade alumi- na was used. Reusoble PP cup measurements were based on IB oz sompbs with a Moss of 479. The wall thickness for the reusable cup was Significantly larger Ilion Vie single -the W ps to provde a more robust ma long-bstin, Ii Fat The reum be stainless Steal cop dimembns Were kxwd1 On mu le stainless ste91 pint wps With a mass of 8B 25g; 304 gFort. AI51 steel was deed. All pbStb cups were omlyzea OS being nanu- faCNred using In)ectbn mOking. Stainless 8t9e1 ono cluminum cups were analyzed as being rolled strip, street metal blanked (155%waste removal), am deep mown to shape 3, sleight wol wnsporls the cups to venue 2025 Updated Scenario bcations3,242km Scemrioloflhte nwas 4. Imusblol Conveyor dishwashers ore used for cop washing (25 Suits per rock, 244 recta Par hour, MOO W. 0,82 gmbns per rock) B. Deh .00hing factory is 10 miles from venue. E. Transition energy calculations are hosed on Coal mesa of motriml being bansported, hg her Most Cups reauire more energy to transport >. Reusable Curds are 100% recovered after each event far washing. This may rat ba POSSItim Os some patrons may wish t0 retain their cups am ale them home. However, a cup Mat token home is expected to have a neutral environmental affect because it e replacing omlher reusable Cup at the home, rather than a angre-use contains, CUP GEOMETRIES AND KAMM All cups within the study Ore assumed to have the some mkrmetra capacity of 18 oz. Cups currently In the market Made of the different motefe is in the study were measured to deter- mine appropmu mosses Single -use PET am PIA cups one commonly available am Were measured of l07g am 144g, H apsafirmy for IB oz vobme. single -use aluminum wps are Mat predominant In the Market line 8011 Ahrmtmm Cup^' was used as the base for analysis With a po upb aodlromorg- inah2021 numbers to re -scab the average sta- dium Capacity and events/yam, more closely reflecting real -world sCemrkad Using Stadium Chat event verom ma study octual5 from the preen Seats Alliance Reuse Plavbook Ono from 14 Bay Area sports am entertainment venues, o hypothetical verve with o coi miry of 18,OW, Fasting 100 events Per year woe cakudted. Accounting for feedback From seamf experts, the scow of Cups/spectolor was upaotea to reflect the imlease in retail packages goods mialive to Cups An overage of 030 cups/spectator coos aerlvea ffom the COSS ttW ies MIRPOMeame ufaaoled environmental maims use the original I CA data, farming a threat regression metha i- oagy to rehear the changes in both upstream are use phase impacts for From, ble items with different numbers of overage uses. LCA Results for State of the United States Recycling Scenarios TM fee -cycle analysis results Presented in the following use scencras cocepale the dif efent cup rhowrals Rased on current recycled con- tent values cfa recycling rates for each mote - !al as given below Container Recycling lrotitute, National Association for PET LE% 20.9% Container Remurces(NAPCOR) MIS; Anlelleoa Chemistry Council one Association of Plostic Recycl i s M19. Spleem)BallCO, 2020;The Aami- nsi .9e.1% nfm Association, 2019 0% 0% IWR, 2014 in American Chemistry Council and Association of Rastk Reayck1s. 2019. - TI% am Teem Stainless, 2019 Tal I: Recycling assumptions for materials 18,000-Capacity venue/ 100 sold out Events/ACups per Seat Scenario The M.,ycle.."is resUlle In tole section are Presented as an amlKis Of an I8,000-capaoiry Venue wild IOO safe Out events t Scups use0 per seal, followed by o breakdown for Impact of the mOlerok manufacture, transportation, use OM artfae0l. fgures I-5 show a comparison al cup material impact ar, respeetrrery, enelgy consumption (MJ), carbon casks footprint (kg), air aaaific0- ton (kg 502e), water eu[rophaation (kg POAe), and aMnn use (ran). The number of uses of the reusable PP and IS cups is fared on the Wilson - lot axis of nits figure& Table 2 provides coneat- ngdata . Total Energy (W) PIT Al PIA PP PP PP PP SS 5s is 55 sirgfo- era- siraw Suw M— 25use 300 5. louse Muse 300 sli 1: Taal energy (MJ) for 18,000 venue, 100 events,.3 cups/sect Toto I COr(Kg) TO.tta 80,000 40,O00 30.000 ___ ...... __. Om I PEt AI %A PP PP PP W 55 SS 55 53 "Ie- "It, Wigle- 5we l0use 25 uae 300 5usc lose.. 25uae 300 Figure 2: Total energy(MJ) for 18,000 venue, 100 events,.3 cups/seat Air Acidification (Kg SO2e) c00 350 300 250 200 50 FET Al RA Pe PP PP M EstSS 55 SS sl singe'- single- Buse 10use 25use 300 S. 10. 25we 300 U. gglPs 0: Air add Inaction (Kg S02e) far 18,000 venue, p0 events, 3 cups/seat 2w 200 1w tw to 0 Water Eutrophieatlm ,zgvoae) FEE AI M W as PP PP 55 55 55 55 "Ie- single- Mngk- Sue 10ase 25 use 300 5use ICwe 25we 300 Landfill (Ton) 15 12 9 6 3 in oMINNOW PIT angle- RI %A eirgle- wngle- Pe Saw Pe Pe ous. 25— W 5$ 55 ss 55 300 5— 10usc Mass NO Figures: Water euaopnicatlan (Rg Pc te) for IB,o00 venue,100 eve sm.3 cups/seat Figure 5: Landfill Impact (tons) for IBo00 venue, ) W events. 3 cups/seat o a ;. 537,458 508,803 23,688 215 1503 6.34 535358 631,268 6g153 387 E3,81 12. 537,458 524,Mt 32,8n 162 3852 8.5 Fro 10),4915 459,658 1928E 88 10.23 5.57 53,Tn5A 22g,33s 9,522 44 5,13 2.78 21Ag8.32 92,838 3,932 IB 2.06 III Lyines B847 418 1 19 0.09 10T,4916 310005 23AI9 235 2DA24 law 53,7452 152,842 IIA97 118 102.1 5.29 25 21/198.M 63,220 4599 47 40.82 2.Q 300 I,191.53 UBE, 523 4 3.38 0.18 Table 2ICA impact comporenn for I8p00 venue, 100 event; 3 cups/sent Brea keven Ana lysis for Rouse below, the breokeven value means that I ale Scenarios regigabigir Cup war ..so that number Or mans times then It is preferable W the specified sin- AbneakeVendialysis was COMuatedtOdeter- gle-use Cup A lower number means that the mine how many uses of the PP and SS cups ream cup is more of a significant improvement would ass recessary to improve their impact over me single-umcup becauseltis, antcl- beyomthe single -um varletles. In Table 3 dated that most Cups Will be reused many times. Singlevse PPEnergy Motenal Breakeven Uses PPOOt ereokevenuses SSEnergy 81eakeven Ums. ssco, Breokeven Uses PET ©©�© Aluminum ©©©© PEA ©©�� Toele 3: Number of uses for breakeven impact in current date M recycling Energy And CO Life -cycle Breakdown of Material Impact In this sector, each materiol is presented bro- ten dawn by ire relative impact of material, manufacture, tronsponotion use, and dlepoeal. Single -use cups are assumed to have nBgYgi- ble use components. figure cups ore assumed to he driven 20 miles round-trip by 40-ton truck to an Iroustriol washing facility, where they are washed with industrial conveyor den - washers (25 cups per rack, 2" rocks pet hour, 1900 W, 0,52 gallons Per rack). End-oHlre (EOQ Is treated as a credit, or subtraction, from the total Impact X pard-use recycling Is usetl. PLA, a bo-polymer, is dssigheo for industrial com- posting instead M recycling, However at the time very little indusbhl mmpasdng infros Wc- lure is operating in the United States am most PIA material that wn be composted finds its way to the ondBt instead. Acooroing to Stare of GbmpORing in the US What, Why. Whem&Hi (Instituro fog Local Se6-Bellarae, 2014), only n of composting facilities take mired organics such as used fo W wane writs: based on that, an assumption of kondMYing is mode for PIA prod - .of. PET Energy Breakdown (IN) 500,000 - - - - - - - 400,OM 300.00E 200,C00 IOa000 -ICO,OW ...kil Mmula... Tramp. Um EM at Ufs Pigw B: PET energy breakdown (M3) for 18,000 venue, 100 events, 3 cups/sent 20,000 Is,aoo Io.Wo 5,000 0 PET CO, Breakdown (Kg) Motxlal Monotetve I'mamt uu Ertl W life Fleeter ]: PET Co, breakdown (kg) for I8,000 venue, too even, 3 cups seat Aluminum Energy Breakdown (MJ) 1000000 Baraboo sog000 aOODOO 20ao00 0 -OWAW Wend MarnRacen. harm on uy End of We FlWM T. Aluminum energy breakdown (MJ) for I&WO venue, I W events..3 cups/seat rooW 60,OW WOOD a000D W,OW Wood IO,OW 0 -to," -Z1,0W Aluminum CO, Breakdown (Kg) Mateial MOMacM Irarnppl the, End of We ilgure4 PET CO, breakdown (kg) for 48,000 venue, IW events, 3 cups/seat ]I PEA Energy Breakdown (PAJ) PIA Impact Breakdown sw000 _.. ........ ..... _... _. ............. ...... In 0.PN.."I%here a sba-of-life impost from antl- 4o0,CC0. -.. -. filling, Out Itstsosmall com- parea to me other catego- _. rie$ it apes nor snow on the 390.ppp _.. chart In lain energy and CO, impact, it accounts for 0.3%of 10a000 100,000 I.blwial Mprye... namport use "Ofule Plgurel0: FLA energy breakdown (MJ) for 18=0 venue,100 event%3 cups/seat PLACED, Breakdown (Kg) ]5," soaoo 15,c00 to," 5,W0 0 Marcum Manaf ctve lramport use End ofure Plgnrell: PET CO3 breakdown(kg) Ior Ht, venue, 100 avents,.3 cups/sent PP TO Use E nnegy Brea kdown(MJ) "Wo 15aaoa _... IOeo00 ... _._. _.... SO.coo ........ 0 -50.000 Polypropylene Impact Breakdown Polypepyehe he 0 reuse saeherm, so it 0. Carly O use imp at due t0 driving back one 1plth from the washing facility ahe the act of woshing itself. To shew the varying impact of use wtth ream ,um- ber boar are 10 use scenaris One the 300 UBe 9CBMIp or. provWed. It can be Seen that as Maur IncR04e9 the Wool ImpOot Sit, nificonlly reduces and the use impost IncneOSeS relotive IO the Other categories. Matelot MonuhcCu, noapan U. aemuro Pig. l3: PP enegy areahuown (MJ), 10 use%18,000 copddty, 130 events, 3 cups/seat PP 300 Use Energy Breakdown (MJ) 5,oa 400 soc 200 tot 5Mxe1 MmulocNe IrmvPmr tlse EM of ula Plgree 13: PP energy breakdown (MJ), 300 uses, 16,000 capacity, Me events, 3 cups/Seat q 23 PP 10 Use CO, Breakdown (Kg) "GOT) AMerbl Mmulacrwa trrcuport Ilw NNof Ne Figure 1e: PP CO. breakdown (kg), 10 uses, IUOO capacity, 100 a ients,.3 cups/sect PP 300 Use CO, Breakdown (Kg) 200 150 100 50 0 -50 _.. Mmwiol wonufrioue Transport U. EMol Ule Figure IS: PP CO, breakdown (kg), 300 use ,1%000 capacity, Ic0 events, 3 cups/seat SS 10 Use Energy Breakdown (MJ) 200,O0f Stainless Steal Impact Breakdown Simibr to polypropylene, stainless Steel IS .reuse srehand, re it carries 0 are impact due to arming back and forth from the washing facility and the Oct of washing itree. To snow the varying Impact of use 150,000 with... number both the TO aee sca- .1. and the 300 ure scenario are pro- vitlea R Similar Impact t0 that W the PP a0,000-. _.... _ _._1 cuplsahowaalthoughths high recycling LP' of Stainlex Steel leads to 0 much or Significant and of Igo credit. 50.000 or ■_r -50aa0 -ICO.WO ..... _.. _._ _.. ...... Mmwia Mv'Mactue Irompot Uu EMNah Flgu er IS: %energy areaktlayn (MJ), 10 uses, 18,000 Capacfty, 100 events,.3 ups/seat SS 300 Use Energy Breakdown (MJ) d000 edg0 ... _.... ........ ..._. staid 2000 Too 0 1 ido _.. -Z000 Mrit-al Montououra ironwar, Um Eno Of life FI,.I): SS energy breakdown (MJ),300 use& IBXO capacity,100..e , 3 cups/seat N 2e SS ICU.. CO, Breakdown (Kg) zooO lo,000 &c00 a,oco son 2000 O -xOoO -a,0m Nori uaMactum norislxvt use FM of ore Xgue 1& 38 CO, breakdown (kg), 10 uses, 18,000 Capacity, 100 event., 3 cup)aeat SS 300 Use COr Breakdown (Kg) 400 350 300 250 200 150 IW BO 0 _W -100 -I50 Material Nonamatve nanvporl Os. EM ofdfs {Igoe as SS CO, breakdown (kg), 300 uses, 18,000 capacity, 100 event., 3 cups/smt LCA Results for Optimal Recycling Scenarios While the previous analysis looked at the current overags stale of mcyclkg Ono use, It is possible to make products with bgh« leVMs of mc,cl, bN materials aM oho d anfO.. a theoretical univerml recycling within a vemre, me follow- ing analysts of three bMNrent event scenarda Onticipoles 0 -best costa for eoch material even if that Cam'R rat currently the corm, Me died allows a find distinction to be drawn for a masi- mum number of reuses necessary to bleakeven with single -use cups. The IXe-cycle analysis results ore pfeseaba by use scenario so that comparison within use scan cl can be made. After IMSe data sets there Is an ono"s of the blotwe impmtonm of venue size and number of events On reuse scimlloa Scenario One Rossi 50 sold out events at 8,000 capacity The figures and table on the following pages provide a compamon of the total energy Can- sumptidn onci total carbon abide emissions mspectNe from best ease scenaya usage and recycling rates (of each material. In this onoN- as, maximum recycling rotes are premn[m for each moterkt The mcycling tabs are presented In Table 4 which also provdes the data shown grapmmlly in Figs, I am 2. While it A recogniba Mat the 100%recycling rotes are urocblevobly optimistic, grey are used in this case bemuse reaming the may - cling Cabs to more typical numbers wad not change the redtue performance of the mate- rials but would Instead create on even Ili gap between the sups that ate reused and the single -um cups. Th«ek e, the result. pre- ened show the most comervatNe mlotionship between the mabrdN. b zr 600Mo 5M,000 aM,000 3M.000 RM.MO IW,000 0 Scenario One: Total Energy (mi) 1 E S 4 S a] e B w n Is to 11 ilgun30: Tool energy for 9,000 capacity, 50 events 9 odr ngoof 3SOM i].OM :EF M 10.M0 I6,000 10,000 6,0m 0 e-a dskw Scan. rho Ono: Total CO, (Kg) 1 2 S 4 9 4 ) S S 10 11 R N 14 ilppm 21: Towl COa for 8,000 Capacity, 50 events 1 1 3 1 1 1 4 1 9 1 9 1 7 1 9 1 9 10 11 1 12 1 12 1 M PFf vw u en„ M hwUses "s MS M4 n5 MW ma SSa 335 am me O.E. immTabk40ndfigs.200M2titaonbeseen SCENARIO ONE BREAKEVEN POINTS that the boast energy and glow[ walming A braOkevea analysis Was Conducted W ONE, impact lot the scenario comes from a Wlypm- mine bow many uses of the PP and SS cups Pylons Cup that is re -used throughout am WWI muW be necessary to improve their impact numosrof Events, meaning that hem are only Corona the single -use varieties in 5canarb One. 6tA00 mode and they dre washed 49 times In In Table 5 on the folboing Wga the bmokeven both the SS and PP .."is the Impact of num- value mean that Attie musoble Cup was used per of reuses shows with the more times the cup that number r mom times then it is preferable is mused the beltm. Among the single-u6e CUM to the tp aP, single -use ou, OFF, PET Cup has the lowest energy and GWP impact. The oNmim an and PIA cups have slmi- lor energy consumption but the P.0 has a bwer carbon diWWO output There Is not a d2krercE within the significance M the data for energy COMUmed. Material Quantify PET single-u.. Content Content Y.Recycled Post E...t ,Total Energy (MJ) Total COr (kg) Al single -use PEA single -use maa PP2Uses�� PP3Yses�� PP4uses��� PP 5 Use. PP SOus¢s 552 Vse3 ���� SS3uses��®," SS4uses��®� SSSuses RsssusesSS50. re � Table 4: Ma[biul voknes for BA00 wWCIIY 50 evOnk as B Single -use Mate "energy PP CO, Ssen rgy SS COr riot Ibreakevenuses'bmakevenuseslbreakevenuses,breakevenuses PET Aluminum ©©©© PLA ©©� Scenario Two Resu IM: 90 vold out events at 18,000 capacity Like Sce m One, the following figures antl table provide a compeison of the was energy consumption am lows corbon wokiae emis- stm wamihe from best case scenorb usage am recycling rates for soon awtedol. 2W1000 ZOOAWc "WON) 1.000,000 sottow 0 e-uxlsk v In this am"is, mommum warding tows are presented for each mawriot The recycling rates ore pesentea in Table 8, which of provides the auto shown gropncalh in Figs, 22 and M. Scenario Two: Total Energy(MJ) 1 2 a • a e 2 a Y to n It It u Figure r Total energy for I84CO capacity, 90 events 1 1 2 1 1 1 • e e T 8 8 1 p 1 11 1 12 1 li 1 14 6660 Isomo Isom IeU,boo IN'" W,Ooo EAM W000 so," "oak, 0 Scenario Two: Total CO, (Kg) 1 2 3 a e e ) e e la 1 12 n 14 figure= Talol Mi 1.118,000 capacity, N (mr. Material Quantity PETsingle-use Recycled content /,Recycled Post Event TolalEnergy (MJ) Total CO, (kg) Alkingle-use PEA single-use��®"' Pp ases PP4uses PP Buses SS 2uses��� SS auses m0� SS4uses a� SS 5uses SS uses 55 SO uses��� Table 8: material A. for ISM) capacity, SO seenw From Toble6 am Figs. none 2% 11 can beseen =ENMgT OMEAKPVPNPMWS that the lowest energy CM gl0b01warmirg Abreakno.in Mlysiswasconduct.Inaster- impact (Or this scenario comes from o Mlypro- mien haw many uses of the PP and 55 does Pylons cup Nat re re -used throughouttM year, vroula be necessary to improve their impact meaning that Nero are only fgda0 mend am beyond the single -use varieties in Scenorlo Toro, they ore Sheal e9 times. TM remoinilg results In Table T below, the bredkeven value means are consistent with Me faults from Scedcric that if the reusable cup was used that number One, with only the magnitude of energy and or more times then it is preferable tothe Speci- GWPgoing upalong wilhthe oddftlonol number bed single -use cu, of cups being used. .. 5 .. ... .5 .. .. ... 5 .. ® 3 2 3 3 3 3 3 A TOW T. Bnedkeven oMlysisfcr SceMro Two Scenario Three Results: 12 sold out in this anclyse, maximum recycling rates are events at$0,000 capacity presented for each momMl. The recycling rates are presented in Table 6, which also provides tire Scencrlos One one Two, the followin, fig- the data shown grophicolly in Fg& 24 one 25. urea am tobse provide a comparison of the total energy consumption and total carbon dioxide emissions nespecolve from best case sceMrq usage and recycling rates for each nMWMt Scenario Throe: Total Energy (MJ) MO.000 9M.000 600000 100,000 600,000 500000 400,000 300000 200000 100000 0 1 S 3 • 5 6 ] e If 10 a 12 a Figure 26: Total energy for 60,000 Medoff , 12 events 3:-uvl6lnw 1 2 3 6 6 6 T 8 B 1 10 0 12 a N1 vgls a "I W R2 M3 W< Ma Mp s53use ess .4 See .12 33 8fr000 Maid w 000 s0,00a Q000 Word nods d dot, 0 Sconario Three: Total CO, (Kg) 1 s 0 a f e 1 e Ir TO B 12 al Figure SE: Total COr for B0,000 capochy, 12 events Refor to kakis key on page 31 Material Quantity FiFlisfingle-use %ReoycleE %Recycled PoslEvent TOTaIEnergy"T--1.0,Content (MJ) Al single-use�� KAsingle-use as PP 2 usm, PP 3 uses�� PPAuses PP uses PP12uses S52uses©' �� ® SS 3uses�� SSAuses SS B uses���� SS12uses •••• � Table B:Mat uial values for 00,000 Capacity, U events N Scenario Three results are consistent with the results from the first two scsndrins, with only the magnitude of energy and OW P going up along with the additional number of Cups being used. SCENMgMME BMMEVEN POINTS A breakeven analysis was conducted to deter- mine how many uses of the PP and SS cups w ld be hecesaory to improve their impact beyond the single -use yo0etiee In Sourarb Three In Table B below, the breakerven value means Mat IF the reusable cup was used mat number or more times then it'a preferable to the sped, fled single -use cup. single -use Match.. PP energy PP cur, SSenargy ss Ca, MedkeVenuse4 breakeven uses brodkevenuses bn:akayenulas _. PET Alumina. ©©©© ru ©©0 Impact of Venue Size and Number of Events To determine the relatve influence of venue side a no the number Of everts On the BM/ itmeMal footprint d Mmparson study was conducted. Three meams were compared interms of energy Consumption for four materials. PET, At using 100%recy01ed Senior, PP used 5 times, and 5s usea a times. 1,RC0,aW OW.OW By Comporing the impacts from lean scenario, fill It can he aMwn which has the .IS, environ- mentolimpact from wide, larger capacity van- we or more events The s arms ore outlined in Table 10, and results shown in Fig. 06. From Fig. 28 there O a anger ncreose in energy consumplan when comparing Scearla IA to>C i. than when comparing IA to 19. Since M Ond IB She the same capacity Out increase number bof ar Of es and M and lC share the some rum leer a events but increase capadry, the longer Impact is snwn To lea an imreese of venue capacity. venu..M aopo City Compwifnn[ Tot of Inergy(MJ) i 4 4od,dO6 �� YM.OW 0 PET vale-r Alw g.- a PP6u. Ss buses Figure tie: Total erargy for venue and capacity comparison sd.melo capacity Events 9000 50 -- '� 5000 90 0 IBAW 50 TOMB Is. SCeam Cafinitbns IMcaterica ll RoCYCHIng Sean skivkyr Analysis The dad ono coMWIom presented in the pMyOw Section was done aid for a -best case - recycled material content A best deal Of pp% recycled content or IBM post use recycling u not raolnhc in meet ecendras, with over011 red,_ Cling rotes in the united States tangling from Y% to M depending On the stab Om a number M fOCtOrs, odeordblg to a recent report by Eunomio end Boll Corporollon(The So States a Pery- c11ng,MomhMI). As mentioned! In Me earlier Seater, the -best Cosa• was used because R provides be beat possible scenario for tingle -wee Cupid am X reUcable Cups are already on improvement over Iho best recycling wee of all single -uses cups ltbn decreasing the recycling roes IS lower values wWl just mote that improvement more significant. The fallowing aalysis provides the impact of using usayaad materials In Me cups at offer - ant rates and stows raw that drives energy consumption and GWP values provided are for i0o0 cups to provide a team number for may axtrOpobtion t0 OOOltgr101 comparisons as desired. Transportation W the new cups is not included in the camporsOna because dll recy- died COMent varieties of the Some martial will have the Same moss and daid me tmnsponst, For each material two tables are presented. The first table shows only the impact of recycled content on energy use and GM The were idea aim provides End of Life Potential (EOLP)' tee is a value that the recycling of an Ban after use is assumed to reduce future environmental Impoa because It reduces future need for virgin matral. However, it a dependent on She eny- cring infrastructure to bring TO fruition. The EOLP a oalyZIXl for a O%Bicycld content because opproprale calculation of actual impact can - at account for energy and M, savings in both using recyoad materials and also in the enm- imdon of future materials - because nose future materials ale 011amy occdunted for by recycled material wage. Pw a not anchuediInia aecWn as R a de it,ram for industrial composting rather than direct recycling. Industrial composffng rotes one exeemely law with only 4%of compoafing sites t.4 g mieed ongona acaware (Institute far Local See-Reranca, M4). A S, In TOf In or 15%OF waid Sensitivity come the Using 0% Table pnawcwrsend of isotential. 0X hw0 45 ioble Bprow0es end of lMe potential — ------� - ,010 - -. reawtbm as associated with recycling 15% I - _ 63 rows Of OX, 50%, and 100%. To bIO 1, ,r. .L- Recycling IMtittlEneEgy FMPlammi'Su Energy Inkii FOVCOr Sum GOB Rate (MJ) (MJ) (MJ) (kg) (kg) (kg) lam 1,100 Alemttun In Table 13 the eensrevey of using M Not Or 100%of recycled content is provided. Table W provides end of life potential Ieauctbns as associated with recycling rotes of M Wis. and 100%. Aldminum snows the largest sensitivity to warding as making cups with IM way - area aluminum was only 20%the amWnt OF rnrgy and 24%the CO, emwilom as making them from virgin aluminum. 710D% 4,350 290 $B20 IN 111 B93 90 1 iuFilc Y6 4 vr,K ...rv,e.m _:ry II I 0% 4 fso 0 4,350 d 290 0- - _t 29� Not li 4,950 -LI30 Z620 290 110 al lam 4,350 -3,450 910 290 220 71 polypropylene In Tabb15,t11asewitWltyd1usilg0%OI 0% 4,dW 158 SM of wayal. content is provided. W!s se I_ the upper end of what ie practice for mi Prg walroed P In new PP Placid. law 15 Not _ 3350 L-_- 152 Provides end Of life potential reductions 0a associated with recycling rates of 0%50% morels l,rp:op�p cr-..^ antl IOOX -e 1 1 R: eap9 Recycling InlitalfritoWA F&WEnOrW SumEnw,firA 0% 4aokd 0 4400 15B 0 280 60% 4F00 ' -1.040 3,380 18B 15 T 152 ' 100% 4,400 -2020 2330„ _ im 32 _I us iub1016. YolyP PY Cl�hr, ,I a .Lv,IL I nn1^-L• oanarnl ICI l psY St31,1 tAIY 304) - t In Table 17, the sensRWity Of Ming M50X L _ 0% 5,540 _.- 456 or 100% Of recycled content is provided for 60% 4=0 306 stainless steel 304. Table M Provb9e -..- Of life Potential reauctbn, as associated 100% Z010 155 with recycling rates Of 0%, 50%Ono 100X Tdblel) 'hie0 tt Fa ... "`.,�'."""'."'„"'^""^'"a'a..""•^�.°"'"' lent aont ;lL WGO cups i 71i"Encergy, lnergy' Initi ICOS EPC0SumCO•eccRoss(MJ)(M.,) (kg) (kg) (so) ,OOX ®_ Table l6: Stolnl r ,ter eryclinG .Iry er.:Ynq-,lAOrr nup.fY<, ecY0ler. eenlmnl Software Data Verification Tne data that Iwo been presendid far S tmands 1, 2 am 31s from ORANTA EduRock using their Suetainobilily WyErl3 Eba Audit All uses of sa [- wore packages for LCA Come with the Comm - parrying assumptions that the values used to crea the the aMtwOre tlOtOb08e901e simibr, l0 those valves being used within the specific product ...[.brute, transportation am use that are being omNmd. This use of general data for aPr ifie bases always provdes o di gin of error within the results that should be recognized.In the case of this onoNsis o margin of error of 20%1 suggested as reasonable. To privies nd. confitlence in the data and conclusions, the orri was irdependentry conducted on another LCA 60Xware Package, Soldwtub, Suatainability Module. The Sold - works module ricks some of the sell of the GRANTA EduPock software so it is not oppropa- are to expect exact molch up of results. How - inner, in. the object of ink.,On wolk it to di tefmine endures ewlronmenlol impact aw- ing the Some ordering of materials in terms of energy consumption and GAP provides a level of confidence, In the results. To provide on example of the Comparison, the energy ontl GWP of a sing%cup is presented. As might be expected, the environmental impact of the cups aesignea for reuse k longer iron a single -use cup due to the extro malenlol and processing necessary to produce it. TCOW 19 provides the mmPOOSOPS of the twat software packages for Individual cups, Irdeperr, dent of use scebarlos, and Pigs, 27 and 28 snow the some material graphically. PIA ls rot present in the analysis bemuse it is hot cow netl in We Soldworks material database. There is generally very good agreement both in magnitude of energy consumption and GWP and In the order in which the impact is seen. Me provides verification of the data provided in the first Part of the repo ft. Sdirworks nick Error% 3"Ich rks -a- Ftlu [tlran[ k PET 191 206 5.96% .10 0.0g an Ar 3.90 6.19 5.92% 32 0.33 185% PP 5c0 4.62 7,6% 023 018 19.65% SS L 510 6,19 17..61% 047 0t3 a69% Tale H: Software camparisan 7 5 5 4 3 2 0 Individual Cup Energy Comparieonby Software (W) PET AI PP SS Plguns2T.Compmisan of software for individual cup toml energy (MJ) 0.50 0.45 0.40 035 0,30 0.25 0.20 0.15 0.10 0.05 0.00 - sddwvrks M faiab Individual Cup COr Com parieon by Software (Kg) PET Al PP SS flpurs U: Comparison of software for individual lop total energy (MJ) Conclusions The mareriob, manufacture, transport and use phases Of IB oz beverage cups made from PET, Aluminum SECA, Pµ PP, OM Stainless Steel 30A were anetyzed for energy Consumption, co loan d'wsae emissions, air oca Mwt'roq water eutro- phicatlon and awlfll impact The reuse of PP and SS were Compared wim single -uses of the Other IMteralt to determine breakeven paints bosed on number of leases. Additionally, recy- cling rote earoitiv'M and multiple software data verification were wwuctea. The primary coroknions include In all use scenarios a PP cup has the aw- es[ Impact Compared to single -use Cups R it con be used at bast six times in optimal recycling and XYB fim96 at Current rates, In all use scenafias a SS cap has a bwer impact compared to single -use cups a used of bast six times in optimal recycling a five times of current rates. At Current recycling razes among wngle-use Cups PET bad me aweII energy consurn, lion and GWP, loliowed closely by P1A Alums - en single -use cups used w%more energy over their fife -cycle and created 88%rtare CO, man PET and PIA options. • The use Category, tronsponotionandwosn- ing, for the reosabb cups hetl a minor Impact for all use crows except maximum uses of PP and IS cups. Cited References 2019 units, States Notional Postconsumer plow, Bathe RecyOfirlg eepad, The Association of Pasta Recycles, Amenaon Chemistry Cwrail, 419. Report an Pashmnsumer PET Contafner Recycling Acd Yy In 2017,, NAPCCR, The ASewlatan of Plastic ReCycbr%201& Beverage Packaging A Comparative Life -Cycle Adeesmem, Sphem, Ball Corporat'on, 20W, The Aluminum Con ACVOntaga Sustoinabilfry Key Performance Indicators, The Aluminum ACWdiO- nor, Can ManAceenen Institute, 202Q rho dotal Life -cycle of Stainless Steels, Team Stainlsas, 2016. State of Ca p,,do, In me Wlat Wry,Where,SHow, Institute for fowl Self-reliance, 201A 50 St... of Rec cllrg, Smormo, Boll COrpOmtiOR=1. 0 Upstream