The Government Services Administration is considering phasing out single-use plastics from its supply chain and procurement processes, which would have major ramifications for America’s economy and the functioning of its production and service sectors. Due to the size and market power of the GSA, the proposed rule’s impacts would likely ripple through the national plastics economy and the personal plastics economy of individual Americans, who would find their choices to use single-use plastics impacted, perhaps considerably.
On July 7, 2022, the Government Services Administration (GSA) put out an advance notice of proposed rulemaking asking its contractors who make or use single-use plastics to tell the GSA what they think about the Center for Biological Diversity’s proposal that they stop contracting for goods or services that use such materials.
In the notice, GSA poses a long list of questions about the scale and scope of single-use plastics used in goods and services they source through their providers and what it would cost those providers to go along with the plan to ditch the single-use plastics. The class of single-use plastics includes plastic drinking straws, plastic water bottles, plastic packaging materials, plastic grocery bags, plastic cutlery, and many other plastic items often treated as environmental villains of the moment. But it also includes things less commonly considered nuisances, even when found out of place as litter, such as single-use medical containers, products, and devices of many sorts, such as surgical masks.
The GSA appears to be acting on this issue due to the petitioning of the Center for Biological Diversity (CBD). This aggressive group describes itself as a conservation organization “dedicated to the protection of endangered species and wild places.” But in this case, what CBD requests the Government Services Administration to do would not improve global, national, local, or individual environmental health and safety. These proposed actions would, in all probability, most likely compromise those very things.
The Center for Biological Diversity argues that banning single-use plastics aligns with President Joe Biden’s Executive Order 14008, “Tackling the Climate Crisis at Home and Abroad,” which calls for federal agencies to align their activities with the president’s climate change agenda. The crux of CBD’s petition is on page 9:
In furtherance of its stated policy to purchase sustainable products, and in line with its directive to procure environmentally preferable and nonhazardous products, the GSA must issue a rule committing the federal government to reduce and eventually eliminate its procurement and acquisition of single-use disposable plastic products….
Petitioners request that the GSA revise its regulations to reduce and eventually eliminate the acquisition of single-use plastic bags, single-use plastic utensils and straws, beverage bottles, packaging, and other single-use food service items and personal care products.
These revisions should apply to the procurement of single-use plastics for federal government meetings, conferences, and events; food service facilities in leased and custodial buildings; and supplies for federal government operations. In addition, the new regulations should apply to all manners by which civilian executive agencies acquire goods and services, directly or indirectly, including through lease, procurement, contracting, and purchase orders.
We further request that the rulemaking contains exemptions for disability accommodations, disaster recovery, medical use, and personal protective equipment. GSA regulations must clarify that “single-use product” does not include medical products necessary for the protection of public health, or personal protective equipment, including masks, gloves, or face shields.
To give the CBD some credit where it is due, this last paragraph is refreshingly grounded in the reality of real-world tradeoffs—some of them, anyway. More such thinking would improve environmental policy considerably. But there does not appear to be much emphasis on the trade-offs of many problematic elements of CBD’s or GSA’s proposed approach to plastics.
Policy Problem One: First, do no harm (proximal)
Perhaps the first test of sound public policy is the same test used to determine sound medical policy, which is, as the Aesculapians like to say, primum non nocere, or first, do no harm.
It doesn’t take much reviewing of the research literature on the topic of plastic material substitutions to reveal that, in fact, plastic substitutes are usually worse for the environment than plastics, as well as worse for human health and safety. I have written about the downsides of plastics substitutions at some length. My recent piece here examines the Canadian context, where they’re even farther ahead of the United States in pursuing “zero plastic waste.”
So why are alternatives to single-use plastics worse for the environment? One of the biggest reasons for this is that the “reusables,” as I’ll call them, consume more energy over their life cycles than their single-use plastic alternatives. More energy in manufacturing, distribution, utilization, and disposal means greater environmental impacts coming out of the soil (oil production); going into the air (conventional pollutants and greenhouse gases); running off into the water, and going back into the land (landfilling).
The downsides with regard to human health involve something that should be top-of-mind for everyone in the post-Covid-19 pandemic landscape—biological contamination. Single-use products are more likely to be sterile when first used, and they are rarely used again in a context where sterility is essential.
The same is not true for durable plastic alternatives that see regular use involving the same activities where biological contamination is an issue: eating and contact with body fluids.
The research literature on the use of renewable bags is fairly solid on this issue and would extend to renewable alternatives to plastic packaging (for food and medicines, for example). Reusable materials are more likely to be contaminated on secondary and sequential use and are simply less safe.
It should be obvious, but this is one reason why single-use plastics were adopted over reusable materials in the first place, particularly in medical settings, but also with regard to food contamination and preservation.
Policy Problem Two: Also, First, do no harm (proximal-distal)
The second policy problem is the same as the first: The policy is likely to violate the idea of doing no harm—in this case, distally, through its impacts on the economy in which we all live and from whose productive powers we receive all the wonderful goods and services that give us our historically absurdly nurturing quality of life.
From the more proximal economic standpoint of impacts to the American economy specifically, the proposal to get GSA out of the business of participating in the market of single-use plastics can only be a net harm. America’s economy is a high-tech transformation and service economy. America specializes in a certain kind of material and energy transformation, which is the creation and use of advanced technologies, materials, and heaps and gobs of powered gizmos and gewgaws of every sort. That’s our thing. We’re not a nation of farmers anymore. We’re not “hewers of wood and haulers of water,” as some of our Canadian friends have been styled. We’re not a raw natural-resource economy where we just dig up materials found in our environment and trade in them.
We are increasingly a consumer goods and services economy that engages in a vast spectrum of activities requiring a vast spectrum of materials with which to provide those goods and services. And though manufacturing has shrunk as a share of US Gross Domestic Product, America still invents, makes, uses, invents new uses of, and, importantly, sells high-tech goods and services rendered with such goods, in high quantities, at high speed, to as big a market as we can reach.
And plastics have become a significant part of that over a short span of time–only about 60 years since early adoption in the US materials economy.
More distally still (but, to this biologist, no less compelling) is that this entire idea of rationing and restricting access to a useful material such as plastic is unwise from the higher-order perspective of humanity’s evolutionary niche. Unlike other animals, human beings evolved to use technology and energy to transform raw materials into things that let us survive in the places that we otherwise might not, which is most of the surface of the Earth, and compete against animals that would otherwise view us as a light snack, or perhaps a decent lunch. Our transformative capabilities also let us defend ourselves against other humans, some of whom might not have gotten the memo about “cooperation is a better strategy for mutual co-existence.”
This is obligatory stuff woven into human evolution. Humans need to make use of virtually all materials available to them (and need a lot more that are not yet created, like that catalyst that will split water with little energy input) in order to meet their evolutionary imperatives to survive. Banning plastics, arguably one of the singularly most useful materials ever available to homo sapiens (as easily shown through the eagerness with which it has been incorporated into the human materials ecosystem freely, without government compulsion), will needlessly—and obviously—set back humanity’s ability to prosper in a hostile universe.
Summary
The Government Services Administration’s proposal to remove single-use plastics from their supply and acquisition chains at the behest of the Center for Biological Diversity would be detrimental to environmental health and safety from the standpoint of humanity’s evolutionary imperatives, America’s social and economic imperatives, people’s individual imperatives and rights, and the protection of the environment itself, either locally or globally.
The GSA might feel obligated to act on the petition of the Center for Biological Diversity’s anti-plastic demands. However, sound public policy principles would suggest that, at the end of the day, the agency should not give the CBD what it wants. The Government Services Administration should not ban single-use plastics from its supply and acquisition chains. That could only do America more harm than good.