The EveryBusiness

Guide to California’s

Raymond Communications, Inc.

C. Neale Merriam, Ph.D. Polymeric Materials Consulting

Alexandra Fletcher TricorB rau n

0 1999 Raymond Communications Inc. All rights reserved; no reproduction without permission

- A -- About The Publisher:

Michele Raymond is president of Raymond E-> - - - - - - - Communications, Inc., publisher of STATE RECYCLING LAWS UPDATE and Recycling Laws International. Raymond has been covering plastics, packaging, and recycling policy since 1987. The firm also publishes special reports, and provides custom research. Reports include Purchasing Preferences for Recycled Products: Guide to Laws; Transportation- Packaging & the Environment; Getting Green Dotted: the German Recycling Law Explained in Plain English; Battery Recovery Laws Worldwide; Recycling & Solid Waste in Latin America.

TRICOR The Puckaging Industry's On/y Super Ownbutor

With more than 28 locations across North America, TricorBraun is the largest supplier of glass and plastic containers, cllosures, dispensers and tubes in North America. TricorBraun represents every major container manufacturer in the USA, and maintains several strategic supplier relationships in Europe and the Pacific Rim. TricorBraun is the leader in the development of new package designs in both glass and plastic, and is a stocking distributor of closures, pumps, sprayers, pharmaceutical cotton & rayon coil, flexible pouches, and other ancillary packaging components.

Victor Bell is President of Environmental Packaging International, where he is working on environmental packaging issues, pollution prevention, solid waste management, waste reduction, recycling and environmental policy with public and private sector clients worldwide. Mr. Bell is a Certified Packaging Professional (CPP) and has more than 20 years experience dealing with environmental issues.

C. Neale Merriam is also a consulting professor at Rutgers University. Merriam worked in polymer development at Union Carbide for 31 years, and has been researching all aspects of plastics recycling for the last several years. He holds more than 50 patents in plastics.

Special thanks to attorney Sam Bleicher for reviewing this Guide.

EveryBusiness Guide to California's Plastics Recycli'ng Law

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What is SB 235?

SB 235 was the original law passed by the California Legislature in 1991, at the height of concern over a shortage of landfill space in the states, and a slew of legislative attempts at persuading manufactur- ers to use more recycled material. Plastics posed the most challeng- ing problem to those collecting recyclables, as it has no “traditional” closed-loop markets from big companies, as there are for paper, glass and aluminum. Environmentalists figured the best way to send the message was to1 force the closed loop on plastic packaging.

Despite billions spent on recycling, markets for post-consumer plastic items remain difficult today, because most plastic processors and recyclers are small, and subject to whims of the marketplace. When virgin resin prices decline periodically, companies using post-consumer resins (PCR) tend to move back to off-spec virgin, and the plastics pile up again. Local governments can’t turn the collection spigot on and off easily, as companies can with corrugated. Moreover, companies are increasing their use of plastic, with more complex polymers. So, the plastics problem remains today.

California’s SB 235 requires that unless industry meets a 25% recycling rate for rigid plastic containers (RPC’s) every year, all RPC’s must meet one of three other criteria: they must contain 25% post-consumer recycled content, be source-reduced IO%, or be reusable or refillable.

PET must achieve a1 55% recovery rate to be exempted from the recycled content maindate.

In 1996, industry got an exemption for food, and cosmetics containers - though food is incliided in counting the recycling rate.’ During the intervening years, and the wait to “count” rate, most con- tainer manufacturers ignored the law, figuring either the 25% rate would be met because of the state’s bottle deposit law, or that the state would never enforce the law.

1 . SB 1 I IO, currently before the Legislature, would increase the required recycling rate to 35% and put food and cosmetic containers back into the law.

EveryBusiness Guide to Califomia’s Plastics Recycling Law

In January 1997, the Califomia Integrated Waste Management Board (CIWMB) found that the “all-container” recycling rate was between 23.3% and 25.9%, therefore containers sold in 1995 did not require certification. (The PET recycling rate never reached the required 55% and l would not count on this to happen in the near future). In January 1998, the Board adopted an all-container rate of 23.2%. Because the rate was less than 25%, product manufacturers that used RPPCs during 1996 are required to demonstrate that their containers were in compliance with one of the other criteria -that year.

California is now attempting to enforce SB 235. They mailed certifica- tions to approximately 480 randomly selected manufacturers in summer 1998, and have filed follow up letters to those not responding to the request. At press time, CIWMB had decided to pursue various levels of enforcement actions against 99 companies. Those that appeared the least cooperative, and had made no good faith effort to comply, were going to be pursued legally.

It is too late to ignore this law, however arbitrary it may seem to manufacturers. The following sections provide some general guid- ance to to help you determine if you are covered by this law, some tips on how to persuade your suppliers to help you comply, plus the technical background on the challenges of using recycled plastics in your containers. The first section is from Consultant Victor Bell.

What Containers are covered?

1.1 What is a RPPC?

0 contains a minimum of (8) fluid ounces but not more than five (5) gallons;

0 is made entirely of ptastic, except that the caps, lids and labels may be made of some other material;

0 is a packaging container in which a product is sold, offered for sale or distributed in California;

0 is capable of maintaining its shape while holding a product; 0 is capable of multiple re-closures with an attached or unattached

lid or cap; and 0 is normally used to store a product for at least (7) days.

EveryBusiness Guide to California’s Plastics Recycliiqg Law

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1.2 RPPCs are: I

0

0

0

0

0

An 8 02. or greater plastic bottle with a reclosable top (the top does not have to be plastic) An 8 oz. or greater plastic jar with a reclosable top (the top does not have to be plastic) A reclosable clamshell pack that is capable of holding 8 fluid 02. A reclosable plastic blister package that is capable of holding 8 fluid oz. A plastic box that is capable of holding 8 fluid oz. A plastic cylinder that is reclosable, capable of holding 8 fluid 02.

Plastic bottles are typical RPPCs

least 8 fl. 02. are RPPCs

\

Reclosable clamshells are RPPCs, unless used as service packaging (ie., take

1.3 RPPCs are mot: out food, see 1.3)

0

0

0

0

0

0

0

0

Blister packaging that cannot be reclosed Clamshell's that cannot be reclosed A flexible tube Service packaging that does not normally store a product for 7 days A plastic box that has a least one side or an attached lid that is not made of plastic A blister package that has at least one attached component not made of plastic. Any plastic container that can hold more than 5 U.S. gallons Any plastic container that cannot hold at least 8 fluid oz.

Eve@usiness Guide to Califomia's Plastics Recycling Law

If you are not sure that your container is a RPPC, you can send it to the California Integrated Waste Management Board.

2.1 What containers are exempt

All food, drugs, medical devices and cosmetic containers are exempt from the law. The definitions of food and drugs are quite clear. The definition of cosmetics includes most soaps, under FDA definitions. Additionally RPPC's that hold toxic or hazardous products or are manufactured for use in the shipment of hazardous materials are exempt.

2.2 Are you eligible for a waiver?

You can get a waiver if your product was or is new to the California market. You will then have 12 months to be in compliance.

If you try to claim that it is technologically infeasiblle to use recycled content material or that the FDA will not allow its use, California now requires that you must meet one of the other criteria (see below).

Compliance Options

In January 1998, the Board adopted an all-container rate of 23.2%. Because the rate was less than 25%, product manufacturers that used RPPCs during 1996 are required to demonstrate that their containers were in compliance with one of the other criteria:

3.1 certified by product manufacturers using these con- t ai ne rs . Post-consumer material is defined below. Additionally it is not neces- sary for every RPPC to individually contain 25% plost-consumer materials (see averaging below).

Be made from 25% post-consumer materials, as

Post-Consumer Material

Materials generated by consumer, business, or institutional sources that have served their intended use or completed their lifecycle and would be destined for disposal had they not been diverted from the waste stream for reuse or recycling. One example of post-consumer

EveryBusiness Guide to Califomia's Plastics Recycling Law ! I

1 I material is where used HDPE milk containers are recycled, pelletized and used in the manufacturing ofan oil or beach container.

Post-consumer materials does not include pre-consumer materials or industrial scrap as defined below:

Pre-Consumer Material

Materials and manufacturing by-products directed towards reuse or recycling rather than the waste stream, Pre-consumer material does not include materials and by-products generated by and reused in the original manufacturing process (see Industrial Scrap).

Industrial Scrap

Materials and manufacturing by-products reused within a company’s manufacturing process. One example of industrial scrap is where polypropylene bottles that are rejected at the end of the manufacturing process, are then redirected back to the beginning of the manufactur- ing process, rather than being disposed of or diverted to another company. This material is not considered recycled material. I

EXCEPTION:

Based on a 1995 letter from CIWMB staff, it appears you may count some pre-consumer material in cases where PCR is not available. This must be purchased scrap, that might otherwise be destined for a landfill.

3 .2 Be source reduced compared to a base year, as certified by product manufacturers using these containers;

A “source reduced container” is a container whose weight per unit or use of product has been reduced by 10% when compared with the packaging used for the product by the manufacturer on January 1, 1995 or over the colurse of the first full year of commerce in California. You can not achieve source reduction by substituting a different material type in the container or if you increased the container’s weight after January 1, 1991 and subsequently reduce it again. Therefore, only concentrating the product (Le. concentrating laundry detergent) or reducing the weight of the container may be used to attain comdiance.

EveryBusiness Guide to California’s Plastics Recycling Law

For multiple packaging lines you would sum the toltal annual number of containers sold in California to determine your average reduction (see averaging below).

For example:

A RPPC (that was on the market on 1/1/95) weighing 60 grams (empty) with 1 OOOml (Un units) of laundry detergent and contains enough product for 10 washes (Un uses) can meet the source reduction requirement by:

0

0

0

Reducing the weight of the container by 6 grams, Increasing the number of washes (uses) by 1, or Source reducing the other products in the product line so that the average reduction is 10% or greater.

3.3 Be reusable or refillable, as certified by product manufac- turers using these containers;

A “refillable package” is a package that is routinely (at least five times) returned to the manufacturer or distributor (manulacturer’s agent) and refilled with the original product.

A “reusable package” is a package that is routinely (at least five times) reused by the consumer to store the originial product contained by the package.

For example, a manufacturer sells laundry detergient in a RPPC and sells refills in a plastic pouch. In order for the laundry detergent RPPC to be considered “reusable”, the manufacturer must be able to demonstrate that for every’RPPC sold at least five refills (of the same volume) were sold.

3.4 Have a recycling rate of 45% for the “product- associ- ated” or “particular- type” containers, as certified by product manufacturers using these containers.

4. Averaging

A product manufacturer can achieve compliance by “averaging” the recycling rate, the post-consumer content, the source reduction and/ or the refill or reuse data of its RPPC. An “average” can be calcu-

EveryBusiness Guide fo California‘s Plastics Recycling Law

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lated using data specific to California or nationwide. Averaging can be based on a product line or the entire company’s production.

5. What records do you need?

If you are using recycled content material;

0 Certification frorn the container manufacturer 0 Size, 0 ResinType 0 Weight of all resins used,

Weight of Post-consumer resin 0 Percentage of Post-consumer resin.

If you are claiming tihe source reduction option:

0 Certification frorn the container manufacturer. 0 Size, original weight of container 0 date of introduction of original container 0 weight of source reduced container 0 percent reductioln.

Under the current law, it is impossible to know whether or not Califor- nia will meet the 25% recycling rate until 24 months after you are required to meet it or one of the other criteria. Therefore, we would recommend that all non-exempt 8- ounce to 5 gallon RPPCs be made from 25% post-consumer material, be source reduced, or be reusable or refillable if sold in California. Further, you need the data to prove it.

How Your Packaging Supplier Can Help With Compliance by Alexandra Fletcher, Corporate Communications Manager - TricorBraun

When a product manufacturer decides to take the requirements of SB23 5 seriously - either voluntarily, or because they have been contacted by the California Integrated Waste Management Board (CIWMB) for compli- ance data, the product manufacturer will come to their packaging supplier for containers that comply with the requirements of the law.

EveryBusiness Guide to California’s Plastics Recycling Law

Many packaging suppliers will struggle when faced with this kind of request. Although most have heard of SB235 and are aware of its goals, practical and immediate assistance may be difficult. I recommend that if you have a strong relationship with your current supplier, that you make a commitment to work with that supplier through the challenges that this legislation poses. If the salesperson you work with isn’t sure about how to help you, ask them to go to their manager, to the vice president; keep moving along the chain in the company until you find someone who knows what to do.

If you are serious about compliance, and the packaging supplier you are working with seems reluctant or unable to help, find another supplier that will work with you.

From the packaging supplier’s point of view, first steps .would include evaluating the customer’s current container. The packaging supplier must determine what the possible option may be for the product manufacturer. Can the gram weight of the current container be reduced 10% without adversely impacting hottle integrity? Is there another container of the same style and in the same resin available from a different manufacturer that is lighter in weight? Gram weights often vary between manufacturers, so getting a package to comply may simply be a matter of sourcing the same container elsewhere.

This is when working with a packaging distributor with broad enough re- sources to assess the entire marketplace can really help. The more choices your packaging supplier has, the more choices you have. In this case, a packaging distributor would have more options and more flexibility than a packaging manufacturer.

A packaging supplier with strong design resources can also be of benefit. Some containers can be re-designed to use less resin, while maintaining the same capacity and shelf presence.

For example, in one case we know of, a 3202. PET container that initialljr ran at 28 grams was reduced to 22 grams, simply by modifying the mold by adding ribbing underneath the label panel.

Post consumer resin, when it is available, is another compliance option. If the container you are using can be run with 25% PCR, you should expect to pay about 10% more than you would if the container was run with virgin resins. Availability of PCR continues to be a problem, which drives prices up. Also, I’ve known many to perceive PCR as “dirty,” potentially problem-

EveryBusiness Guide to California’s Plastics Recycling Law 1

1 I atic, or unattractive when it blended into the resin mix. I’ve wondered why a natural “recycled look” that’s so popular in paper hasn’t crossed over to plastic containers.

A way around this “flecked” look is co-extrusion. Co-extruded manufactur- ing methods “sandwich” a PCR layer between two layers of virgin resin. The resin that touches the product, and the resin that is decorated, is actually virgin, but bottle strength and mass is provided by the PCR layer inside. This method - while preferred by many product manufacturers - is not for everyone: the number of container manufacturers who are actually capable of this co-extrusion manufacturing method are few. One advantage is, for example, if you use pearlized resins, your costs could go down because you need to buy less ofthe premium colored material. Using multi-layered containers does severely limit package choice; lead times are typically longer, and minimum orders can be high.

Retroactive compliance - if pursued - is going to be tough. If, in 1996 or 1997 or 1998, your puirchasing department didn’t ask specifically for packag- ing that was in compliance with SB235, the packaging supplier would not have automatically provided it. “In compliance” was not, and still is not, the industry’s default setting. Ask your packaging supplier for support. It’s important to remember that we are all figuring this out together, and the CIWMB certainly knows what the challenges are.

Ifyou use stock containers, your choices will be limited. You should still work with your supplier to fulfill whatever their requirements are in order to run and stock PCR containers. If enough companies ask for PCR contain- ers (increased demand), suppliers will work hard to keep them available (increased supply), and in theory at least, this option should become more cost effective.

And from this moment forth, when you ask your supplier for packaging that complies, be sure document your requests on the purchase order. When your packaging supplier ruins up against technical or PCR resin supply obstacles, document that, and ask your supplier to do the same. Create a strong paper trail. By putting forth a good faith effort to comply, we will discover exactly what the problems are, and learn how to respond to requests from the CIWMB. You will also learn which suppliers can help you with compliance, and which ones cannot.

A few thoughts about Source Reduction Another way to get at source reduction is to take a lesson from what some

EveryBusiriess Guide to California’s Plastics Recycling Law

of the large multinational corporations have done: incre<ase product concen- tration and dowpize. Use a smaller container to deliver the same number of product applications. Proctor and Gamble’s reformulated, concentrated versions of dishwashing liquids Dawn, Ivory and Joy reduced packaging by 16.6%, or 9.7,million pounds per year: 5.5 million pounds of that was plastic, and the other 4.2 million pounds was corrugated.

Reducing packaging and product weight reduces costs of producing and shipping products, a savings that goes straight to the bottom line. Get with your marketing team, talk to your product formulation people, and find out if this is an avenue you could pursue. If it is, ask your packaging supplier to help you source or design a new, smaller container. Downsize 10% or more, and then do your public relations. Tell your customers what you are doing to reduce their packaging costs and to reduce the impact of your packaging on the environment.

Technical Considerations and Issues Encountered when you try to use PCR in Making Containers by C. Neale Merriam Plastics Consultant

The reclamation processes to recover post consumer plastic materials have developed to yield polymers that are adequate to perform in the thermoplas- tic fabrication of new containers as well in meeting all the performance requirements in the end use application. The complexity and cost of the reclamation process is dependent on the level of decont,amination required for the “new” container as well as the volume of the product being re- claimed. For some applications the price of PCR may exceed that of virgin resin.

PET or Polyethylene Terephthalate Foreign solid particulate material such as grit, dirt and metal if not removed during the reclamation process can interfere with normal continuity of the manufacturing process for new containers. Both the reduced output as well as defective containers could increase the costs of utilizing PCR. All wash plants have demonstrated the capability of producing very high quality PCR for the fiber spinning industry which has a higher standard for removal of solids than the manufacture of containers because of the small spinerette channels.

EveryBusiness Guide to California’s Plastics Recycling Law

For non-solid contaminants such as color and food residue, quality color control of bottles fed to the wash system and adequate wash conditions assure the new container manufacturer that his product will meet virgin resin performance requirements.

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PCR PET can be used in food contact and cosmetic applications in several ways. The chemical repolymerization of PET has been demonstrated but is not cost effective in competition with virgin. Multi-layer bottles in which the food contact layer in virgin PET have FDA clearance. As much as 50% by weight PCR PET can be utilized in such a construction. FDA approval has been granted for PCR PET recovered from deposit programs which has been reclaimed under stringent wash conditions. This PCR PET can be used 100% or with mixtures of virgin PET.

HDPE - High Density Polyethylene High density polyethylene reclamation has encountered the same quality problems PCR PET as well as several additional contaminants.

Foreign solid particulate matter sinks in the water separation process while the HDPE floats. In addition, many wash plants melt extrude and filter the HDPE which ensures quality.

Color is a much greater problem with HDPE mainly due to a broad spectrum of colors used for the cosmetic and detergent bottles. One solution is to sort out the natural HDPE milk, juice and water bottles and reclaim a non-color grade of PCR HDPE.

Curbside color bottles when recoGered in mass yield gray blueish green pellet which limits its use in making new container except where deep tones are acceptable for consumer marketing. One of the early uses of colQred HDPE PCR was quart oil containers.

Mixed color washed flake can be color sorted into 3-4 color fractions (yellow, red, blue green, and subsequently color matched with pigment concentrates). In addition to utilizing a lower cost raw material stream, the recovered value of the pigment is significant to the “new” container manu- facturer.

Commercial cfetergent bottle production of colored flake sorted HDPE which meets all the requirements of colored virgin bottles has been demonstrated. Technology for flake sorting HDPE is available from a California HDPE recycler.

EveryBusiness Guide to Califomia’s Plastics Recycling Law

Odor has to be considered in the recycling of HDPE. For milk container the residue milk reacts to form butyric acid which has a very penetrating odor. The butyric acid is absorbed by the HDPE and requires the combination of a stringent hot wash and vacuum stripping during pellet extrusion. A similar problem from perfume in detergent and cosmetic recycled containers is controlled in the same fashion during reclamation. HDPE PCR can be used in food contact or cosmetic applications as a non contact layer in a laminate. The PCR should be sourced from a facility that practices the technology for maximum removal of odor. A letter of no objection has been issued by the FDA for a PCR HDPE made from milk and water containers that have been washed and vacuum stripped under very specific conditions. This technology is available if the market demand develops.

PP - Polypropylene While polypropylene can be processed in a similar way to HDPE, limited quantities of collectable polypropylene are available. The only commercial quantity of recycled polypropylene is post manufacturing scrap. Its qualities depend on the specific processor.

PVC - Polyvinyl Chloride Inadequate volumes (About 150 million pounds) of PCR in the packaging stream has prevented the development of a viable PCR.-PVC. Technology has been demonstrated but scale of operation is uneconomical. Another problem is that one PVC bottle can contaminate a whole load of PET bottles, which tends to hurt plastics recycling economics further. While new separation systems can get most PVC out, the cost of the technology is prohibitive for many operations. On balance any PVC-PCR should be used in non-container applications

PS - Polystyrene Despite efforts to collect post-consumer PS containers in the early 1 9 9 0 ' ~ ~ very little is collected today because of poor economics. There is a commer- cial stream from packing foams, recycled at about 10%. However, there is little or no PCR PS avaiiable for containers.

Multitayer Both PET and HDPE PCR can be used in multilayer construction as dis- cussed in the above sections. Meanwhile, using PET or HDPE means the package theoretically can be recycled in m existing stream and you have a better chance of obtaining PCR - because few other plastics are being recycled from consumers.+

EveryBusiness Guide to Califomia's Plastics Recycling Law

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Other Political Considerations

What Can CIWMB do to us if we don’t comply?

The law allows a fine of up to $1 00,000 per year per company for violations. The board is mulling how they will deat with violators, and getting a response from manufacturers ha been tough. One serious issue is how to determine what you bought in 1996 - as compliance is retroactive.

Why can’t they fix the law?

Board staff has told us they seriously want to amend the law so you don’t have to worry about retroactive compliance. Environmentalists are aware of the shortcomings of the current law. However, they want to use the current bill, SB 11 lO,(sponsored by former CIWMB board member Wesley Chesboro) as leverage -they are happy to see these kinds of amendments but they want something back from industry - like expanding the required recycling rate to 35% or putting food containers back in the law. No action has been yet taken by CIWMB on pushing any amendments in the Legislature, and there seems to be no champion for modest change at this point. There is a

. large industry coalition formed to oppose SB 1 1 IO.

Can I label my container?

About 15 states have laws or regulations regarding environmental labeling, though most defer to the Federal Trade Commission guide- lines. If you use recycled content, you should state what was used in a full truthful sentence preferably, and indicate if it is pre- or postconsumer material. Procter & Gamble and other major firms do use recycled material in their plastic bottles but do not label it be- cause they found it does not help sales. lt may help smaller compa- nies in niche markets, but you must be aware of FTC guidelines. These are explained in STATE RECYCLING LAWS UPDATE Year- End 1998, published by Raymond Communications. If you want to claim that your package is “recyclable” that gets a lot more complex, and again we refer you to our Year-End report. We strongly recom- mend against using “recyclable” unless you check with FTC and legal counsel.

EveryBusiness Guide to California’s Plastics Recycling Law

Are there other environmental packaging laws still in force?

Yes, there are a few packaging laws still on the books in the U.S., but either they are not enforced or are voided. For example, Oregon has a law nearly identical to California’s, but industry met the 25% recy- cling rate, so no action is needed. Wisconsin has a law requiring 10% recycled content in RPC’s eight ounces and over, but you can use pre-consumer (or industrial) material. There seems to be little impe- tus to enforce the Wisconsin law. There are a few plastic bag laws on the books, and perhaps a dozen polystyrene foam restrictions on the books on the city level.

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The City of tos Angeles and North Hollywood passed a resolution (Feb 1999) requiring Miller Brewing to use recycled content in its new plastic beer bottles, and that it pay for the cost of sorting the new material out for recycling. If the beer bottle sbreads, expect to see more local regulation of PET bottles, as recyclers don’t want to mess up the existing stream to PET. Local governments continue to be unhappy about markets for recycled plastics, so we may see some local or state actions in the future.

What if we export?

There are producer responsibility (EPR) laws for packaging now in 28 countries. If you are a manufacturer and have deferred all compli- ance to your distributors overseas, please be aware that if the dis- tributor does not join the appropriate organization or take back, you could be liable for fines. We recommend you follow the issue interna- tionally through Recycling Laws International, our other newsletter. The issues are also covered at our Take it Back! conferences. A conference is planned for California in 1999.

Will EPR come to the U.S.?

State and local governments are unhappy. They are aware of the l a m outside the U.S., and are aware that there are pitfalls. American industry has been pretty effective in muting packaging legislation in the past, even though there is no general packaging lobby. However, as long as the majority of companies are perceived as ignoring or simply fighting current laws like SB 235, environmentalists have more fodder to go back to the Legislatures and ask for more laws.

EveryBusiness Guide to California’s Plastics Recycling Law

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I If the trash situation gets worse because of the flow control situation,

we could see some EPR legislation in a few states. California groups are already researching the idea, as is the Municipal Waste Manage- ment Assn. of the U.S. Conference of Mayors.

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Where do I go for Help?

If you use a distributor, you need to demand they help you comply with SB 235. There will be an upcharge of perhaps 10% if you decide to use recycled content. If you can't find.any PCR (postconsumer recycled resin) for your container, you can try using purchased scrap, or go the source reduction route. See the Tricor Braun section.

If you feel the law is simply unreasonable, and would like to get it changed, you can contact the coalition organized by GMA. We have listed some resources at the end of this section.

To avoid getting caught in the future, may I also recommend you consider getting STATE RECYCLING LAWS UPDATE to keep you informed of any new policy developments in this area. The expanded version of this report, available free to new subscribers, will have a more complete list of resources, and complete design for recycling guidelines, plus our free wall charts.

EveryBusiness Guide to Califomia's Plastics Recycling Law

RESOURCES

Michele Raymond Raymond Communications, Inc.

5111 Berwyn Rd # I15 College Park MD 20740

f a x 301 345-4768 michele@raymond.com

http://www.raymond.com

301 -345-4237

Robin Cotchan Assoc. of Post-Consumer Plastics Recyclers 1801 K Street, NW Washington, D.C. 2006 Phone: (202) 974-5419

E-mail: rcotchan@ameriplas.org Fax: (202) 296-7154

Rick Best Californian's Against Waste 926 J Street, Suite 606 Sacramento, CA 95814 Phone: (916) 443-5422 Fax: (91 6) 443-391 2 E-mail: rgbest@ix.netcom.com Main environmental lobby; wants to expand the law

Victor Bell Environmental Packaging International 38-D Narragansett Ave. Jamestown RI 02835

Fax: 401 423-2226 401 -423-2225

Lance Hastings, Senior Manager, Staff Affairs Grocery Manufacturers of America 915 L Street, Suite 110 Sacramento, CA 95814 Phone: (916) 447-9425 Fax: (916) 447-9439 E-mail: Iwh@gmabrands.com GMA is leading the industry coalition to defeat expansion of SB 235

Sam Bleicher, Attomey Miles & Stockbridge 1400 16"'St. NW WOO Washington D.C. 20036

Fax: 202-737-0097 202-434-8 100

C. Neale Merriam Polymeric Materials Consulting 16 James St. Harvey Cedars, NJ 08008 609-361 -0556

Alexandra Fletcher Tricor Braun 460 N Lindbergh Blvd. St. Louis, MO 63141 800-325-7782 (ext. 704)

Web: www.tricorbraun.com Largest, most diverse packaging distribution organization in North America; 28 branch offices

314-569-5087

EveVBusiness Guide to Califomia's Plastics Recycling Law