Objectionable Provisions in Plastics Waste (Management & Handling) Rules, 2011

While the myth about biodegradable and compostable plastics continues to be perpetuated by the plastics industry, it is germane to inquire whether biodegradable and compostable mean one and the same?. Section 2 (d) of Plastics (Manufacture, Usage and Waste Management) Rules, 2011 defines “Compostable plastics” as "plastic that undergoes degradation by biological processes during composting to yield CO2, water, inorganic compounds and biomass at a rate consistent with other known compostable materials and does not leave visible, distinguishable or toxic residue." There are numerous questions about biodegradable and compostable
plastics that require to be addressed before making a Rule that promotes biodegradable plastics.

Section 7 reads "Protocols for Compostable Plastic Materials:- Determination of the degree of degradability and degree of disintegration of plastic material shall be as per the protocols of the Bureau of Indian Standards".
 

Even these so called compostable or biodegradable plastic will persist long enough in the environment to present many of the same potential threats as the traditional plastics.

Do biodegradable plastics contain the plasticizers, such as phthalates or bishneol-A, as the conventional non-biodegrabale plastics do? 

Is there a Rule in India that prohibits the addition of carcinogenic or hormone-disrupting chemicals to plastic products as additives?

Is there a Rule that regulates what kinds of chemical "plasticizers" are typically added to different types of bio-plastics?

What is to stop manipulation of "Determination of the "degree of (bio) degradability" and "degree of disintegration of plastic material"? 

Section 6 (h) reads "the municipal authority shall encourage the use of platic waste by adopting suitable technology such as in road construction, co-incineration etc. The municipal authority or the operator intending to use such technology shall ensure the compliance with prescribed by the competent authority in this regard".

Unless blinded by profit mongers from plastic industry, how can anyone recommend land filling of plastics in the name of road construction? Environmental health impact assessment of plastic materials in road construction is yet to be done, paucity of land for landfill does not mean that the whole country is made into an open ground for dumping plastic waste in the name of road construction.

How can incineration or co-incineration be recommended for plastic waste? Will it not become a source of emission of Persistent Organic Pollutants (POPs) like Dioxins?  New and extensive environmental health risks because of the makeup of the waste stream and its incineration creates toxic air pollution and toxic ash. The air pollutants can affect both the local communities and can travel the jet stream to pollute distant lands and people. The ash may be placed in a landfill, creating the potential for the pollutants to leach into our ground water. Some of the pollutants persist in the environment, accumulating in the environment and in our bodies. 

Incineration cannot be recommended either for disposal or for energy generation. A U.S. Energy Information Administration report lists incinerators as the most expensive way to create energy. At an estimated $8,232 per kilowatt, incinerators cost two times as much as coal plants and 60 percent more than nuclear energy. Incinerator operating and maintenance costs are even more staggering: ten times more than coal, and four times more than nuclear, which explains why incinerators require public subsidies and economic incentives to operate. 

Section 3 (k) deals with "multilayered plastics" means any material having a combination of more than one layer of packaging material such as paper, paper board, polymeric materials, metalised layers or aluminium foil, either in the form of a laminate or co-extruded structure. Section 8 (d) reads: "retailers shall ensure that plastic carry bags and multilayered packaging sold by them are properly labelled" This is hardly sufficient. Environmental groups were expecting a ban on non-recyclable laminated multi-layered plastics and metallic pouches but the possible hazards from multilayered plastics has only been dealt with clumsily and callously.

The recommendation for "adopting suitable technology such as in road construction, co-incineration etc." is highly objectionable also because its use of the word "etc" leaves it quite open ended creating space for  hazardous experimental waste technologies like gasification, pyrolysis and plasma technologies heat waste materials to high temperatures, creating gas, solid and liquid residues. The gases are then combusted, releasing hazardous pollutants.