CSPA Aerosol Recycling Initiatives Sustainability for the Aerosol Products Industry

March 13, 2014 SATA Spring Meeting Marriott Perimeter Center Atlanta, Georgia

D. Douglas Fratz Senior Science Fellow & Aerosol Products Division Staff Executive

Washington, DC - USA

OR

“To Be Seen as Sustainable, We Must

Actually Be Sustainable”

Today’s Presentation

• History of CSPA Aerosol Recycling Initiatives

• Assuring Technical Feasibility

• Partnering to Improve Access and Rates

• Encouraging Use of Recycling Logo

• Assuring FTC Green Guides Compliance

• Partnering with Retailers on Reject Recycling

• Striving for Sustainability for the Aerosol Form

History of CSPA Aerosol Recycling Initiatives The 1990s • Establishing Technical Feasibility

• Formation CSPA Aerosol Recycling Task Force

• Factory Mutual Study on Material Recovery Facility (MRF) Risk from Aerosols in Mixed Metal Recycling

• Factory Mutual Safety Guidelines for MRFs

• Partnering with Steel Recycling Institute (SRI)

History of CSPA Aerosol Recycling Initiatives The 2000s

• CSPA/SRI Targeting Acceptance in Recycling Programs

– CSPA Booths at Recycling Conferences to Promote

• Compliance with FTC Green Guides for Recycling Claims

• SRI Tracking of Steel Aerosol Recycling Availability

• SRI “Please Recycle When Empty” Logo

• CSPA Aerosol Guide 9th Edition Section M

• CAPCO Education on Aerosol Recyclability Begins

– Science Teachers and Students Are Initial Focus

History of CSPA Aerosol Recycling Initiatives

The 2010s • CAPCO Consumer Education

• Revised FTC Green Guides on Recycling Claims

• CSPA/SRI Meeting with FTC Officials

• CSPA Open Letter on Aerosol Recyclability

• CSPA/RILA Meeting with EPA on Reject Recovery/ EPA Notice in Federal Register

Factory Mutual

Risk Assessment on Recycling Aerosol

Cans

• Two-Volume Study

• April 1996

Factory Mutual MRF Safety Guidelines

• Procedures for Aerosols

• August 1998

Aerosol Recycling • Aerosol Containers

in Metal Bales

CSPA Aerosol Products Division Recycling Committee

• Formed in 2001

• Primary Early Focus:

• Increase Curbside Program Acceptance

• Increase Aerosol Recycling Availability

• Increase Consumer Understanding

• Increase Rates of Aerosol Recycling

• Collect Support Documents for FTC Compliance for Please Recycle Logos

Promoting Aerosol Recycling - 2000s

Steel Recycling Institute Steel Container Recycling Logo

• CSPA encouraged use

on all steel aerosol products

• SRI data to assure availability to majority of communities

Federal Trade Commission Guides for the Use of Environmental Marketing Claims

• Adopted in 1990s to Assist Product Manufacturers to Assure That All Environmental Marketing Claims are Accurate and Non-Misleading

• Recycling Logos are Used Primarily to Educate Consumers and Increase Aerosol Recycling Rates—HOWEVER

• FTC Considers Instructions to Recycle to be ENVIRONMENTAL MARKETING CLAIMS

Federal Trade Commission Guides for the Use of Environmental Marketing Claims (FTC Green Guides) -1990s/2000s

• “Unless recycling facilities for this container are available to a substantial majority of consumers or communities, the claim should be qualified to disclose the limited availability of recycling programs for the container.”

• SRI Data by the late 1990s: More than 50% of communities with recycling programs accepted steel aerosols with other steel containers.

CSPA Aerosol Guide 2009

• Section M – Aerosol Recycling

• Documents Supporting Recycling Logo

Support Documents for Steel Recycling Logo for Aerosol Products • Collected 15 Key Documents

• 1994 - 2003

• CSPA Aerosol Guide 9th Edition – 2009

• Section M on Aerosol Recycling

• Documents Covered Steel Aerosols Only

Conceptual Proposal for CSPA Aerosol Recycling Promotion Campaign

• First Drafted in 2011

• Components of Campaign

• Encourage SRI Logo for Steel Containers

• Develop Please Recycle Logo for Aluminum Containers

• Assure FTC Green Guides Compliance for Both

• Create Website to Encourage Logos on All Products

• Educate Consumers to Recycle (CSPA/CAPCO)

CSPA APD Member Survey on Aerosol Recyclability Claims/Logos

• Conducted in Early 2012

• 18 Companies; >3000 Products

• 29% of Products With Logo or Recycling Instructions

• Primary Reasons Recycling Instructions Not Used

• Label Space Limitations

• FTC Regulatory Uncertainty

• FIFRA Product Regulatory Uncertainty

Revised FTC Green Guides

• 2010 Proposal; 2012 Final Rule

• CSPA Commented in 2010 on No-CFCs and Recycling

• Final Rule Response to Comments

• Some Clarification on “Free-Of” Claims

• Significant Clarification on Recyclability Claims

• “Substantial Majority” Means 60% of Communities Where Product is Sold

October 2012 FTC Green Guides • “When recycling facilities are available to a substantial majority of consumers

or communities where the item is sold, marketers can make unqualified recyclable claims. The term “substantial majority,” as used in this context, means at least 60 percent. “

• “For example, if recycling facilities are available to slightly less than a substantial majority of consumers or communities where the item is sold, a marketer may qualify a recyclable claim by stating: “This product [package] may not be recyclable in your area,” or “Recycling facilities for this product [package] may not exist in your area.” If recycling facilities are available only to a few consumers, marketers should use stronger clarifications. For example, a marketer in this situation may qualify its recyclable claim by stating: “This product [package] is recyclable only in the few communities that have appropriate recycling facilities.””

SRI Data on Steel Aerosol Recycling Availability • SRI Tracks Steel Container Recycling Availability

• Curbside Recycling Programs

• Drop-Off Recycling Programs

• Resource Recovery (Waste-to-Energy) Programs

• All Programs with Steel Recycling Include Aerosols

• 67.5% of Americans Have Access to One or More of These Programs for Aerosol Recycling

• CSPA/SRI Meeting with FTC Officials in June 2013

Steel Can Recycling Recovery Rates

CSPA Open Letter on Aerosol Recycling

• Finalized November 2013

• All Steel Aerosol Containers

Should Include SRI Logo

• Continued Work Needed on

Aluminum Aerosol Containers

• Replace No-CFCs Logo if

Space is Needed

CSPA Open Letter on Aerosol Recycling – Plans for 2014

• Increase Availability to Non-Members

• Partner with Regional Associations – Distribute to

All Members

• SATA, EAA, MWAA, WAIB, NAA

• Continue Work on Aluminum Aerosol Recycling

Potential Partners for Aluminum Aerosol Recycling Access

• Aluminum Association / Alcoa

• Earth911 Recycling Website

• GreenBlue/Sustainable Packaging Council How2Recycle & Industry-Wide Access to Recycling Data Programs

Aluminum Association http://www.aluminum.org/

• Tracks Overall Aluminum Container Recycling Rates and Availability

Earth911 Recycling Website

Aerosol Cans

The recyclability of aerosol cans depends upon

whether the container is empty or still has liquid in it.

If the product is empty, you can put it in the bin

designated for steel or aluminum at your local

recycling facility or curbside program. If the can is

still full, contact your local recycling facility about

disposal options.

http://earth911.com/

GreenBlue/Sustainable Packaging Council

How2Recycle

http://www.how2recycle.info/

Recyclability Reference Summary

GreenBlue/Sustainable Packaging Council

How2Recycle

http://www.how2recycle.info/

GreenBlue/Sustainable Packaging Council Industry-Wide Access to Recycling Data Programs

• Proposed December 18, 2013

• First Meeting Held February 19, 2014

• Overall Goals of Project 1. A fully vetted methodology used industry-wide for access to recycling information.

2. A study conducted regularly using the methodology developed (#1) that:

a. Is facilitated by GreenBlue

b. Is cost-effective and represents a costs savings from individually funded studies

c. Is funded by a variety of stakeholders

d. Includes “proprietary” information for organizations that request it and fund it

e. Eliminates redundancy and duplication of effort

f. Includes both the U.S. and Canada

3. Clear and transparent access numbers used as a basis for categorization in the

How2Recycle Label Program, as well as other uses as determined by the stakeholders.

4. Understand and explore alternatives for consumer recycling search tools.

GreenBlue/Sustainable Packaging Council Industry-Wide Access to Recycling Data Programs

• 25 Attendees at Kick-Off Meeting

• No Consensus on Massive Single Study

• Some Consensus on Usefulness of Developing

Standard Methodology

• Associations Conducting Current Studies Asked to

Submit Methodologies Used

• Awaiting Further Steps

CAPCO Consumer Education

• CAPCO Recycling Education Key Priority

• Partnering with ACE and Keep America Beautiful

• National Science Teacher Association

• Website and Social Media (Facebook, Twitter, etc.)

C A P C O B O A R D M E E T I N G 2 0 1 3 CAPCO - Recycle-Bowl with

Keep America Beautiful

• Competition ran Oct. 15 – Nov. 15, 2013

• CAPCO Promoted at RRC and through Social Media

• CAPCO provided an aerosol recycling fact sheet and classroom experiment

• 1200 kits were sent out and CAPCO was listed as a toolkit sponsor with a link to www.aerosolprodcts.org/recycling

• Recycle-Bowl prominently displayed on FB Fan Page for ARD

• Also posted ARD posts on LinkedIn and several tweets

C A P C O B O A R D M E E T I N G 2 0 1 3

CAPCO - America Recycles Day

C A P C O B O A R D M E E T I N G 2 0 1 3 CAPCO - America Recycles Day

C A P C O B O A R D M E E T I N G 2 0 1 3

CAPCO at 2013 Recycling Conference

Resource Recycling Conference • Attended for the first time

• Aug. 27-28, 2013 in Louisville, KY

• Companies like Nestle Waters, Alcoa and non-profits like

Keep America Beautiful are involved in the sessions and

the conference is also attended by people from MRFs

(Material Recovery Facilities), local officials involved in

waste/recycling, and waste haulers

C A P C O B O A R D M E E T I N G 2 0 1 3

CAPCO at 2013 Recycling Conference

• Dennis Smith from Precise

Packaging volunteered and

was sponsored by EAA.

• Both Dennis and CAPCO

tweeted and had several FB

posts during the conference

• Overall, CAPCO’s attendance

was very well received, and

although many municipalities

do include empty aerosols in

their curbside programs, many

still don’t and there is a lot of

confusion

C A P C O B O A R D M E E T I N G 2 0 1 3

CAPCO at 2013 Recycling Conference

• Continue with Current Activities

– NSTA National Conference

– Earth Day

– Keep America Beautiful Recycle-Bowl

– America Recycles Day

• Incorporate New Initiatives

– Resource Recycling Conference

– Recycling Outreach/Promotion

– Partnership with ACE

C A P C O B O A R D M E E T I N G 2 0 1 3

2014 CAPCO Initiatives

• September 16-17, 2014 at the Hilton Riverside in New Orleans, Louisiana

C A P C O B O A R D M E E T I N G 2 0 1 3

CAPCO - Recycling Conference

CSPA/RILA Initiative with EPA on RCRA

• CSPA Learned in 2012 of Retailer Problem with Rejected Aerosols • Ongoing Efforts by Retail Industry Leaders Association • Participation by Major Retailers

• CSPA Provided Support for RILA/Retailer Proposals to EPA to Decrease RCRA Barriers to Sending Rejects for Recovery • CSPA/RILA Meeting in November 2012 with EPA Officials to Answer Questions About Current Aerosol Technology and Reject Aerosol Recycling and Materials Recovery • EPA Issued Notice in February 2014 to Solicit Public Comments • CSPA Will Comment in Coordination with RILA, Others

Some Final Thoughts on Aerosol Sustainability

• Assuring Aerosol Containers Are Recycled is Key to Assuring the Sustainability of the Aerosol Packaging Form

• Making Aerosol Products Form Sustainable is Key to How Our Customers Perceive Our Products

• Being Perceived as Sustainable is Key to Our Future Growth

2012 Was a Good Year for USA Aerosols

• Highest Unit Production Ever in USA and in North America

0

500,000,000

1,000,000,000

1,500,000,000

2,000,000,000

2,500,000,000

3,000,000,000

3,500,000,000

4,000,000,000

4,500,000,000

Un

its

Year

U.S. Aerosol Unit Production - 1970-2012

0

2

4

6

8

10

12

14

16

Un

its p

er

Cap

ita

Year

U.S. Per Capita Aerosol Unit Sales - 1970-2012

0.000

0.500

1.000

1.500

2.000

2.500

3.000

3.500

4.000

4.500

5.000

Units (

Bill

ion

s)

Actual U.S. Unit Aerosol Production vs. Unit Sales Potential

U.S. Unit AerosolProduction

Unit SalesPotential*

*Sales if 1973 per capita maintained

Summary and Conclusions

• Many issues remain to be resolved.

• These issues will not solve themselves.

• Your help is needed to make the aerosol product form more sustainable.

Thank You! Questions?

D. DOUGLAS FRATZ Senior Science Fellow & Aerosol Products Division Staff Executive

Consumer Specialty Products Association dfratz@cspa.org

Washington, DC - USA