Plastic Pellets in the Aquatic Environment - 4.0 Pellet Sources to the Environment

Plastic Pellets in the Aquatic Environment:
Sources and Recommendations

United States Environmental Protection Agency Office of Water (WH-556F) EPA 842/B-92/010 Dec92

5.0 Controlling Pellet Resources

[Table of contents | Executive Summary | Sections 1 · 2 · 3 · 4 · 5 · Glossary | Tables | References ]

The Environmental Protection Agency (EPA) is concerned about the presence of pellets in the aquatic environment for several reasons: (1) pellets are ubiquitous; (2) pellets have been found in considerable quantities in coastal areas of the United States; and (3) laboratory studies and field observations suggest that ingested pellets may harm or kill aquatic wildlife, including several endangered or threatened species. These issues were detailed in Section 3.0 of this report.

Pellets are released to the environment as a result of plastics industry activities, and major transport pathways to the environment were highlighted during the site visits to several industry companies (Section 4.0). During the site visits, Company officials stated that during normal operations, most of the released pellets can be captured easily by existing pellet containment systems. However, under severe weather conditions (heavy rainfall) many of the pellets may escape even the best pellet containment systems. Unfortunately, once plastic pellets are released into the environment they cannot be easily recovered, therefore, the most realistic mitigation measure available is the prevention of discharges.

EPA believes that immediate industry action is needed to prevent pellet releases to the environment. Effective prevention of pellet releases requires both the implementation of appropriate voluntary control measures as well as a regulatory framework. Section 5.1 presents recommendations to the plastics industry for preventing and controlling pellets releases to the environment. The current regulatory framework and steps being taken by the industry to control pellet releases are included in Section 5.2.

5.1 Recommendations to the Plastics Industry

The following recommendations for preventing and controlling pellets releases to the environment were developed based on the site visit observations (described in Section 4.0), knowledge of plastics industry operations, a literature review, industry recommendations (SPI, 1991), and Department of Transportation (DOT) Cargo Security Advisory Standards (49 CFR Part 101). Concurrent with this study, the Society of the Plastics Industry, Inc. (SPI) has also developed recommendations for controlling pellet releases; these recommendations have been incorporated into the following discussion. The specific recommendations are organized according to eight general areas: industry management; education and training; equipment and facilities; routine operations; maintenance and housekeeping; packaging; shipping; and recycling and waste disposal. Table 10 is a summary of the recommendations and indicates the sectors to which to each recommendation applies.

Table 10. Summary of Recommendations to the Plastics Industry According to Industry Sector.

									Tran/
                      Recommendation                          		Prod 	Pack 	Proc
Management 
 Adopt and implement SPI's Pellet Retention Environmental Code. 		●	●	●
 Conduct self evaluations to identify problem areas.			●	●	●
 Encourage information sharing between companies.			●	●	●
 Continuing developing educational materials.				●	●	●
Education and Training  
 Educate key officials and company managers regarding the fate and	●	●	●
   effects and the economic disadvantages of pellet loss.
 Educate company employees regarding environmental hazards and 		●	●	●
   employee responsibility for corrective actions.
 Train pellet handlers to operate equipment, particularly fork lifts,	●	●	●
   in a manner that minimizes the potential for pellet loss.
 Train longshoremen and other cargo handlers regarding proper pellet 		●
   handling procedures.
Equipment and Facilities 
 Install a containment system to capture storm water runoff. 		●	●	●
 Improve dry cleanup procedures.						●	●	●
 Install connecting hoses equipped with valves that will close 		●	●	●
   automatically when the connection is broken.
 Direct the water flow from rail hopper cars and bulk trucks through 	●
   a screen to capture the pellets rather than spilling them onto the 
   ground.
 Seal expansion joints in concrete floors with a flexible material.	●	●	●
 Install alarms in the pellet conveying system. 				●	●	●
 Pave all pellet handling areas, including loading docks and rail 	●	●	●
  sidings.
 Place screening in storm drains.					●	●	●
 Place control devices where they can be serviced without 		●	●	●
   losing pellets.
 Equip bag-handling stations with vacuum hoses to facilitate 		●	●	●
  spill cleanup.
 Use tarps or containment devices to collect pellets as they 		●	●	●
   are spilled.
 Install grating at doorways for wiping feet.				●	●	●
 Modify loading systems so that transfer lines can be completely 	●	●
   emptied, with any residual resin being contained when 
   loading ceases.
Routine Operations 
 Place portable screens underneath connection points when making 	●	●	●
   and breaking all connections.
 Place permanent screens along the exterior edge of the loading docks.  		●
 Completely empty transport and storage vessels before disconnecting 		●	●
   from the conveying system.
 Supervise longshoremen and other cargo handlers during cargo loading 		●
   and unloading to ensure proper pellet containment.
 Inspect cargo immediately upon receipt and note the condition of 		●	●
   shipping containers and parcels on the carrier's receipt.
 Inspect seals on rail hopper cars before unloading.				●	●
 Check outlet tubes for pellets before moving rail hopper cars			●	●
   or trucks.
 Secure outlet caps and seals before moving full or empty rail 		●	●	●
   hopper cars and trucks.
 Insist on handling procedures that minimize punctures and 		●	●	●
   pellet spillage.
 Do not sweep pellets off loading docks and into the water.  			●
 Repair punctured bags immediately					●	●	●
Maintenance and Housekeeping 
 Improve daily and routine housekeeping and spill response procedures.	●	●	●
 Develop SOPs for containing and cleaning up spills. 			●	●	●
 Conduct routine inspections for the presence of loose pellets on the 	●	●	●
   facility grounds, including parking lots, drainage areas, 
   driveways, etc.
Packaging  
 Design puncture-resistant shipping containers. 				●	●
 Use reinforced bags and line containers with puncture-resistant 	●	●
  material.
 Minimize the use of valved bags, or seal valved bags immediately	●	●
  after filling.
 Use sea containers instead of break bulk packaging. 			●	●
 Improve palleting methods.						●	●
 Tape leaks or replace leaking bags immediately.				●	●	●
 Inspect pellet packaging before offloading.				●	●
Shipping Vehicles 
 Use containers for cargo shipping rather than individual pallets.	●	●
 Identify the person responsible for sealing the ports on rail hopper 	●	●
   cars and bulk trucks, and document sealing. 
 Close and secure the rail hopper car valve with strong wire or		●	● 	●
   aircraft cable in addition to the normal sealing mechanism.
 Visually confirm that each compartment and tube of shipping vehicles 	●	● 
   is empty. 
 Inspect interiors of trailers and sea containers for defects that 	●	● 
   may puncture pellet packaging. 
 Consider vandalism exposure when selecting leased track sites.		●	● 
 Avoid on-deck pellet stowage. 							● 
 Do not jettison pellets or containers of pellets.				●
 Seal empty rail hopper cars and bulk trucks before returning them 	●	●
   to shipper.
Recycling and Waste Disposal 
 Store waste pellets in properly labeled containers.			●	●	●
 Inspect and confirm proper handling and storage procedures if an 	●	●	●
   outside vendor is used for waste removal.
 Recycle or resell waste pellets. 					●	●	●
 Check broken and discarded packaging for residual pellets.		●	●	●

Prod: Producers.
Tran: Transporters.
Pack: Contract packagers.
Proc: Processors.
● : checked
source: http://www.epa.gov/owowwtr1/OCPD/PLASTIC/10-recs.html 14apr03

5.1.1 Industry Management

Poor communication between industry management and management of related industries hampers the identification and elimination of pellet release pathways. Despite the SPI efforts to educate the industry, some company managers did not understand the pellet problem and the need to control pellet releases. Information is rarely shared between companies in regard to pellet spillage, the condition of shipped packages, and the receipt of unsealed rail hopper cars.

The following are recommendations for controlling the release of pellets into the aquatic environment through improving industry management practices.

Adopt and implement SPI's 1991 Pellet Retention Environmental Code and 1992 Processor's Pledge. The code and pledge are presented and discussed in greater detail in Section 5.2.3.
Conduct self evaluations to identify problem areas. The checklists developed by SPI (1991) should be used by each sector (Appendix).
Encourage information-sharing between companies. The information transfer should include pellet containment system successes, identification of problem areas (e.g., the manufacturer should notify a processor if the rail hopper cars return with valves open and unsealed), and other industry successes and failures in pellet containment. This communication should extend between companies of the same sector (manufacturer to manufacturer, etc.) and between companies of different sectors (manufacturer to packager, processor to manufacturer, etc). Good examples of information transfer are the Dow Chemical and Paxon Polymers videotapes of their containment systems.
Continue developing educational materials, advertising in trade journals, conducting presentations at professional meetings, sending mailings, and producing videotapes for distribution throughout the industry.

5.1.2 Education and Training

The least expensive and the most effective first step to controlling the release of pellets into the aquatic environment is through education. Many industry officials believe that pellet releases result more from improper employee attitudes than from equipment failure. This would indicate that employee education is critical to the success of any corrective action. Recommendations are to

Educate key officials and company managers regarding the fate and effects of plastic pellets and the economic disadvantages of pellet loss. Despite SPI's efforts, some company officials remain unaware of the environmental impacts of pellets, and, therefore, industry-wide education and education and training within each company is needed. Stress the economic considerations of controlling pellet releases, the economic benefits of recovering and recycling lost pellets, and the economic disadvantages (loss of feedstock, loss of recycling revenues) and regulatory penalties [National Pollutant Discharge Elimination System (NPDES) permit violations] for releasing pellets. Also, use modern teamwork practices to solve problems, and build a consensus and commitment to the task (SPI, 1991).
Educate company employees regarding the environmental hazards of pellets and employee responsibility in instituting corrective actions. If employees feel involved or responsible they may provide simple and useful solutions to eliminating pellet release pathways. This can be accomplished through (1) conduct of employee awareness programs to educate personnel of the need to prevent pellet loss. This could include posting SPI educational material (described in Section 5.2.3), throughout the facilities, particularly in areas where pellets are frequently spilled. A short presentation (i.e., lunchtime seminar) and forum for discussion should be initiated with the employees; (2) establishing boundaries of responsibility for spill response and cleanup (SPI, 1991). For example, designate one or more persons per shift who will be responsible for ensuring prompt and thorough spill cleanup within a specified work area, or for monitoring and managing a pellet retention program; and (3) initiating a system of rewards for creative solutions for pellet containment and exemplary performance in preventing pellet loss to the environment.
Train pellet handlers to operate equipment, particularly forklifts, in a manner that minimizes the potential for pellet loss. For example, train the forklift operators to exercise greater caution when handling pallets of pellets, such as ensuring that the tines of the forklift are properly aligned before contacting the pallet.
Train longshoremen and other cargo handlers regarding proper pellet handling procedures (49 CFR Part 101). CMC (1988) also recommended that these workers be trained in the handling all cargo wastes.

5.1.3 Equipment and Facilities

Many companies have few cooling-, waste-, and storm-water containment systems for controlling the release of pellets from the facility, or methods for immediately controlling spilled pellets. Recommendations for controlling pellet releases to the aquatic environment by improving existing equipment and facilities are presented below.

Install a containment system to capture storm-water runoff from pellet-handling facilities. The design of these systems must take into account worst case storm-water discharges; SPI (1991) recommends a system capable of handling "50- to 100-year high" conditions. Within the containment system, install baffles, skirts, booms, surface skimmers, and vacuum systems to accumulate and remove pellets (SPI, 1991). Two possible containment systems could be installed: (1) an area-specific containment systems in each pellet handling area. Area-specific containment systems would be the primary pellet containment systems and the facility-wide system would serve as a backup; or (2) a facility-wide containment systems, such as the systems used at Companies F and G (detailed in Section 4.2.2). These systems are effective in controlling pellet releases from facilities covering a large area and handling large volumes of pellets.
Improve dry cleanup procedures, particularly in areas subject to storm-water runoff. By allowing pellets to be entrained in storm-water runoff, the pellets are further contaminated by compounds in the storm water (SPI, 1991).
Install connecting hoses equipped with valves that will close automatically when the connection is broken. Hoses of this type are commonly available.
Direct the cleaning water flow from rail hopper cars and bulk trucks through a screen to capture the pellets directly rather than allowing the pellets to spill onto the ground. This simple control measure would immediately capture the pellets at the release point, rather than relying on elaborate passive control systems to recapture the pellets downstream.
Seal expansion joints in concrete floors with a flexible material to eliminate the pellet-collecting contour. Pellets that accumulate in these joints are difficult to recover by broom sweeping, and may have to be recovered either manually or by vacuuming. Sealing the joints would facilitate cleaning and would not interfere with the expansion and contraction of the concrete.
Install alarms in the pellet conveying system that will alert operators to a breach of the system. Increase the capacity of air conveying systems to prevent clogging, and install a bag house or filter bag assembly in the transfer lines to minimize surges in unloading lines that cause pellets to be vented into the environment (SPI, 1991).
Pave all pellet handling areas, including loading docks and rail sidings. Pellets accumulate between paving stones and gravel making pellet recovery difficult if not impossible.
Place screening in storm drains. The mesh of the screening should be smaller than the smallest pellet handled at the facility. Regularly clean the storm drain screens to prevent drain clogging and overflow.
Place control devices, such as bag houses and cyclones, where they can be serviced without losing pellets. If these devices are placed atop silos or bins, pellets accumulate on top of the bins or silos and are washed down by rainfall or blown by wind (SPI, 1991).
Equip bag-handling stations with vacuum hoses to facilitate spill cleanup.
Use tarps or containment devices to collect pellets as they are spilled. This facilitates cleanup, minimizes contamination of the pellets (so that they can be recycled), and permits quick pellet recovery by containing them (SPI, 1991).
Install grating at doorways for wiping feet. During the site visits, pellets were observed in areas of the facilities where only foot traffic could have transported the pellets.
Modify loading systems so that transfer lines can be completely emptied, with any residual pellets being contained when loading ceases (SPI, 1991). Use stainless steel elbows on all transfer lines, and cycle the outlet valves while the air is flowing through the rail hopper car or bulk truck during pellet unloading.

5.1.4 Routine Operations

Whenever pellets are handled there is the potential for pellet spillage, and implementing a few simple practices would decrease the potential for spillage during routine operations. Recommendations for controlling pellet releases to the aquatic environment by modifying and improving routine operations are presented below.

Place portable screens underneath connection points when making and breaking all connections. The screens should be placed under the valve before the connection is made, and remain in place during pellet transfer and valve disconnection. These screens are inexpensive, easily-moved, and are an effective method for containing pellets at the discharge point. For example, the screens used by Company B consisted of a frame made of 2- 4-in. cut lumber that was covered on one side by wire screening (Section 4.3.2). Additional suggestions include (1) use screens when conducting quality control (QC) checks, breaking into conveying systems, etc., (2) conduct sampling only in areas protected by containment procedures (SPI, 1991), and (3) use wide-mouth containers or polybags for collecting pellet samples. These containers have wide openings that facilitate filling (SPI, 1991).
Place permanent screens along the exterior edge of the loading docks. These screens will capture pellets leaking from punctured containers and incompletely sealed bag valves, and those pellets tracked onto the loading dock from other areas of the facility. The screen mesh should be smaller than the diameter of the smallest pellets handled at the facility.
Completely empty transport and storage vessels before disconnecting from the conveying system. This would minimize the possibility of overfilling a vessel and reduce leakage while making or breaking connections.
Supervise longshoremen and other cargo handlers during cargo loading and unloading to ensure proper pellet containment (49 CFR Part 101).
Inspect cargo immediately upon receipt, and note the condition of shipping containers and parcels on the carrier's receipt (49 CFR Part 101).
Inspect seals on rail hopper cars before unloading. Allow only authorized persons to remove the shipping seals (49 CFR Part 101). This ensures that only persons properly trained to prevent or contain pellet spills will break the seals. Document broken seals and the notify the shipper of the seal condition.
Check outlet tubes for pellets before moving railcars or trucks. Visually inspect the connection ports of both the tube and the pneumatic-system hose. Purge lines before unhooking them and lift hoses to assist purging process (SPI, 1991).
Secure outlet caps and seals before moving full or empty rail hopper cars and trucks.
Insist on warehouse and other handling procedures that minimize bag and box punctures and pellet spillage (SPI, 1991).
Do not sweep pellets off of loading docks into the water (SPI, 1991).
Repair punctured bags immediately (SPI, 1991).

5.1.5 Maintenance and Housekeeping

If pellets are not quickly recovered after they are spilled, they will be dispersed and will likely be released into the environment. Therefore, improvements to standard maintenance and housekeeping practices are recommended for controlling pellet releases. These recommendations include the following.

Improve daily and routine housekeeping and spill response procedures both inside and outside the facility. Insist on prompt spill cleanup and make spill cleanup the responsibility of the person(s) causing the spill. Pellets left for someone else to clean up will quickly disperse and recovery of all pellets will be difficult if not impossible. Spilled pellets also poses a safety hazard to the employees.
Invest more time in routine housekeeping. The more often loose pellets are collected, the less likely the pellets are to be released into the environment.
Initiate vacuuming procedures to collect and contain spilled pellets. Pellets are lightweight and broom sweeping may disperse some of the pellets rather than gather them.
Develop standard operating procedures (SOPs) for containing and cleaning up spills (SPI, 1991).
Conduct routine inspections for the presence of loose pellets on the facility grounds including parking lots, drainage areas, driveways, etc. Pellets entrained in storm-water runoff from any area will impact compliance with NPDES permits (see Section 5.2.1).

5.1.6 Packaging

Damaged packaging is a major source of pellet loss to the environment; this fact was evident throughout the site visits. Therefore, several recommendations can be made to prevent pellet loss through leaky packaging.

Design puncture-resistant shipping containers.
Use reinforced bags, such as woven polypropylene bags, and line larger containers with puncture-resistant material.
Minimize the use of valved bags or seal valved bags immediately after filling.
Use sea containers instead of break bulk packaging. Pellets in sea containers cannot be released during shipment.
Improve palleting methods. Move and stack bags immediately after filling to avoid seepage from valves, and stack bags on pallet in tight, interlocking patters. Shrink- or stretch-wrap pallet to stabilize stacks and help contain lost pellets. Use corrugated cardboard caps on the top and on the bottom of pallets to minimize puncturing or tearing bags and to contain loose pellets. Finally, block and brace outbound loads to avoid broken bags in transit (SPI, 1991).
Tape leaks or replace leaking bags immediately (SPI, 1991).
Inspect pellet packaging, particularly pellets bagged in unreinforced paper or cardboard packages/gaylords, before offloading. This will prevent pellet release through the gap between the vehicle and the loading dock.

5.1.7 Shipping Vehicles

Changes to current shipping practices and vehicles can decrease the likelihood of pellet releases to the aquatic environment. Therefore, several recommendations can be made to the shipping industry and users of the shipping industry.

Use containers for cargo shipping rather than individual pallets. The shipping containers will contain spilled pellets and will prevent them from dispersing among other cargo, onto the docks, on the deck of vessels, etc.
Identify the person responsible for sealing the ports on rail hopper cars and bulk trucks and have the person document the completion of the seal (49 CFR Part 101). This will establish the responsibility for correctly sealing the car and a method for tracking the point at which a seal is broken and pellets are released.
Close and secure the rail hopper car valve with strong wire or aircraft cable in addition to the normal sealing mechanism. This redundancy increases the time and effort that a vandal must expend to break the seal and release the pellets. Close hatches and reapply cable seals after inspecting or sampling the pellets. Insist on strict procedures that require outlet caps to be properly closed before rail hopper cars are moved, and request customers to do the same when returning empty cars (SPI, 1991).
Document the condition of bags and cargo containers and rail hopper car seals, and promptly notify the manufacturer of problems (e.g., damaged packages, broken valve seals) (49 CFR Part 101).
Visually confirm that each compartment and tube of shipping vehicles is empty (SPI, 1991). In addition, sweep, blow, vacuum, or rinse the exterior surfaces of loaded rail hopper cars to remove loose pellets before cars leave the containment area. Direct pellet flow into a screened bin or into the containment system. Also, air lance into containers to remove residual pellets in rail hopper cars and trucks (SPI, 1991).
Inspect interiors of trailers and sea containers for damaged walls, defective floors, or other defects that may puncture pellet packaging. Cover defects with corrugated cardboard or, if necessary, insist on a replacement vehicle, sweep or vacuum any loose pellets in trucks or sea containers, and contain and dispose of any pellets from previous shipments properly when cleaning ship holds or sea containers after break-bulk shipments (SPI, 1991).
Consider vandalism exposure when selecting leased track sites. Establish security procedures as needed (SPI, 1991). Advise companies to report problems to the delivering railroad as well as to the shipper, and utilize security personnel.
Avoid on-deck pellet stowage (SPI, 1991). Stow other products on top and place resin containers in ship wells.
Do not jettison pellets or containers of pellets.
Seal empty rail hopper cars and bulk trucks before returning to the shipper. This will prevent loss of residual pellets.

5.1.8 Recycling and Waste Disposal

Many companies either do not recycle waste pellets, or recycle the pellets only sporadically. Minimizing the loss of recyclable pellets into the municipal waste streams could decrease the likelihood of their eventual release into the aquatic environment. Therefore, several recommendations can be made in regard to pellet recycling and the disposal of waste pellets.

Store waste pellets in properly labeled containers. Do not permit loose pellets to accumulate on the ground or on floors (SPI, 1991). Install a minimum of one pellet-specific waste container in each pellet-handling area; separate containers should be used for recyclable and nonrecyclable pellets.
Inspect and confirm proper handling and storage procedures if an outside vendor is used for waste removal. Insist on no-loss-to-the-environment procedures (SPI, 1991).
Recycle or resell waste pellets. Use incineration and controlled landfilling only when recycling or resale are inappropriate. Consider using waste pellets in a fuel blending program (SPI, 1991). Properly handle "heels," and ensure that they are collected and recycled, resold, or disposed of properly. The preferred pellet disposal method is by recycling, followed by reuse, incineration by approved methods, or deposit in a controlled landfill (SPI, 1991).
Check broken and discarded packaging for residual pellets.

5.2 Existing Control Measures

Several measures exist for preventing and controlling the release of pellets to the aquatic environment. An extensive regulatory framework is available that consists of international treaties and Federal legislation; several Federal agencies have developed policies and programs in response to plastic debris-related regulations. Industry has also adopted policies and implemented programs geared toward controlling the release of plastics and, consequently, pellets into the environment. Descriptions of these regulations, programs, and policies are presented below.

5.2.1 Legal Framework

Several legal authorities, such as international conventions and Federal regulations, have been developed for controlling the release of plastic materials into the aquatic environment. This reviews some of the legal authorities for controlling the disposal of plastic wastes from vessels into navigable waters (water-based sources) and the disposal of plastic debris from land-based sources, such as industry and sanitary and storm-sewer systems.

Water-Based Sources
The United States is a signatory to Annex V of the Protocol of 1978 Relating to the International Convention for the Prevention of Pollution from Ships (MARPOL Protocol of 1973/78) (hereafter referred to as MARPOL Annex V). Under the terms of the Convention, MARPOL Annex V became effective on December 31, 1988. The treaty prohibits the at-sea disposal of all plastic wastes generated during normal shipboard operations.

MARPOL Annex V cannot be used as a mechanism for controlling land-based releases of pellets into the environment because the treaty applies only to releases at sea and is not applicable to land-based sources. In addition, MARPOL Annex V applies only to vessels of signatory nations; vessels from nonsignatory nations are not bound by the treaty's restrictions, but signatory nations are obligated to provide facilities for the reception of plastic wastes at ports (Anon., 1988b).

The Marine Plastic Pollution Research and Control Act, Public Law 100-220 (MPPRCA) implements the provisions of MARPOL Annex V by amending the Act to Prevent Pollution From Ships as amended in 1901 (ITF, 1988). MPPRCA also implements several other pieces of legislation introduced in the Congress in 1986 and 1987 (CMC, 1988).0

The MPPRCA specifically prohibits the disposal of plastics at-sea by U.S.-registered vessels in any waters, and foreign-registered vessels in navigable waters (i.e., bays, sounds, other inland waterways, and coastal waters) and the exclusive economic zone (waters to 200 miles offshore) of the United States (ITF, 1988; CMC, 1988). The law assigns the responsibility of developing regulations for implementing the MPPRCA, implementing and enforcing the regulations, and establishing civil penalties for violations to the United States Coast Guard (USCG).

Several requirements of the MPPRCA that are applicable to pellet releases include

Public Outreach - The National Oceanographic and Atmospheric Administration (NOAA) and EPA are required to develop and conduct public outreach programs for educating the public about the problems associated with the disposal of plastic and other debris into the aquatic environment.
Waste-Reception Facilities - All ports and terminals that receive oceangoing vessels of ò400 gross tons or >500,000 lb of commercial fishing products in a calendar year must have adequate waste-handling and waste-reception facilities for collecting shipboard wastes. Pellets spilled on loading docks, ships' decks, and in cargo holds may be considered shipboard wastes (A.T. Kearney, 1991).
Waste Management Plan - All U.S. vessels must develop and implement shipboard waste management plans that address the provisions of MARPOL Annex V. The USCG is authorized to prosecute any vessel, foreign or domestic, that disposes of plastics within 200 miles of the U.S. coast (CMC, 1988).

Another Federal law that may apply to water-based releases of pellets into the environment is the Marine Protection, Research, and Sanctuaries Act of 1972 (MPRSA), which is commonly referred to as the Ocean Dumping Act. Under the MPRSA, no U.S. vessel may transport any material, including plastic, for the purpose of dumping the material into the ocean unless the vessel has a permit to dump from EPA; EPA does not grant permits for the dumping of plastics into the ocean and regulations implementing the MPRSA also prohibit such dumping.

In addition to Federal laws and international treaties to which the United States is a signatory, states and local governments may regulate the disposal of wastes from vessels in waters under their jurisdiction. Bean (1987) suggested that state and local strategies should focus on shore-based or dockside controls, including at-sea waste-storage requirements and provisions for adequate waste-disposal facilities at ports.

Land-Based Sources
The discharge of pellets from outfalls or other land-based point sources into coastal or inland waters is subject to regulation under Section 402 of the Clean Water Act (Bean, 1987). Prior to November 16, 1990, permit guidelines for the plastics industries controlled only the pH of the effluent and did not limit the discharge of solid or suspended particles (Bean, 1987). On November 16, 1990, EPA published the final revisions to the NPDES regulations for storm-water discharges. Section 122 of Title 40 [40 CFR 122.26(b)(12)] defines materials considered to be significant in storm-water discharges and plastic pellets are specifically named as significant materials. Therefore, pellets can be subject to regulation under the NPDES permit guidelines.

The new storm-water discharge regulations require selected industries to obtain NPDES permits for all storm sewers that carry storm water from industrial sites into public waterways (Bain and Mummert, 1991). Applicable industrial discharges include storm-water runoff from industrial plant yards, immediate access roads and railroad sidings, drainage ponds, material handling sites, refuse sites, wastewater sites, equipment handling/main-tenance areas, residual treatment areas, and loading/unloading areas (40 CFR 122.26) (Bain and Mummert, 1991). Areas excluded from NPDES permitting include lands separate from those above mentioned areas, such as employee parking lots where runoff from the lots does not mix with runoff from areas of industrial activity (Bain and Mummert, 1991).

Other Federal laws that may apply to land-based releases of pellets into the environment include

Rivers and Harbors Act of 1899 (Refuse Act) - Although the Refuse Act of 1899 has been superseded by the NPDES permit program of the Clean Water Act, it does contain a prohibition against the unpermitted deposit of "material of any kind" that is likely to be transported into navigable waters, other than what would be carried by sewers (CMC, 1988). According to CMC (1988), it is possible that the Refuse Act of 1899 "could be used to prosecute against, for example, an industrial source of large quantities of plastic pellets or a landfill operated in such a way that refuse could be washed into rivers."
Toxic Substances Control Act (TSCA) of 1976 - Under TSCA, EPA has the authority to require the testing of new and existing chemical substances entering the environment, and, subsequently, the authority to regulate these substances (EPA, 1990a). EPA (1990a) stated that a serious impact of plastics disposal in water bodies is the injury to and death of marine animals that mistake plastics for food. However, EPA has historically applied its authority to substances more acutely toxic than plastic materials, and the focus is on the toxicity of the chemicals and not on the effects of the products in which the chemicals are used (EPA, 1990a).
Resource Conservation and Recovery Act of 1976 (RCRA) - RCRA defines hazardous waste as "a solid waste . . . which because of its . . . physical [or] chemical . . . characteristics may . . . pose a substantial present or potential hazard to . . . the environment when improperly treated, stored, transported, or disposed of." Based on this definition, Bean (1987) considers plastic trash (e.g., pellets in the solid waste stream) to be hazardous waste. Because the focus of the EPA's RCRA program focuses on chemical toxicity and generators that produce this type of waste in the course of manufacturing other products, EPA does not regulate pollution by plastic trash under the authority of the RCRA (Bean, 1987).

Additional strategies to reduce plastic marine pollution from land-based sources should be aimed at state and local governments (Bean, 1987). To date, no states have enacted laws restricting pellet releases, although several states have enacted laws limiting the use of plastic products such as beverage yokes (Bean, 1987) or requiring the use of degradable material in lobster/crab traps and pots (ITF, 1988). Bean (1990) encouraged the development of recyclable or degradable plastics as the solution to plastics pollution (and the growing contribution of plastic to the solid-waste stream), and recommended solid-waste disposal laws of general applicability in lieu of a major shift to degradable or recyclable plastics or nonplastic alternatives.

5.2.2 Government Programs and Policy

The MPPRCA (described in detail in Section 5.2.1) requires that EPA, NOAA, and the Secretary of Transportation jointly develop marine debris public education programs. To date, in addition to the present study, EPA has sponsored several activities that directly address the issue of pellets in the environment (Redford, 1990), including

Preparing the 1990 Report to the Congress, Methods to Manage and Control Plastic Wastes (EPA, 1990a)
Revising NPDES permit requirements for storm-water discharges (40 CFR 122)
Developing a strategy for enforcing provisions of the Clean Water Act in regard to combined sewer overflow (CSO) discharges
Initiating studies of CSOs as sources of aquatic debris, including pellets (EPA, 1992b)
Initiating field investigations of floating debris in harbors of the United States (EPA, 1990b, 1992a; Trulli et al., 1990; Redford et al., 1992)
Initiating a pilot program for monitoring the presence of pellets on U.S. beaches. This program is being conducted in conjunction with the National Park Service.

The National Ocean Pollution Planning Act of 1978 required that NOAA prepare 5-year plans for researching and monitoring ocean pollution, including the problems of entanglement and ingestion of debris by marine organisms. In 1987, NOAA convened a workshop to establish the National marine pollution research priorities. Marine debris was among the top five research priorities and the identification of the pellet sources and effects on the environment were specifically named. The proceedings of the workshop were used to develop the Federal Plan for Ocean Pollution Research, Development, and Monitoring for Fiscal Years 1988-1992.

Under the sponsorship of NOAA and the National Marine Fisheries Service (NMFS), the Shipping Industry Marine Debris Education Plan was developed to educate all commercial vessel operators and crew of the MARPOL Annex V provisions and to encourage voluntary compliance with those provisions (Wallace, 1990). Components of the plan that directly involve pellet releases include

Case studies of current levels of awareness of MARPOL Annex V provisions; the emphasis is on positive-action cases (i.e., those companies that have changed their plastics handling and disposal practices). Model waste-minimization plans are also outlined.
MARPOL Annex V Education Kit containing legal and environmental issues pertaining to the disposal of debris from ships
Liaison with international shipping trade associations as vehicles for disseminating debris-related information (as opposed to contacting each individual shipping company) and placing public service announcements in trade publications to reach all plastics industries.

The Department of Transportation (DOT) does not consider plastic pellets to be acutely hazardous (acutely hazardous substances include explosives, toxic chemicals, etc.) and, therefore, have not developed regulations for transporting pellets or remediating pellet spills from rail hopper cars (Mr. Fred Pritchard, DOT, personal communication, November 1991, Washington, DC). However, DOT has developed Cargo Security Advisory Standards (49 CFR Part 101) for securing cargo transport. These standards were developed based on concerns over the security (prevention of vandalism and theft) of expensive or controlled products (e.g., appliances, alcohol, firearms); engineering/performance resins may be considered in this cargo classification (F. Pritchard, ibid.). Although the Cargo Security Advisory Standards carry no enforcement powers and are intended only to be recommendations, they provide several good suggestions for controlling pellet releases from rail hopper cars in railroad yards and along the railroad right-of-way. Applicable recommendations have been incorporated into Section 5.1.

5.2.3 Industry Programs and Initiatives

In response to the implementation of MARPOL Annex V regulations and increasing evidence of the harmful effects of plastics in the aquatic environment, the plastics industry and merchant shipping industry have initiated programs and developed policies aimed at controlling the release of plastics, including pellets, into the oceans and waterways.

Plastics Industry Programs
In addition to the voluntary cooperation of SPI and the seven companies visited in the present study (Section 4.0), SPI has initiated other activities designed to inform and educate the plastics industries in regard to the effects of released pellets on the environment.

To alert pellet producers of the hazards of pellet releases into the environment, SPI hosted a briefing for pellet producers in September, 1986. Discussions prompted by a Center for Marine Conservation (CMC) presentation on marine debris, as well as presentations of industry pellet reclamation activities, eventually led to a public service campaign (discussed below). In September 1987, the SPI Board of Directors issued an official policy statement in regard to marine debris and the plastics industry's pledge to solve the problem. In regard to pellets specifically, the statement clearly stated that SPI was dedicated to eliminating conditions under which pellets are released by manufacturers and transporters (Bruner, 1990).

In 1987, SPI, NOAA, and CMC jointly initiated a campaign to educate the industry about the hazards of plastics to wildlife. The campaign focused on all types of plastic debris and their respective target audiences. Pellets, whose target audience was the major pellet producers and processors, was one of five target points of the campaign (SPI, 1990). SPI prepared a Marine Debris Briefing and Education Kit for the campaign, which included posters, stickers, brochures, written information, and pellet-related materials carrying the caption Please Don't Feed the Birds including a photograph of a single pellet (see Figure 31 below). The kit was designed so that individual companies could initiate internal information campaigns and educate employees about the environmental hazards posed by pellets. Several recommendations were discussed for controlling pellet releases during manufacture, shipping, and handling. SPI distributed these kits to 1500 SPI-member companies and frequently published portions of the kits in trade magazines. In 1988, the kit was also presented to the international community; SPI President Larry Thomas distributed copies to the International Association of Plastics Directors. By the end of 1989, more than 1000 column-inches of advertisement space (25 appearances in 10 publications) or news coverage had been devoted to the entire campaign (Bruner, 1990; SPI, 1990). These kits continue to be distributed upon request, and the pellet photograph appeared in trade magazines through 1990.

[ Fig. 31 not available at time of access ]

EPA studies between 1988 and 1992 (EPA, 1990b, 1992a,b,c) found that pellet releases continue to be an environmental problem. In response to these findings SPI founded a Resin Pellet Task Force to investigate the problem. In November 1990, following the findings of the Resin Pellet Task Force, SPI initiated a second campaign entitled Operation Clean Sweep, targeted at the plastics industry and its customers (see Figure 32 below). The 1991 Pellet Retention Environmental Code (see Figure 33 below) and the 1992 Processor's Pledge (see Figure 34 below) are an integral part of this campaign. SPI hasasked its member resin-producing companies to sign the Pellet Retention Environmental Code and, thereby, commit to "the total containment of plastic pellets throughout their lifespan and to [operate] in full compliance with environmental laws and regulations impacting on pellet containment" (SPI, 1991). By the end of August 1991, nearly two-thirds of the companies had signed and agreed to the code, and the remaining companies were considering the matter (Mr. Ronald Bruner, SPI, personal communication, August 28, 1991, Washington, DC.). The Processor's Pledge was developed and introduced to SPI's processor members in the summer of 1992 in an effort to make that segment of the industry more aware of the importance of preventing pellet loss. Operation Clean Sweep was introduced to the plastics industry at the National Plastics Trade Show in July 1991, in Chicago, Illinois. The campaign was also discussed with representatives of plastics industries from over 25 countries at the International Association of Plastics Directors in June 1991. SPI is considering development of multilingual copies of the campaign materials for distribution.

[Fig 32 not available when accessed]

[Fig 33 not available when accessed]

[Fig 34 not available when accessed]

Initiatives by Individual Companies
Several companies have initiated programs to control the release of plastic pellets into the environment. Good examples of effective control measures were observed at pellet producer Companies F and G (Section 4.2.2) and contract packager Company B (Section 4.3.2).

Merchant Shipping Initiatives
CMC (1988) reported that the American Institute of Merchant Shipping (AIMS), a national trade association for many U.S.-flagged merchant vessels, has given testimony to the Congress in support of the provisions of MARPOL Annex V. AIMS supports mandatory training of merchant seamen regarding plastic pollution prevention and achievement of compliance with MARPOL Annex V standards.

5.3 Recommendations to Regulators

A logical resource for identifying problem areas within a facility are the Federal, state, and local inspectors that routinely visit the three sectors. This does not mean that these inspectors should be empowered to fine or otherwise penalize the facility operators. Instead, the inspectors could take the opportunity to point out pellet containment and release problems during their routine inspections.

Therefore, the following recommendations have been developed for regulators.

Educate local, state, and Federal inspectors. These inspectors generally have greater access to the facilities than do any other regulatory official. Although the inspectors have no regulatory authority over pellet containment, the fact that a regulatory official identifies a potential problem may encourage better containment practices.
Establish guidelines for sealing the ports on rail hopper cars, bulk trucks, and other shipping vehicles. The DOT Cargo Security Advisory Guidelines, published in 49 CFR Part 101, include several recommendations that have been incorporated into this report.
Encourage shipping companies to notify the shipper and receiver when broken or damaged seals are observed. Although pellets are not considered by DOT to be hazardous materials, spillage by vandalism should be reported to the shipper, particularly if no preventive measures have been taken (e.g., rail hopper car valve not sealed or inadequately sealed).

5.4 Summary of Recommendations

Existing Federal regulations, such as the MPPRCA, provide a basis for requiring controls over the release of all plastic materials, including pellets, into the aquatic environment. Provisions of the recently finalized storm- water discharge rules specifically target pellets in storm-water discharge. All facilities are advised that they need to be mindful of pellet contamination of storm water and the need to comply with any applicable terms of their permit regarding pellets. However, penalties alone cannot control the release of pellets; the penalties can only encourage companies to implement control measures. Ultimately, controlling pellet releases into the environment is the responsibility of the plastics industry, and effective controls should be continued and enhanced through voluntary industry programs.

Controlling pellet releases can begin with proper training and education of plastics industry managers and employees and by increasing awareness of the hazards posed by pellets and of the economic incentives for controlling releases. Capital investments in containment systems may be necessary to control releases at facilities that handle large volumes of pellets, but inexpensive control measures, such as portable screens or tarps, may be adequate for controlling releases at small-volume companies. All facilities could improve routine housekeeping measures by increasing the frequency of sweeping and including the use of vacuums to recover spilled pellets.

In conclusion, several mechanisms for controlling pellet releases are currently available, and most of the mechanisms, such as education, portable screens, and improved housekeeping, would be inexpensive to implement. Facility-wide containment systems have been shown to be effective pellet control mechanisms, but these systems may not be necessary at smaller facilities or at facilities that effectively control pellet spills where they occur.