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HomeMy WebLinkAboutCOM 0107.038 2016-2018 Murashige, Laura From: Lauren Suzanne Zirbel <laurenzirbel@gmail.com> Sent: Monday, February 20, 2017 11:10 AM To: Council Testimony Subject: HFIA TESTIMONY Attachments: FINAL DRAFT Bill 13_HFIA_Polystyrene_OPPOSE_FEB_2017.pdf HFIA testimony on Bill 13 attached. Tues.Feb 21 1:30 pm COUNTY CLERK COUNTY OF HAWAI'I ,RECEIVED Mahalo! Time V 00 gm, Bir bateFB2 p COMM. No. IO Ref. Ta: ...31 ). Ref. Date MO 0 8 2017 1 Executive Officers: John Erickson,Young's Market Company—Chair "e x Beau Oshiro,C&S Wholesale—Vice Chair Toby Taniguchi,KTA Superstores—Secretary/Treasurer k. John Schilf,Rainbow Sales and Marketing-Advisor 4 Stan Brown,Acosta—Advisor Paul Kosasa,ABC Stores—Advisor HAWAII FOOD INDUSTRY ASSOCIATION Barry Taniguchi,KTA Superstores—Advisor Derek Kurisu,KTA Superstores—Immediate Past Chair Lauren Zirbel,Executive Director 1050 Bishop St. PMB 235 Honolulu,HI 96813 Fax:808-791-0702 Telephone:808-533-1292 http://www.hawaiifood.com TO: COMMITTEE ON ENVIRONMENTAL MANAGEMENT EILEEN 0' HARA, Chair and Presiding Officer HERBERT M. "TIM".RICHARDS,Vice Chair FROM: HAWAII FOOD INDUSTRY ASSOCIATION Lauren Zirbel, Executive Director DATE: FEB. 21, 2017 TIME: 1:30 P.M. PLACE: West Hawai'i Civic Center, Kailua-Kona • RE: Bill 13 Position: Oppose The Hawaii Food Industry Association is comprised of two hundred member companies representing retailers, suppliers, producers, and distributors of food and beverage related products in the State of Hawaii. HFIA is in opposition to this mandate because it will increase costs for consumers and provide no upside for the environment. Without a commercial composting facility that can accept these "compostable" food-packaging items,they are not compostable. All packaging types are bad for the environment if they are littered. We hope that the committee defers this measure and instead passes measures, which address larger waste management issues. Main Points Items packaged in store to be prepared at home,which are used for potentially hazardous products such as raw meats and eggs, use foam trays and egg cartons for the safety and preservation of these items.These types of items are almost always exempted for legislation such as this.Although the language in the"prohibition"section is clear that the intent is for prepared foods the language in the "Required use of recyclable or compostable food service ware" uses different language and does not include the words"prepared foods". This is very dangerous.We talk more about how the definitions in that section will be impossible to comply with later in our testimony. Leaks from alternative containers may burn customers, leaving vendors liable when they are unable to supply suitable containers. Some members have re-evaluated their packaging for to- go orders, and although they were able to replace the vast majority of foam items from their packaging line-up,there are still items that were simply dangerous for transport in any other container. It is unfair to leave a business open to such a huge liability and not provide exemptions for difficult to transport hot items. Specific Bill Drafting Issues There is currently no definition for"recyclable" in the bill,which can be problematic as what is recyclable may change year over year depending on the policies put in place by the State and the County. Currently,virtually no material types are recycled within the state of Hawaii— metals,glass, plastics and paper are all collected and shipped to Asia or the mainland to be recycled there. In contrast, polystyrene is collected and recycled in many regions globally, and is even recycled in Honolulu'. Currently none of the ASTM compostable items are being collected and composted in Hawaii County so it is unclear if they can be included in this definition of compostable. We would request the following changes be considered if the council intends to pass this measure forward, which we hope they do not. Bracketed sections to be deleted, underlined to be added, and comments/reasoning in italics. Division 2. Prohibitions [and Requirements]. Section 20-_. Prohibitions. Food vendors are prohibited, as ofJuly 1,2021 from providing prepared food to a customer in disposable food service ware that is made from polystyrene foam. 2021 is a more realistic start date for companies to find alternative products and the industry to attempt to produce appropriate products to fill the void for dangerously hot items. [Section 20-_. Required use of recyclable or compostable food service ware. a)As of July 1, 2018, all food vendors using any disposable food service ware shall use a suitable recyclable or compostable product.] This section is extremely problematic, as it does not use the same format as the prohibitions section. This section omits the words "providing prepared food". This means that this would apply to meat trays and egg cartons. This would place local eggs and meat at a huge disadvantage to mainland packaged meat and eggs that are transported here in less expensive foam packaging. This would result in more leakage,spoilage, and breakage of local products. It is inappropriate for non-prepared foods to be included in this ban. The results would be disastrous for the local food economy. http://www.epsindustry.org/eps-sustainability/excellence-eps-recycling-award What is "recyclable and compostable"may change from administration to administration depending on the standards used and programs implemented. This will make enforcement difficult. Imagine you are a business owner and you have to change your entire packaging line up every time the State changes their recycling requirements and procedures. This section may be impossible to comply with year over year if the standards change. We currently do not have an acting composting facility in the county so would the products labeled cornpostable actually be compostable?If the state is unable to pay to ship recyclables to the mainland one year are products marked as recyclable still recyclable?If some of the recyclables are incinerated at a power facility are they recyclable? [b)As of July 1, 2018, all county facility users shall use a suitable recyclable or compostable product for disposable food service ware.] Section 20-_. Exemptions. a) Food packaging[outside the limits of the County of Hawai' i ] including but not limited to egg cartons and meat tray sand all packaging used for allproducts that are notprepared foods are exempted from theprovisions of this article: b) Vendors authorized to acceptSupplemental Nutrition Assistance Pro&ra_m (SNAP) benefits. c) Vendors classified as nonprofits by_the IRS. d) Foodpackagin�for food types that commonly are served too hot to be safely_packaged in an alternative_package. We are concerned about the bill's impact on valued partners in the Big Island community, including non-profits and retailers that assist individuals under the Supplemental Nutrition Assistance Program (SNAP). Non-profits rely heavily on food fundraisers. In general,food retailers, which provide food to many low-income individuals, operate at a profit margin of around one percent and small businesses, grocers and non-profits have comparably low or non- existent profit margins. With Hawaii's high prices, Big Island residents and their non-profits and businesses struggle every day to survive. Vendors use polystyrene products as a means of dispensing food because polystyrene is cost effective and sanitary and its sturdiness protects customers from spills and burns. In addition to being FDA approved, polystyrene containers promote food safety and help to keep food fresh for longer periods of time by insulating and maintaining appropriate temperature. There is currently no comparable alternative available that provides the same level of durability, temperature regulation and overall efficacy as polystyrene. Comparing Different Products Impacts on the Environment &Human Health There are very real concerns associated with the manufacturing of biodegradable packaging.A Smithsonian Magazine article (2006)wrote that biodegradable alternatives have considerable drawbacks that haven't been publicized ...for example the cultivation of corn uses more nitrogen fertilizer, more herbicides and more insecticides than any other U.S. crop;those practices contribute to soil erosion and water pollution when nitrogen runoff enters streams and rivers. 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).A 2006 Life Cycle Inventory study by Franklin and Associates showed that polystyrene,when compared to other food service containers, is very efficient in minimizing air emissions and energyTused in the manufacturing process and in reducing the amount of waterborne waste generated during the manufacturing process. This bill makes the false assumption that products that would replace polystyrene are somehow manufactured in a vacuum without the use of any raw materials,energy,or water, or fuel to deliver the product. This is especially important considering many bio-degradable options are produced in China where labor, quality and environmental standards are know to be well below the labor, quality and environmental standards practiced in plants which produce polystyrene here on the island of Oahu. It is important to consider the carbon footprint of shipping supplies from China, especially given that local businesses currently produce a more economically viable product while also providing hundreds of jobs to the community. Extensive studies from the FDA, Health Canada and Environment Canada concluded 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." Concluding Remarks We believe it is unfair to require our local businesses to use packaging alternatives that cost two to three times more than polystyrene products.The only ways to offset this proposed prohibition are to increase prices or to take a substantial financial loss, which may lead to layoffs or closures, leaving people without jobs. Increases to the price of food will also impact Hawaii families and individuals who are already struggling to pay for basic living necessities. We strongly encourage the County of Hawaii to look into establishing a polystyrene recycling program,which would mitigate environmental concerns and reduce solid waste on the island. Please remember that the proposed ban will not be a negligible cost against a large company; rather it will hurt non-profits, school cafeterias, grocers, restaurants, small mom and pop establishments and local families-all struggling with high food and living costs. Financially hurting non-profits and small businesses, fostering job layoffs and closures in the food industry and driving up the price of food for families is not the right choice for Hawaii County and for these reasons we ask that this measure be held. Thank you for the opportunity to submit testimony.