Dear Gentle Persons at the FTC, EDS Group, Inc founded in 1991 created a business unit LABWORKS which has been testing plastics, physical properties, and biodegradability/compost-ability of plastics for the past 5 years. during the course of our research we analyze the environments that we mimic in our laboratory testing. The environments include landfills, anaerobic digesters, commercial composting scenarios. The initiators added to plastics attract the microbes and bacteria normally found in the environment. Research has shown 45% of the 500,000 million pounds of plastics manufactured annually end up in landfills and less than 10% are recycled annually. Microbial counts of 250 million CFU are found in commercial compost, 25 million in Sewage sludge used in anaerobic digesters, and less than 1 million CFU found in landfill leachates we collect frequently. The issue of creating a parameter that a plastic must biodegrade with in a set time period such as 1 year is akin to demanding a foot of snow to melt in 1 week. The conditions that allow snow to melt are obvious. The conditions to allow plastics to biodegrade are similar in the requirements of what is naturally found in the environment ie: ebb and flow similar to the changes in weather and oceanic tidal patterns. Temperatures, moisture, bacteria intensity and population of types of bacteria all contribute to the rate at which a polymeric material will be converted to carbon while emitting CO2, C4H4 gasses. our research has shown the rate of bio-degradation is not linear. The rates for varieties of polymers of differing specific gravities, density,chemical make up also vary and as such rates can run upwards of 20 years. PVC credit cards with 1% initiators are shown to possess 1/2 lies of less than 5 years in a landfill. it is considered highly impractical to demand nature to convert an initiator loaded polymer to biodegrade in 1 year. The oil industry clean up of oil spills are not considered unlawful if the process to clean up a site is not completed with in a 1 year period. We highly recommend to the FTC to consider scientific evidence all found by many labs located around the world who are verifying plastics biodegradability rates up to 20 years and more as compared to an untreated polymer which may be present in the environment for 500 to 1,000 years. We at LABWORKS invite the FTC to our lab for a tour and presentation of data verifying the traceability of microbial density in varying environments which also are controlled by the moisture and temperature within those environments. The opportunity to manage these bacterial environemnts to convert the polymers to energy are of significant value in our energy challenged environment. The FTC Guidelines could be a benefit with practical rates based upon the reality of the tested environments to benefit mankind as compared to limiting a bacterial performance for the benefit of a water soluble plastic.