Packaging Waste Reduction

Metals: Packaging Reuse and the Need for a Definition of Industrial Packaging

By Paul W. Rankin, President, Reusable Industrial Packaging Association (RIPA)

For years, policy professionals at all levels of government have worked tirelessly to promote recycling as means to reduce the amount of solid waste disposed of in landfills. Their efforts have produced measurable environmental benefits. In 1996, for example, Americans recycled 27 percent of the municipal solid waste stream, including about 40 percent of discarded packaging.

Some of this success can be traced to EPA which recommended using "integrated waste management" systems to resolve waste management problems. The Agency’s strategy was to encourage businesses and consumers to employ a hierarchy of waste management options--source reduction, recycling, and combustion--to reduce the amount of solid waste being disposed of landfills.

For purposes of implementation, the agency defined "source reduction" as:

The design and manufacture of products and packaging with minimum toxic content, minimum volume of material, and/or a longer useful life.

Almost as an afterthought, EPA noted that source reduction "could be practiced…through selective buying habits and reuse of products and materials." (Emphasis added.)

At about the same time, Congress enacted "The Pollution Prevention Act of 1990," which enshrined in national policy the concept that toxic pollution emitted from industrial facilities "should be prevented or reduced at the source whenever feasible." This law defined "source reduction, in part, in the following manner:

…any practice which reduces the amount of any hazardous substance, pollutant or contaminant entering the waste stream or otherwise released into the environment…prior to recycling, treatment or disposal….

In subsequent years, various federal statutes, including the Clean Air Act, the Clean Water Act and the Toxic Substances Control Act, incorporated the concept of pollution prevention as a key waste management strategy.

In addition to these federal actions, numerous state solid and hazardous waste management laws and regulations have been written employing the terms "source reduction" and "pollution prevention." Unfortunately, these terms imply different waste management activities from state to state (e.g., recycling, incineration), and focus on varying target audiences, including manufacturers, commercial enterprises and consumers.

More recently, the terms "waste reduction" and "waste prevention" have been added to the waste management lexicon. Regrettably, these terms are not defined in a common manner in the various statutes and rules in which they appear; indeed, they are used interchangeably to refer to programs affecting industrial, commercial and consumer solid and hazardous waste programs, recycling and minimum content issues.

It is not surprising, therefore, that communication between governments and both the public and the regulated community--particularly the packaging industry--on issues related to "pollution prevention" and/or "source reduction" are often confused and, at times, counterproductive.

For years, companies in the reusable industrial packaging business dismissed these oddities as little more than distant battles among outsiders. Laws and regulations rarely addressed directly issues related to the management of industrial packagings, and those that did encouraged, but generally did not require, recycling.

Times have changed, and businesses that use and produce industrial packages are increasingly concerned that the decades old focus on materials recycling has evolved a web of laws and regulations that ignore or, in some cases, discriminate against reuse. Consequently, these companies believe there is a need to develop a system in which the reuse of emptied industrial packages is encouraged and promoted over competing, but less environmentally responsible alternatives such as recycling.

RIPA believes the most practical means to accomplish this goal is to establish a clear, nationally accepted definition for the term "industrial package." This would ensure that, for matters of policy, "industrial packages" could be distinguished from commercial and consumer packagings. Decision makers could easily target specific packaging types or systems when designing and implementing waste management strategies which focus, in whole or in part, on packaging.

The proposed definition should recognize that packaging reuse is most commonly practiced in industrial settings. In fact, it is well established that the industrial packaging production, filling, transport and emptying cycle is materially different than that associated with commercial/consumer packagings. As such, industrial packages are often quite different than those used in commercial/consumer systems. They are generally sturdier than commercial/consumer packages; used often as primary packagings; are commonly designed for reuse; and, are reused regularly.

The definition should not exclude packages of any size or capacity, and should provide a clear means to classify and/or identify packages that may be used for either industrial or commercial purposes. RIPA believes the following definition of "industrial package" fulfills all these basic requirements.

Industrial Package--A package plus any required protective materials, used for the transportation or storage of commodities, the contents of which are not meant for retail sale without being repackaged.

The heart of the definition is the final clause which specifies that the contents of an industrial package may not be sold at the retail (i.e., consumer) level. Thus, packages such as steel, plastic and fiber drums, intermediate bulk and bulk containers, etc. are covered because their contents are virtually always used by industrial sources. Also covered are a wide range of reusable plastic and wooden boxes, as well as jars and bottles containing industrial chemical samples, the contents of which are not sold at the retail level.

Packagings not covered by the definition include fiber boxes used to ship items to retail establishments such as grocery stores and furniture outlets, milk cartons, liquor bottles, etc.

In addition to a new definition for industrial package, RIPA advocates amending the EPA waste management hierarchy, as it relates to industrial packaging, to establish "reuse" as the highest priority, followed by source reduction, recycling, combustion and landfill.

Research has shown that reuse of packaging in the form it was originally intended is environmentally beneficial and saves significant amounts of energy. For example, it takes roughly ten times the amount of energy to manufacture a steel drum as to recondition the same drum, and numerous studies of consumer packaging have shown that refillable containers are far more energy efficient than those manufactured from recycled or virgin materials.

Reuse reduces waste at every level, from extraction and processing of virgin materials to package manufacturing and transport. In addition, reuse provides opportunities to lessen the amount of material ultimately entering the waste stream. For example, if 100 steel drums, each with a capacity of 55 gallons and weighing 30 pounds are used to ship material one-way, one time, the total amount of material that is ultimately disposed of or recycled after four trips will be 12,000 pounds. If the same shipper used a sturdier drums weighing 36 pounds, and obtained four trips per drum, the total weight of material disposed of or recycled after the same number of trips would be 3,600 pounds, a savings of 8,400 pounds of waste.

Even assuming the initial cost of the reusable drum is several dollars higher than the non-reusable drum, this difference is completely erased after one use, and the cost of the reusable drum continues to fall thereafter, even factoring in the costs of processing and transportation.

This example raises one of the most contentious issues facing the reusable industrial packaging industry today--the inadvertent promotion of "lightweighted" packages by governments and recycling advocates. As the example above implies, lighter packages are generally less capable of being reused than those which are heavier or constructed of sturdier (and usually more expensive) material. Unfortunately, the term "source reduction" has come to be interpreted as any means by which packaging waste is reduced.

For this reason, RIPA believes that the term "source reduction," which appears in both the Pollution Prevention Act of 1990 and the EPA solid waste hierarchy, should be amended to preclude practices which obstruct or prevent the reuse of products or materials for the purpose they were originally intended. These actions would send a clear signal that reuse is a top environmental priority.

Policy makers are finally coming to grips with the idea that the limits of recycling are in sight, that recycling cannot take care of all our waste disposal problems, and that recycling is not even the best waste management option. Reuse of products and materials, particularly packaging, is superior in terms of overall environmental impact, is often the best long term economic choice for businesses and consumers.

For more information, contact:
Paul Rankin
Reusable Industrial Packaging Association
www.reconditioners.com

The identification of individuals, companies, and products in this document does not constitute endorsement by the Integrated Waste Management Board and is provided for informational purposes only.

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