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Ask 10 people for a definition of plastics or microplastics, or who's responsible for plastic pollution, or how plastic is integrated into their lives, or what they think about plastics, and you likely will hear 10 different answers. Plastic is ubiquitous in our lives these days, found in our cars, our appliances, our furniture, our clothing, our food and cosmetic packaging and household product containers, as well as in an enormous group of products labeled as “disposable,” and more. It also is found in the food we eat, the water we drink, the ground we walk on, the rain that falls from the clouds, and pretty much every aspect of our daily lives.

As part of our continuing coverage of trending global issues, we sat down with 3E subject matter expert Rob Campbell, senior chemical business advisor, for a Q&A session about plastics and microplastics. Prior to joining 3E, Campbell spent over 40 years helping global companies manage their product stewardship and EHS programs. Rob now works with 3E to help prospective and current customers find better ways to identify and address their own stewardship, sustainability, and compliance obligations. Rob holds a BS in Occupational Safety and Health from Indiana University of PA and a MS in Industrial Hygiene from the University of Pittsburgh.

(This interview has been edited for length and clarity.)

3E: You and I have had a few conversations recently about the proliferation of plastic in the environment and the environmental and human health hazards of microplastics. Plastic currently is a hot topic, yet it's been around for decades. Why now?

Rob Campbell: I'll start by saying the topic of plastics in the environment is certainly getting a lot of attention for a range of reasons, but driven largely by environmental nongovernmental organizations (NGOs) that rightfully want to shine a spotlight on this topic. You know when it gets to the point of negotiating a United Nations treaty that it is an important topic to a lot of nations. When it comes to microplastics, we are adding a whole lot of layers of complexity from a scientific perspective.

So where do we start?

First and foremost is figuring out what constitutes a microplastic. This definitional question must consider both the size of the plastic - what is micro - and what in fact is a plastic. This is not a simple answer.

The European Union (EU) grappled with this for several years and addressed it in their 2023 commission regulation that places some restrictions on “synthetic polymer microparticles” (EU 2023/2055). Note they did not use the term “plastic.” Using the leeway they had, they cleverly eased their struggles by limiting the definition to “synthetic polymers” and said “synthetic polymer microparticles” meet the following definition:

They are solid polymers that are contained in particles and constitute at least 1% of those particles or build a continuous surface coating on particles and for which at least 1% of those particles meet either of the following requirements:

  • ≤ 5 millimeters (mm) for all particle dimensions, or
  • ≤ 15 mm for particle length with a length to diameter ratio of more than 3.

5 mm is about the diameter of a pencil eraser, so any solid, human-made polymer the size of a small bead down to a nanoscale particle (>1 million times smaller) is covered here.

What falls outside of the scope of this regulation?

What the EU has said is outside the scope of this regulation is interesting to ponder here. The following are not designated as synthetic polymer microparticles:

  • Polymers that are the result of a natural polymerization process and not chemically modified. [Wood (cellulose), polysaccharides (e.g., starches, certain sugars), and proteins are examples of natural polymers]. While these are excluded, note that some natural polymers are themselves toxic/harmful to human health and the environment. Botulinum toxin is a protein and highly toxic, for example.
  • Degradable polymers in accordance with Appendix 15 “Rules on Proving Degradability” in the regulation.
  • Polymers with a solubility of more than 2 grams per liter (g/L) in accordance with Appendix 16 “Rules on Proving Solubility” in the regulation. As a sidenote, water-soluble and water-absorbing polymers in micron sizes can cause lung damage.
  • Polymers that do not contain carbon atoms in their chemical structure. A number of commercially important synthetic silicone polymers fit this exemption, as do other synthetic, non-carbon polymers.

Just to muddy the waters more, there are the microplastics (micropolymers) that are synthesized and distributed in that fashion - e.g., the plastic pellets that companies make and sell to the molders of plastic articles - and microplastics that form during the product life cycle, such as the breakdown of polymeric articles like a nylon rope or a plastic bag into smaller and smaller fragments.

Comparing the hazards and risks of a 5 mm bead of plastic to a 5 nm (nanometer) particle of that same plastic is comparing apples to oranges because of the completely different behavior of particles at either end of this size scale. Relatively large polymer particles (mm to um (micron) size) can be characterized from a traditional hazard and toxicity perspective - based on the toxicity of ingredients and bioavailability. When you get into the nanoparticle size, the research is still ongoing on deciding how to best characterize the toxicity/hazards/risks.

Using the levers of the precautionary approach and the emotional impact of wildlife ingesting plastic or trapped in plastic debris, the NGOs argue the best approach is to eliminate as much use of plastics as possible with zero plastic being the ultimate goal. The industry side is to discourage all-out bans of any type of plastic by trying to convince the public and regulators of the necessity of plastics/polymers in our lives and arguing that overly restrictive regulation of plastics will do more harm than good. For example, the comparison of the life cycle carbon footprint [for various uses of] plastic when lightweight polymers are used versus the heavy alternatives of glass, steel, or concrete. We can discuss a real-world example of that later.

What are the challenges for companies related to plastics and microplastics?

If you make polymers or use them in your products, the challenges are enormous. Reputational risk - think of food and beverage companies that sell in single-use plastic containers, and liability risk-such as what ExxonMobil and others are spending to turn the tide and defend against lawsuits like those in California and elsewhere, are significant.

Although I am not aware of any personal injury claims for exposure to microplastics in our daily lives, you will likely see these come when more evidence is compiled about exposures and links/associations are made to adverse health effects, much like what happened with glyphosate, talc, and asbestos litigation in the U.S.

Will companies face additional regulations and if so, how tough could these regulations be?

The developed nations are already working on addressing plastic waste with extended producer responsibility (EPR)-type rules and funding research into disposal/recycling technology and some of the fundamental science needed to better characterize the hazards and exposures to microplastics. The EU regulation is a start; more will come. When finalized and ratified by nations, the UN treaty on plastic pollution will lead to the passage of new rules and regulations by countries around the globe. However, this is a lengthy process, measured in years to decades after the passage of the treaty.

What should companies be aware of and what should they be doing to meet any future challenges?

It will be a while until the developing countries get regulations in place on end-of-life plastic/polymer management. Companies need to keep a close eye on what is happening in their own backyard. In the U.S., EPR laws are popping up all over to address plastic packaging, tires, mattresses, and other products that contain polymers of various types and as you can see, the EU is already well down that path and other developed countries are also acting on the issue.

So, if polymers/plastics are important to your business, you need a way to keep up-to-date with the changing landscape. Having digital tools and news services that cover these topics and the people that can provide the strategic guidance/direction towards a different attitude and environment for plastics/polymers will be critically important.

For years, the importance of recycling plastic has been impressed on us. How effective is plastic recycling?

According to everything I’ve read, only about 9% of plastic is recycled. The rest ends up dumped in the oceans or in landfills with some being burned as fuel in municipal solid waste streams. Mechanical recycling technology is solid and getting better and better. Advanced recycling is a broad term for a variety of different methods to treat polymers at the end of life. Some methods are farther along than others, but advanced recycling is still in its infancy but holds great promise.

The challenge for all forms of recycling (even for paper) is economics. Most experts would agree that technology is not the reason recycling rates are low; it is really the economics. To achieve economies of scale for end-of-life plastic recycling, you need a lot of feedstock materials in a relatively small geographic area.

Transporting plastic for hundreds of miles is expensive, which means large countries like the U.S. with spread-out population centers can struggle to justify these costs when there are wide-open spaces where modern landfills or waste incinerators can operate and offer a far less costly end-of-life solution. My guess is that in smaller, densely populated developed countries such as Japan and some EU countries, you will find much greater success with recycling rates.

Does the technology exist to recycle microplastics?

Yes and no. Think about plastic manufacturers and companies that make plastic items. They generate their own in-house waste every day and most of that can be re-processed right on site and turned into perfectly useable product. I have witnessed plastics recycling operations in several countries and what do they do? They turn large pieces of plastics (macroplastics) into microplastics (small chips, fragments) as part of the process of recycling. So, in that regard, the technology exists.

But if you think about true microplastics, those that are micron size or smaller, you are dealing with dust. Much of which is invisible unless you capture it in a bulk form like in dust collectors. The tiny bits of polymer that enter the environment from trash and debris is lost there and not recoverable, and it continues to degrade and break down in the elements. The smaller the pieces/particles, the more surface area on which physical and biological processes can work to transform it into its elements.

Are we drowning in a sea of plastic?

Last time I looked out my window, all I saw was grass and pavement. What about you? Hyperboles make for good advertising and can generate an emotional response, so I understand why the environmental NGOs like it when people and the media promote this idea.

I have traveled to over 50 countries throughout the Americas, Europe, and Asia. I have been in impoverished developing countries and in some of the richest. In my opinion, plastic waste is not the problem, it is a symptom. It is a symptom of economic disparity and opportunity.

Where there is economic prosperity and development, peoples' expectations for a cleaner, more pristine environment are higher. In those countries, the industries, politicians, regulations, and personal behaviors encourage a movement in the direction of cleaner environments. Where people are struggling with obtaining basic necessities and government resources are limited or available but misused/misappropriated, plastic pollution is way down the priority list. This is why over the long-term, I see a global treaty on plastic pollution as a long term - albeit slow - way to address the issue.

I’ve heard it said that plastic was always Plan B for the petrochemical industry once cleaner fuels and power sources proliferated on the market. What are your thoughts on that?

I have no view or insights on that. Talk to some economists and some seers about that topic.

Are people the problem with plastic?

Of course we are. If we didn't exist, we wouldn't need plastics and we wouldn't be having this conversation. But putting aside the existential aspect of the question, the answer is the same: The invention of the first synthetic polymers and the subsequent development of all other synthetic polymers was to answer a demand from someone who needed a problem solved. Without a market, there is no need for the product.

When a product is being designed or developed, decisions are made about the materials of construction based on a whole series of considerations that I tend to group under performance (in all aspects), aesthetics (which can be closely tied to performance), and cost (in production and in service; now including end-of-life costs). This is why you don't see plastic aircraft carriers or steel toothbrushes. They aren't “fit for purpose.” In some cases, different priorities are given to one of these factors. For example, aesthetics might trump cost because the customer will pay for a prettier widget even if it costs more.

That seems counterintuitive. Can you cite an example of this?

Cars are a great example. When cars were first invented, there were no synthetic polymers and that remained the case for decades. Leather, steel, glass, and natural rubber tires were what it took to manufacture a car. Safety and fuel economy were not given much consideration, if any. Even cars in the early 1950s utilized almost no plastics.

Today, the U.S. government sets fuel economy and safety standards for the car companies, none of which could be met utilizing the materials from the early autos. Today, some 10-15% of a car's weight is polymers and plastics of various types, which works out to several hundred pounds. They also make up about 50% of the volume.

If we are looking for the victim, the villain, and the victor in the plastic pollution story, how should we assign the roles to the people that buy the cars, the government that makes the rules for the vehicles, the auto companies that make the cars, and the plastic industry that develop the solutions needed by the industry and consumer to meet those rules?

If I tried to answer that question, I would say that my demand for a vehicle with more value at less cost, both initially and over the life of the vehicle, created the need for synthetic polymers/plastics and my unwillingness to bear the full life-cycle cost from cradle-to-grave makes me, the consumer, both the victim and the villain in this tale.

———–

Editor's Note: 3E is expanding news coverage to provide customers with insights into topics that enable a safer, more sustainable world by protecting people, safeguarding products, and helping business grow. Q&A articles feature our reporters' exclusive 1:1 interviews with regulatory and industry influencers.

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