Executive Summary

In an effort to decrease polychlorinated biphenyl (PCB) and other toxic chemical contamination in Washington waters, the Spokane River Regional Toxics Task Force (SRRTTF) is working on multifaceted approaches to reduce loading that include both regulatory and voluntary initiatives. PCBs can be divided into two broad groups based on their origins: legacy and inadvertent. Legacy PCBs were intentionally manufactured for use in products from 1921-1977, and have been banned in the U.S. since 1979 (EPA, 1979). However, they are still found in legacy products such as electrical equipment and old caulking in buildings and may continue to be a source when leaked from contaminated sites (EPA, 2019). Inadvertent PCBs (iPCBs) are currently produced as byproducts from manufacturing other products.

This project addresses inadvertently generated PCBs (iPCBs) that are released into waterways, with a focus on iPCBs from pigments used in newsprint, and in paper and paperboard packaging materials. We address current business and government procurement policies and regulations relevant to iPCBs, and identify potential alternative pigments that are reasonable substitutes for pigments that are high in iPCBs. It builds on prior work prepared by Northwest Green Chemistry for SRRTTF (Heine, 2018). Whether or not iPCBs in pigments used on individual packages and newsprint present a risk to users of those materials is not the focus of this paper. Rather, the issue is that iPCBs in pigments are ubiquitous and provide a steady flow of additional PCBs into products and the environment on a global scale.

Pigments used on paper and packaging materials contaminate recycling streams that hinder both recycling businesses and our collective ability to achieve a safe and healthy ‘circular economy’. A circular economy is defined by Geissdoerfer, Savaget, Bocken, and Hultink “as a regenerative system in which resource input and waste, emission, and energy leakage are minimised by slowing, closing, and narrowing material and energy loops. This can be achieved through long-lasting design, maintenance, repair, reuse, remanufacturing, refurbishing, and recycling“ (2017, p. 762). Additionally, calls for a circular economy are growing. An economy that 1) eliminates waste and pollution by design, 2) keeps products and materials in use, and 3) regenerates natural systems.

Another consequence of the continued discharge of iPCBs into waterways is that it decreases the effectiveness of expensive, ongoing remediation efforts designed to protect human and environmental health. This is occurring at a time when the government in China, the primary destination for paper and plastic wastes for many years, is no longer accepting these wastes for recycling. There is a growing call to action to address plastic and other wastes that pollute the ocean and other water bodies.

To advance movement toward a circular economy, prevent iPCB exposure to humans and the environment, and ensure recycling infrastructure can support domestic demand, a number of leading companies and local government agencies have created procurement policies or enacted regulation. Procurement and regulation are two potential pathways to increase adoption of alternative pigments and process controls and encourage innovation. This advances the 6 circular economy by decreasing and eventually eliminating contaminants from the circular material stream. In this report, we review current regulations and procurement policies that address iPCBs from pigments and identifying promising practices and innovation opportunities.

We also identify alternatives to pigments known to contain iPCBs after summarizing pigment and iPCB chemistry considerations. Our initial focus is on yellows and blues/greens as they constitute the bulk of iPCB generation from pigments. Future work should include consideration of other pigment colors. We identify opportunities for process controls or synthesis modifications that limit or eliminate iPCB formation, as well as alternative pigments whose syntheses are unlikely to generate iPCBs. It is outside the scope of the project to address the hazards or life cycle impacts of these alternatives. However, this is important alternatives assessment work that is recommended to ensure that the recommended alternatives are not regrettable substitutions.

The purpose of this research and report is to educate SRRTTF members and other interested parties on the chemistry, supply chain considerations, regulations, and business procurement policies related to iPCBs. It is intended to provide actionable intelligence for next steps to reduce iPCBs effluent into the Spokane river. By identifying sources, preliminary alternatives, drivers for change including regulation and voluntary corporate procurement policies, and interested parties SRRTTF can take the next strategic step. A workshop to address gaps in current technology or information, to convene interested parties, and to create, harmonize, adopt, or implement iPCB procurement is recommended.

Using, in part, the information gathered and questions raised in this report, and in line with the goals of the SRRTTF, we recommend pulling together stakeholders from the newsprint and paper and paperboard packaging supply chain, including users, recyclers and other disposers, and impacted communities to develop unified procurement and substitution approaches and to identify the most critical ongoing research needs. The SRRTTF is in initial planning stages for such a workshop, with a focus on discussing solutions and identifying action steps. Our vision includes forming workgroups to advance solutions and take action to reduce and eventually eliminate iPCBs in pigments. Recommendations for potential workgroup topics and suggested participants and expert speakers are included in this report.