12 Spray May 2016 Pressure Points Doug Fratz CSPA Aerosol Products Division Staff executive Consumer attitude surveys for more than thirty years have shown that recyclability is a key environmental attribute for packaging. A Honeywell study found that 24% of consumers stated that they’d be more inclined to use aerosol products if they could recycle the can. The recyclability of empty aerosol containers is clearly the most important environmental attribute. CSPA has been working for more than thirty years to increase aerosol recycling. The CSPA Recycling Committee was formed in 1992, when the curbside recycling industry was young and growing, and it continues its crucial work today. Early successes were critical: In 1993, only 600 communities were recycling aerosols, but that number increased to 2,600 in two years. At that time, CSPA— under the CSMA name—worked with the U.S. Environmental Protection Agency (EPA) to clarify that household aerosol containers were not hazardous waste, and worked with agencies in Minnesota and Texas to demonstrate that discarded, empty aerosols are recyclable. In 1995, EPA approved the inclusion of recycling as a disposal option on pesticide labels. CSMA also worked with Michigan agencies to create a “Michigan Recycles Aerosols” campaign that included televised public service announcements—featuring television stars Tim Allen and Ed Asner— and also worked with legislators to enact key legislation in California. In 1996, CSMA funded a critical risk study by Factory Mutual engineers to show that aerosol containers in mixed metal recycling do not present a risk at material recovery facilities (MRFs). That was also the year that I first saw aerosols actually being recycled at a recycling facility in Baltimore, MD. In 1998, we worked with Wisconsin and Minnesota to establish statewide policies for accepting aerosols, while Factory Mutual completed a second project: guidelines for aerosol recycling at MFRs. All of these key early documents were included in the 9th Edition of the CSPA Aerosol Guide in 2009. During the 2000s, CSPA and the Consumer Aerosol Products Council (CAPCO) attended recycling and science teacher conferences Aerosol Recycling: Our Key to Sustainability annually to promote aerosol recycling. Another regulatory initiative in the 1990s impacted our efforts: the Federal Trade Commission (FTC) Guides for Environmental Marketing Claims (FTC Green Guides). Under the FTC Green Guides, educational recycling instructions on labels are also marketing claims. In the late 2000s, the CSPA Recycling Committee created an Aerosol Recycling Promotion Campaign to coordinate efforts throughout the aerosol industry to increase aerosol recycling rates. One goal was to convince aerosol marketers to include the “Please Recycle When Empty” message on all products. CSPA surveyed Division members in 2012 and found that just 29% had the recycle message on the label. The main reasons for this result were 1) label space and 2) FTC concerns. Later in 2012, FTC issued revised Green Guides that set new criteria for recycle labeling: 60% or more population availability. This delayed CSPA’s campaign to promote recycle labeling while the new requirement was evaluated. Fortunately, the Steel Recycling Institute (SRI) produced data showing that steel aerosol recycling was above 60% availability, and along with CSPA, shared the data with FTC officials in 2013. CSPA initiated its recycle labeling campaign in December 2013, with an “Open Letter on Aerosol Recycling,” which was distributed to every industry member. The letter recommended that all product labels have the “Please Recycle When Empty” message and suggested that all “No-CFCs” labeling be removed. Removing “No-CFCs” wasn’t just to create label space for recycling language, but also because it had become clear that it may be doing more harm than good. The fact that about half of all product labels bear the claim creates the appearance that others do contain CFCs. My moment of epiphany on this occurred about fifteen years ago while judging a CAPCO Science Class Challenge contest. A very smart and creative teacher had her students bring to class “good aerosols” (with a no-CFC label) and “bad aerosols” (without). All of the CAPCO atmospheric science educational materials did not dispel the teacher’s logical surmise. In 2015, CSPA re-surveyed Division members to see if we were making progress and the results were impressive. Today, 68% of products have “Please Recycle When Empty” on their labels, and more than half of members are continuing work to increase that number. Also, more than two-thirds of members have removed “No-CFCs” from product labels. Last year, CSPA also initiated a cofunded study on recycling availability that includes both steel and aluminum aerosols. Other co-funders come from across the packaging industry. The study is being coordinated through the environmental group GreenBlue. Results will be presented at the Aerosol Products Division Program at the 2016 CSPA Mid- Year Meeting this month. These data will not only provide further confirmation that our labeling meets FTC Green Guides standards, but also provide data we need to target programs not recycling aerosols to further increase availability and to educate consumers to increase their aerosol recycling. Today, more than 7,500 curbside programs and 10,000 drop-off programs accept aerosols for recycling, but we will continue to work to increase acceptance and assure all consumers know they can and should recycle their aerosols. Spray 1 Aerosol Consumer Preferences, USA, presentation by Ken Gaglione, Honeywell, at the CSPA Annual Meeting Aerosol Products Division Program, Fort Lauderdale, Florida, December 8, 2015. 2 Recycling of Aerosol Cans: A Risk Assessment, Volume I: Analysis and Results, Factory Mutual Research Corporation Technical Report J.I.0Y3R3.RE, April 1996. 3 Guidelines for Aerosol Can Recycling in Material Recovery Facilities, Factory Mutual Research Corporation, Technical Report J.I.ODOR8.RM, August 1998.
Spray May 2016
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