Siddika Sultana, Executive Director at Environmental and Social Developmental Organization (ESDO) Intervention on Plastic Waste Guidelines

Thank you President,

We would like to express our appreciation to the small intersessional working group reviewing and updating the Technical Guidelines. While IPEN welcomes the updated guidelines and the much-improved text around waste avoidance, reduction and mechanical recycling of plastic waste we would like to see stronger text on the need for global rather than national controls on plastic waste including limits on plastic production and an emphasis on waste avoidance. We also remain very concerned about the potential inclusion of chemical recycling in the guidelines.

Chemical recycling is not a new technology. It mainly consists of variants of pyrolysis and gasification technologies that all have long and poor commercial and environmental track records, with large carbon footprints and hazardous waste streams. Most of the output of these technologies when processing plastic waste is not polymer feedstock but low grade hydrocarbon fuel.

The US EPA recently noted that emissions from one plastic waste to fuel plant carried a one in four public risk factor for excess lifetime cancers. This is completely unacceptable since the standard acceptable public risk is one in a million.

IPEN is of the view that chemical recycling should not be included in the plastic waste technical guidance as there is no evidence that demonstrates that it meets the minimum standards of Environmentally Sound Management. ESM is an essential criterion for inclusion of technologies in this and other Basel Convention technical guidance documents, and we are concerned that such technologies may be concentrated in the global south bringing unacceptable exposures and major hazardous waste streams to local populations. We would therefore urge parties to remove chemical recycling from the guidelines until there is credible scientific evidence to suggest it meets the most basic standards of ESM.

Lastly on other matters IPEN is concerned that the guidelines do not adequately address the hazardous characteristics or fluoropolymers and cured resins and effectively suggest they are benign when scientific data suggests the opposite. This must be amended to reflect the true hazardous nature of these polymers.

Thank you.

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