Keith Christman - Sun Aug 7 10:25:47 2005

The Vinyl Institute has not seen the comment referred to by the Task Group, however, some groups in the past have inappropriately used data from curbside packaging recycling programs to make such claims.

Vinyl’s use in packaging is small and represents only 4% of total plastics in packaging according to American Plastics Council data. Vinyl’s use in building and construction represents a very large fraction of total plastics used in that market -- 65% of all plastics in building and construction in 2004, according to data from the American Plastics Council.

Thus, data on curbside recycling programs cannot be generalized to construction and demolition waste. However, it is worth noting that recent trade industry articles on issues in plastic container recycling point not to contamination but to high demand, especially high export demand, and high prices -- exactly the opposite of what one would expect if PVC were causing contamination problems. For example, an article in Waste Age (“Full Speed Ahead,” April 2005) notes the following with respect to plastic recycling:

Polyethylene terephthalate (PET) and high-density polyethylene (HDPE) have commanded strong prices over the past few years, says Judith Dunbar, recycling manager at the American Plastics Council (APC), Arlington, Va. “I don't see that stopping over the next year.” A burgeoning international economy means strong demand for plastic both at home and overseas. Like aluminum, curbside collection of plastic is down, driving prices up. “With plastic, the demand overseas is so strong that people can't afford to buy it here,” says NERC's Remolador. In fact, more than 30 percent of recycled resin is going to exports, says Robin Cotchan, manager of the Association of Postconsumer Plastic Recyclers, Arlington, Va. That high overseas demand, especially for PET, leaves domestic mills with a large portion of underutilized capacity, Dunbar says. “We want to increase the supply to reclaimers,” Dunbar says, so the APC has focused on grassroots initiatives to improve collection and recovery of usable plastic. The group offers grants to municipalities and organizations that install “on-the-go” receptacles in high-traffic locations such as highway rest stops and community centers. APC also has launched a Web site in California to direct consumers to local collection centers. “Some communities either don't give the right signs or education,” she says. “The key is good education that is concise. Pictures are great. Graphics are great.” She adds that educational marketing does not have to be expensive, but maintaining recycling awareness at the community level is essential to keeping operations profitable. The above-cited article is available on-line at http://wasteage.com/mag/waste_full_speed_ahead_2/index. html

Vinyl as a thermoplastic is inherently recyclable. According to a study conducted for the VI by Principia Partners (1999), some one billion pounds of vinyl was recycled at the post-industrial level, ensuring that 99 percent of all vinyl goes into finished products. Limitations to post-consumer recycling are similar to those of other building materials.

Additionally, the Vinyl Institute has a history of supporting recycling, including funding the development of optical sorters now used in many materials recovery facilities to separate out (3-7) plastics, metal and paper contained in the curbside collection process for PET and HDPE bottles. The PET and HDPE container recyclers have been growing their businesses limited only by the available bottles/containers collected, as the article above indicates.

The vinyl industry also provided funding and technical assistance to facilitate a recycling infrastructure throughout the US. The infrastructure currently collects and recycles approximately 99% of the available pre-consumer vinyl building waste (Principia Partners study). It is expected that this infrastructure will handle vinyl building products as they become available from the post-consumer waste stream.

Here are some examples of companies successfully collecting and recycling vinyl windows, siding and pipe:

Reily Recovery Systems 3 million pounds

East Coast Recycling 15 million pounds

Fryman Recycling Inc. 3-5 million pounds

Arundal Recycling Center >20 million pounds

Nicos Polymer and Grinding >20 million pounds

Recycle Resources Corporation > 20 million pounds

Tom Lent - Sun Aug 7 19:25:52 2005

In tests cited by the EPA, the highest dioxin emissions occurred in secondary smelting operations to recycle metals when the scrap metal was contaminated with PVC plastic (US EPA, The Inventory of Sources and Environmental Releases of Dioxin-Like Compounds in the United States: The Year 2000 Update, EPA/600/P-03/002A). PVC sheathing on copper wire has been identified as a contaminant contributing to dioxin releases in copper smelting. PVC auto parts in automobiles being recycled for steel reclamation has been identified as a contaminant in steel recycling.

PVC has long been identified as a serious contaminant problem in container recycling. PET recycling efforts have been particularly hard hit by PVC contamination because the specific gravities are very similar making mechanical separation difficult: “The primary contaminant to the PET recycling process is any source of polyvinyl chloride (PVC) plastic resin. The presence of PVC when reprocessing and remanufacturing post-consumer PET resin may cause one of several problems, even at very low concentrations.

PVC can form acids when mixed with PET during processing. These acids break down the physical and chemical structure of PET, causing it to turn yellow and brittle. This will render the PET material unacceptable for many high-value end-use applications. In addition, the presence of PVC may result in out gassing of chlorine vapors during certain stages of PET reprocessing. This can increase the cost of control systems or regulatory compliance for the facility operator.”

“The sensitivity of PET to PVC contamination is based on the ultimate end-use application for which the recycled PET is intended, but in general the tolerance for PVC contamination is extremely low. The negative impacts of PVC contamination can occur with concentrations as low as 50 parts per million (ppm). This is an amount equal to less than one PVC bottle ground into an 800-pound container of recycled PET regrind or “flake,” made from thousands of PET bottles. However, many end-use applications have tolerances even lower than that.” (Pacific NorthWest Economic Region, “Best Practices in PET Recycling”, http://www.cwc.org/pet_bp/pbp3-0401.htm). These problems can be expected to adversely affect similar efforts to commodify recycling of building materials.

Brian Whelan - Mon Aug 8 11:12:14 2005

Thank you for allowing us the opportunity to provide additional factual information regarding plastic recycling. Although not directly relevant to the materials being studied, we believe the information on recycling of PVC roof membranes is important and an example that PVC can be recycled. The European Single Ply Waterproofing Association (ESWA) represents the leading producers of thermoplastic roofing membranes in Europe. Together these manufacturers have over 85% market share in Europe. ESWA member companies have had an effective recycling program in place for 5+ years. Old PVC roofs are recycled into new roof membranes. This closed loop processing cycle is the only one of its kind in the European roofing business. Sarnafil Inc., located in Canton MA has been recycling our production scrap and waste for 10 years into walkway materials (we received the Bronze Medal Award 1994 Plant Engineering from Customer Cryogenic Grinding Corp.). Today Sarnafil has 0% waste from production scrap and waste. We will invest almost $1M this year building a recycling plant to take old PVC roofs and recycle them back into our roofing and waterproofing membranes. We will be recycling an estimated 60,000 lbs. of old PVC roofs in the next few months. To insure and promote the recycling of PVC and other building products, we would encourage the U.S.G.B.C. to initiate and award product specific (i.e. roofing, windows)credits/points for using products with significant recycled content. The present credit system for the whole building is not enough to drive the recycling message. As evident in Europe and here with Sarnafil, PVC is the only fully closed loop cycle roof membrane.