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HomeMy WebLinkAboutCOM 0944.044 2014-2016 PIEMO Murashige, Laura From: Joy Gold <joy@joygoldunlimited.com> Sent: Monday, October 03, 2016 11:16 AM To: Council Testimony Cc: Jason Higa; Steve N. Ueda;Justin Yoshino; Dexter Yamada (dy@kyd-inc.com); Lauren Zirbel Subject: Testimony for Comm. 944.40, Hawaii Island Packaging Sustainability Initiative Stakehoders Task Force Report -Tues Oct 4, EMC Hearing Attachments: 10_3_2106_Signed_HIPSIS_PositionStatement.pdf Aloha, On behalf of the business community participants of the HIPSIS Task Force, please accept the attached testimony. I can be reached at 808-368-1146 if there are any questions. Thank you, Joy Gold ******************************************* Joy Gold Unlimited 1136 Union Mall, Ste. 403 Honolulu, Hawaii 96813 Phone: 808-526-3770 Mobile: 808-368-1146 Email: Ioy(a,ioygoldunlimited.com www.ioygoldunlimited.com "Working with you to achieve your organization's mission and public policy goals" CONFIDENTIALITY NOTICE:This e-mail message,including any attachments,is for the sole use of the intended recipient(s)and may contain confidential and privileged information.Any unauthorized review, use,disclosure or distribution is prohibited. If you are not the intended recipient,.please contact the sender by reply e-mail and destroy all copies of the original message. ' ; o Comm. N.. 1 ` itc . Ref. To: toi Ref. Dote OCT 0 4 201 1 To: Council Member Daniel Paleka, Co-Chair HIPSIS Task Force Council Member Margaret Wille, Co-Chair HIPSIS Task Force From: HIPSIS Task Force Business Community Representatives Date: October 3, 2016 Copy: Hawaii Island County Council and HIPSIS Task Force Members Council Members Paleka and Wille, as businesses serving the Hawaii Island community, we appreciate your efforts to convene the Hawaii Island Packaging Sustainability Initiative Stakeholders Task Force (HIPSIS TF) for the broad purpose and layered goals of"identifying solutions addressing the production and distribution of environmental friendly products and packaging to improve and reduce product and packaging waste from entering our ocean as it has been proven to be detrimental to marine life." We strongly support the big picture need for waste diversion from the Hilo landfill, and better management of marine debris and litter. However, at the end of HIPSIS TF Meeting #2, there was no consensus about how to do that. We recommend that the October 6, 2016 HIPSIS TF Meeting #3 focus on points of mutual agreement. Issues That Impact the Credibility of the Task Force: • Participation in the TF was based on the Co-Chairs' promise to the Council as well as to the business community that the focus would be on all types of packaging, to include discussion about WTE and recycling, and that an EPS ban would not be the focus of discussion. Further, full discussion would occur before any group action is taken. - However, discussions at both Task Force meetings focused on the EPS ban, with little or no discussion about other packaging, WTE and recycling - CM Wille presented a proposed amended EPS ban bill at the HIPSIS TF Meeting #2 after she had already submitted it to the Council. • While emphasis was placed on bringing in the experts, there was no fact-based discussion nor were the heads of relevant county and state departments brought into the discussion as requested. Sharing thoughts and comments comprised the discussions. Overall, the process is not geared for fact-based discussion about complex issues. For example, some of the key information requested and missing from the discussion includes: - Specific information on EPR and the Green Dot Program and its applicability to Hawaii - Potential sanitation issues of returning post-consumer use food service containers to restaurants and encouraging reusable food containers at food establishments • While well intentioned, having a TF member prepare the minutes does not allow that member to fully participate or pay full attention to the discussion for recording the minutes, nor does it reflect objectivity in the minutes or an impartial relationship with the Co-Chair. What We Can Agree To: • Source reduction (not substitution) promotions. We can agree on an education campaign to get people to bring their own bag, straw or utensils if that is something the DOH says is safe. We would not support promotion of false or misleading information as explained in HFIA's 4- page document. (Please see attached) • COH sign-on to the malama808.org litter management best practices as more than 100 restaurants and stores have already done. This is free and could be a win-win for preventing all types of plastics, including compostable plastics, from entering the ocean. • COH ensuring source separation of waste for schools. • A study of the best solution towards managing waste and reuse economically and environmentally. It would be good to have a full study that gave well-researched answers on questions relating to the financial impact on residents and the long-term viability of waste programs. • A viability study for creating a business to produce compostable foodservice containers in Hawaii County, to include but not limited to: - Material sourcing and supply. - Equipment cost and technical support - Plant Location - Return on Investment for exports and local markets - Other Cost Factors: Energy, water and transportation What We Cannot Agree To: • Any proposed product ban • Any proposed tax on food, including EPR We respectfully request that this memo be included as a matter of record of the HIPSIS Task Force Report and in the Hawaii County Council Oct. 4, 2016 Environmental Management Committee minutes. Acknowledged and Agreed Upon By: 1)(<21&, Jason Higa, CEO, Zippy's Inc., on behalf of Steve Ueda, Vice President Sales Hawaii Restaurant Association Suisan Co. Ltd. ‘''st _ ,r Dexter Yamada, President Ju t �Yoshin®, Vice President KYD, Inc. dba: K Yamada Distributors Tp e F Distri•uting'Inc (A‘ r y�j Lauren Zirbel, Executive Director Hawaii Food Industry Association, on behalf of: John Erickson, Young's Market Company, Chair Beau Oshiro, C&S Wholesale, Vice Chair Toby Taniguchi, KTA Superstores, Secretary/Treasurer John Schilf, Rainbow Sales and Marketing, Advisor Paul Kosasa, ABC Stores, Advisor Derek Kurisu, KTA Superstores, Immediate Past Chair/Advisor Attachment (No Support for False or Misleading Information About Source Reduction Promotion (not substitution) Response to Box#1 (Kuleana Matrix): Identify Solutions Addressing The Production And Distribution Of Environmental Friendly Products And Packaging To Improve And Reduce Product And Packaging Waste From Entering Our Ocean We will start our analysis by considering some facts and principles that should guide our decision- making: Food is an essential commodity. Almost half of Hawaii's residents live paycheck to paycheck.1 Increasing the price of all food that comes in a package will impact the amount of food people can afford to buy and eat. This will materially impact heath and physical well being of many of our residents. There is no more regressive tax,than a tax on food. It's not something that should be seriously considered. Requiring residents who live paycheck to paycheck to foot the cost of projects, which are universally uneconomic, is bad public policy. Developing a recycling center just for the recyclable items produced on the island of Hawaii would be tremendously expensive. Mainland recyclers, even those operating with very large volume, struggle financially and operate with large losses year over year.2 "...Recycling has become a money-sucking enterprise. The District, Baltimore and many counties in between are contributing millions annually to prop up one of the nation's busiest facilities in Elkridge, Md. — but it is still losing money. Almost every facility similar to it in the country is running in the red. Waste Management and other recyclers say that more than 2,000 municipalities are paying to dispose of their recyclables instead of the other way around.i3 California has seen more than 20 percent of recycling centers statewide shut down in the past year due to the cost of recycling far exceeding the value of the recovered materials4. To pass this tremendous cost onto the price of food is inhumane and irresponsible. The definition of"environmentally friendly product" is a subject of tremendous debate. What is the standard used here? Do the products break down in the marine environment? Here is the answer provided by a manufacturer of compostable products on their websites: "Are your compostable products marine degradable? No, our products are not certified as marine degradable and we strongly encourage everyone to keep all plastics out of oceans and waterways. Land-based commercial compost facilities have the ability to maintain ideal composting conditions and sustained heat and moisture needed for Ingeo to break down entirely with the appropriate soil bacteria, yeast, and fungi. The ocean is salty and filled with life that is affected when plastics enter the water. The compost process does not occur there. Additionally, there is more and more research all the time showing the harmful effects of plastics in the ocean, including the impacts on birds that often mistake plastics for fish and eat them. Please help keep our oceans and waterways free of litter and plastic and dispose of any waste responsibly." http://www.hawaiinewsnow.com/story/31595253/survey-almost-half-of-hawaii-residents-live-paycheck-to-paycheck 2 httpsJ/www.washingtonpost.com/local/dc-politics/cities-and-counties-come-to-grips-with-the- high-cost-of-recycling-programs/2015/06/23/b53b98fc-18de-11e5-ab92-c75ae6ab94b5_story.html 3 httpsJ/www.washingtonpost.com/local/dc-politics/cities=and-counties-come-to-grips-with-the-high-cost-of-recycling- programs/2015/06/23/b53b98fc-18de-11e5-ab92- c75ae6ab94b5_story.html 4 httpJ/sanfrancisco.cbslocal.com/2016/07/19/over-20-percent-of-californias-recycling-centers- shut-down/ 5 httpJ/www.ecoproducts.com/fags-composting_and_recycling.html Are the products recyclable? In general, foodservice containers are not considered recyclable due mainly to food residue. Here is the answer provided by the manufacturers of compostable products on their website6: "Are your products recyclable? In short, probably not. Here's why: We have 2 lines of products; our GreenStripe® items that are made with renewable resources and our BlueStripeTM items that are made with recycled content materials. Not all of these materials can be recycled most places in the US." So according to manufacturers of compostable foodservice containers their products do not compost in the ocean and they are not recyclable. In the County of Hawaii, there is currently no facility for them to be composted or recycled, so they are not compostable or recyclable in the County of Hawaii. Many counties including Oahu have had working composting sites for upwards of a decade, yet have not successfully transitioned to accepting post consumer food waste and compostable foodservice containers because of significant engineering and economic barriers. The latest large-scale attempt to compost post- consumer food waste ended in a massive failure that will now require a major environmental clean-up'. Until there is an existing composting facility that can prove that it is capable of succeeding where most attempts have failed, the truthful answer to the question, "Will these products be composted in the County of Hawaii?" is "No". Considering these facts that foodservice packaging is unlikely to be recycled or composted on-island, we fail to see how there can be any reasonable argument that the more expensive compostable products currently sold in Hawaii are quantifiably "environmentally friendly." The production of all packaging involves environmental trade-offs, and the selection of the "best" option requires a judgement call on which impacts are more acceptable. Substituting bio-based feedstocks in an industrial process to produce compostable containers does not necessarily mean that these products are "environmentally friendly" or require less petroleum to produce and transport. In some cases, compostable materials may require environmental trade-offs that are incompatible with local opinion, such as the use of polylactic acid (PLA)-based plastics which are among the most commonly available type of compostable food containers. The cultivation of corn requires more nitrogen fertilizer, more herbicides and more insecticides than almost any other U.S. crop, and that practice contributes to soil erosion and water pollution when nitrogen runs off fields into streams and rivers.8 In addition, PLA is refined from GMO corn that has been genetically engineered to maximize the compounds that are extracted to produce the needed feedstock chemicals. One must acknowledge the environmental trade-offs associated with the use of any packaging material and whether a mandate to use one particular type of container or product will have the desired result of reducing litter and/or marine debris. All foodservice products —regardless of the material from which they are made—require the use of various natural resources, i.e. energy, water, etc. A 2006 Life Cycle Inventory study by Franklin Associates showed that polystyrene, when compared to other food service containers, is very efficient in terms of minimizing air emissions and energy used in the manufacturing process and in reducing the amount of waterborne waste generated during the manufacturing process? 6 http://www.ecoproducts.com/faqs-composting_and_recycling.html 7 http//www.dnrec.delaware.gov/news/pages/dnrec-secretary-small-orders-closure-.aspx 8 http//psep.cce.cornell.edu/facts-slides-self/facts/mod-ag-grw85.aspx 9 "Final Peer-Reviewed Report Executive Summary Life Cycle Inventory of Polystyrene Foam,Bleached Paperboard,and Corrugated Paperboard Foodservice Products",March 2006.Franklin Associates,LTD. A Harvard study reported that styrene is naturally present in food such as strawberries, beef, and spices, and is naturally produced in the processing of foods such as wine and cheese. The study noted that "federal regulations also permit low concentrations of styrene in food" as an additive. The scientists reviewed all of the published data on the quantity of styrene contributed to the diet due to migration from food contact packaging. The scientists concluded that there is no cause for concern from exposure to styrene from food or from polystyrene used in food contact applications, such as packaging and foodservice containers.10 The FDA, Health Canada and Environment Canada concluded extensive studies that polystyrene is "non-toxic" and that styrene "does not constitute a danger to human life and health" and "does not constitute a danger to the environment on which human life depends.„11 The concept of growing corn on Hawaii Island, and processing that GMO corn into a food package by any reasonable analysis would result in a tremendously cost prohibitive item. If not corn, it would be another crop requiring industrial agricultural practices to produce enough feedstock for the manufacturing process. All this water, fertilizer and land would not be used for food, but instead to recreate something that is already cheap and abundant. The cost of land, water, labor, and building infrastructure in Hawaii are close to the highest in the world. Farmers who sell locally grown food have a hard time making a living in Hawaii. Selling crops as food is a much higher use than growing crops to be used in food packaging materials and commands a higher price by consumers. We need to increase the amount of food grown in Hawaii to feed people. Growing crops to be used for packaging material is the not the best use of agricultural land. Growing food for uses other than food consumption drives up the price of food.13 10 "A Comprehensive Evaluation of the Potential Health Risks Associated with Occupational and Environmental Exposure to Styrene", (Journal of Toxicology and Environmental Health, Volume 5,Number 1-2, January—June 2002, published quarterly by Taylor&Francis.) Harvard Center for Risk Analysis, Harvard School of Public Health, Boston, MA. Findings also were published in the Harvard Center for Risk Analysis's Risk in Perspective. 11 httpJ/www.foamfacts.com/health/ 13 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2430252/ This Space Intentionally Left Blank Specific Recommendations for part two of the question: To respond to the statement in box one which asks how to best, "reduce product and packaging waste from entering the ocean," we offer the guidelines set forth in the Malama 808 program. Guidelines can be found here: http://www.malama808.org/malama-808-pledge/. By singing onto this program the County of Hawaii will show that it is committed to preventing all types of plastics, including compostable plastics,from entering the ocean where they will do considerable harm. Preventing trash from entering the ocean is the best way to protect our marine environment. Encouraging industrial agricultural production of crops to be turned into food packaging is not good for the environment. The only truly "environmentally friendly" foodservice packaging is one that is reusable. Reusable packaging is carbon neutral. You don't have to use nitrogen fertilizer to grow it or inflict a very high carbon footprint of shipping products from China to the mainland and then to Hawaii. Consumers can be encouraged to bring their own reusable packaging through public education campaigns at the county level. However, the state health department should first give their opinion on the potential public health risks before any decision is made by this task force. Having consumers hand unsanitized reusable containers across the counter into the food preparation area could create compliance issues with existing health codes. We can't estimate the cost of the County of Hawaii signing onto Malama 808 and adopting best management practices for litter. The cost would have to be researched by the county. We also can't estimate the cost to the County of Hawaii engaging in a public education campaign about litter reduction and the promotion of reusable products. The cost would have to be studied at the County level.