Guides for the Use of Environmental Marketing Claims, Project No. P954501 #00017 

Submission Number:
00017 
Commenter:
Terry Feinberg
Organization:
Ecosmartplastics
State:
New York
Initiative Name:
Guides for the Use of Environmental Marketing Claims, Project No. P954501

I beleive your proposed revisions of biodegradable and compostable claims is very meaningful, but must take into account new technologies that should be allowed to fall under the new guidelines. My company, Ecosmartplastics(ESP), has developed over the past 15 years(we just starting selling our additives), our ESP-BIO additive that 100% biodegrades most plastics(PE,PP,PS,PET,PVC,BOPP) in any typical landfill, under anaerobic conditions. We have done independent lab tests over the past 10 years, and are even running additional lab tests such as:ASTM-D5511(anerobic biodegradation), ASTM-D6474 (Gel Permeation Chromatography),and OECD 207 (soil toxicity) & OECD 208(plant growth) . These tests are all based on my current ESP-BIO additive load factor of 1.5% in all products being produced currently that 100% prove all our biodegradable and compostable claims. We do not trt to confuse or fool our customers and hide behind any organizations likesome of our competitors do. One example being the Biodegradable Products Institute(BPI), which really only promotes compostable plastics, NOT biodegradable plastics, to the public or business customers. We back up our claims 100% with verifiable and independent testing, which we would be happy to provide to you for reference to make your guidelines meaningful to all businesses that wish to produce "truly biodegradable" products. In addition, we have not gone for the million and one certifications that we beleive have little meaning. We are working on getting a UL certification, since it is the most recognized certification in most major industries, and a recycling certification. All products produced using ESP-BIO additives can be 100% recycled too, because our technology does not contaminate the recycling stream. Our products do not break down till they enter the an active microbial environments, while other technolgies break down faster, but do not biodegrade 100%, such as PLA, OXIo, and cornstarch, and they would not produce strong recycled plastics, while all products containing ESP-BIO additives would. The difference between our additive technology and others is that we DO NOT require a commercial composting facility or any environmental conditions, such as oxygen, heat, light, moisture, or mechanical stress for the plastics to break down naturally. The other technologies (PLA, Oxio, Cornstarch, SugarCaine) all require these to function, but not us. ESP-BIO additive technology is an all natural, vegatative based, proprietary formulation that, when added to existing plastics, makes the plastics attractive and tasty(A food source) to the living micro-oganisms that exist in typical landfills, compost bins and the ocean. The organisms colonize the plastic because of the attraction, and depending on how active the organisms are in any particular environment, make the plastics compostable within 5-7 months, and the plastics 100% biodegrades because of this colonization, within 7 months to 7 years, depending on the amount of plastic for the colonies to consume and turn into Biogas and Biomass. Also, a guiding feature regarding our technology is that it is non-toxic and does not use any heavy metals or catalysts at all, that can harm the environment. In conclusion, I hope that the FTC, in consideration of our new technology that causes biodegradation to take place in a very reasonable timeframe fo 7 months to 7 years, does not limit any labeling of biodegradation to 1 year or less. Plastics typically take hundreds of years to biodegrade, and my ESP-BIO additive technology dramatically reduces this process naturally, safely, and simply. We only make our biodegradability claims that have been 100% verified independently. Reasoanble guidelines should take this into account, and not just classify us with other additive technologies in a general way, because we a definitely unique, new, and worth the extra consideration. Sincerely, Terry Feinberg ESP