Shipboard Pollution Control: U.S. Navy Compliance with MARPOL Annex V (1996)

To the extent that packaging materials are disposed of by release to the ocean environment, consideration should be given to ensuring that these packaging materials are biodegradable and can be assimilated into the ocean without significant harm. Biodegradability has been promoted as an environmental virtue, but care must be taken in selecting materials on this basis. Paper products can be discharged into the ocean outside Special Areas, but various papers treated to enhance moisture resistance may or may not be so handled under Annex V. Wet strength papers, which are impregnated with crosslinked polymers, and polymer-coated papers are classified as plastics under Annex V. Wax-coated paper, on the other hand, would appear to be dischargeable outside Special Areas, assuming that the wax is a “natural” hydrocarbon and not a synthetic low molecular weight polyethylene.

A number of biodegradable polymers are becoming available, e.g., polyhydroxybutyrate-valerate, starch-based polymers, and lactic acid polymers. These materials are all plastics in terms of Annex V and subject to prohibitions against ocean dumping. In addition, these materials are expensive and have less robust physical properties than familiar synthetic polymers. Availability is also a problem.

In any attempt to reduce the discharges of packaging materials from ships, it is obvious that an early priority should be to limit the introduction of packaging materials into the ships. The Navy's submarines have already accomplished source reduction to a very significant degree. Substitution of fountain soft drinks for drinks in bottles or cans, and removal of food and other items from their corrugated shipping containers at dockside and storing them in alternative fashions, are two significant examples. Surface vessels should consider the potential for engaging in similar source reduction activities.

A complete description of source reduction opportunities is beyond the scope of this report. However, several packaging areas are logical targets and can serve as examples for the types of activities which should be considered.

For shipping containers, which are now predominantly corrugated boxes, two major alternative types exist. One is the combination of slip sheets and stretch wrap as a substitute for corrugated boxes. This results in a smaller volume of packaging for disposal. The slip sheets are generally paper-based, whereas the stretch wrap is plastic. Thus although overall volumes are smaller, it does result in an increase in plastic. However, this will be non-food-contaminated plastic, which can be handled relatively easily, and volumes, once compacted, will be much smaller than the corrugated cardboard that is replaced. This substitution is being employed in the commercial sector, though corrugated boxes still dominate.

Another option is to employ reusable shipping containers. These would probably be plastic. Designs that incorporate the ability either to nest or to fold down and stack can significantly reduce the storage space required for empty containers. Since these would be nonfood contaminated, storage should not present as much difficulty as for food-contaminated waste. In fact, storage of empty food distribution containers adjacent to food storage may be feasible. Although the initial investment in reusable shipping containers is larger than for the same number of corrugated boxes, the longer life and avoidance of disposal costs render them highly economical in a variety of uses in the private sector, notably in the

automotive and furniture industries. If goods cannot be acquired already packaged in reusable containers, the savings in disposal costs and associated problems may mean that a repackaging operation is viable. This would also largely eliminate the major problem with reusable distribution packaging—losses of the packages from the system —since they would then stay in the control of the Navy. Cooperation with other branches of the military in this endeavor should also be considered, since the problems of disposal of packaging wastes extend beyond the Navy.

The submarine fleet has already illustrated the savings in packaging waste that can be accomplished by a drastic change in the way these products are supplied. Substitution of machines that dispense drinks into reusable containers results in total elimination of the cans that are currently used. Packaging materials can be limited to the containers that supply the syrup and the carbonation, resulting in a very large reduction in packaging waste for disposal.

Food packaging can be divided roughly into applications where effective and efficient cleaning of the packaging materials can be attained and those where it is difficult to achieve.

Where efficient cleaning can be accomplished, consideration can be given to reusable packages. If packages are to be stored on board, either for reuse or disposal, consideration should be given to nestable or collapsible packages, or other designs that maximize space-efficient stowage of empty containers. Obviously, the volume occupied by both full and empty containers is a significant consideration. It will often be found that plastic packaging materials have advantages over paper, glass, and metal in this regard. Plastic packages will in general have advantages over paper packages in washability.

Where efficient cleaning of food packaging cannot be achieved, on-board storage of contaminated packages clearly presents difficulties for maintenance of sanitation as well as for the livability of the environment. To minimize the difficulties encountered, serious attention should be given to minimizing the volume of food-contaminated materials by source reduction of packaging. In practice, this will often mean substitution of flexible packages for bulkier rigid containers. These flexible packages will often be plastic. Treatment of food-contaminated plastics in the on-board plastics processors and stowage of the plastic discs produced in odor-barrier bags are likely to be satisfactory handling methods for these materials. Attention to source reduction will ensure a minimum volume of waste.

Efforts to use reusable and source-reduced packaging for food products are likely to encounter barriers of lack of availability at a reasonable cost, since it is the Navy's general practice to use commercially available products and packages. Thus, this may well be the area where the Navy will encounter the most difficulty in practicing source reduction. Nonetheless, there are opportunities here.

Nonfood packaging also presents opportunities for the use of reusable and source-reduced package options. Contamination of the used packages by the products may or may not present a problem, depending on the nature of the product. The amount of flexibility the Navy has in specifying reusable or source-reduced packages will also be related to the type of product involved.

Where the items involved are common consumer goods, the Navy may be tied to the available packages employed in the commercial sector. Repackaging, or unpackaging, operations may or may not be feasible. For articles of clothing, for example, the ideal primary (product contact) package is no package at all. For other products, a switch from rigid to flexible packages may be an option, as discussed above for food.

For hazardous materials such as paint, the Navy has already initiated an excellent program to control both the materials and their packages, with significant source-reduction savings in both the materials and their packages.

For goods that are manufactured strictly or mostly for the Navy or other branches of the military, the procuring agencies routinely specify exactly the packages that are acceptable. There are substantial opportunities for source reduction in this area, many of them along the lines discussed above for shipping containers. Here too a switch from rigid to flexible packaging structures may be feasible and result in substantially less packaging waste for disposal.

If the Navy is to indeed work toward zero discharge from ships, the guiding principle is simple: if it goes on, it has to come off. Therefore, the less that goes on, the less that must be managed on board and ultimately off-loaded and disposed of. Further, if it is still useful when it comes off, then it can be reused and therefore does not require disposal. Although zero discharge may require more, or at least different, management on board, the overall impact may be less. Thus, attention should be given to reusable packages, as well as to smaller (less volume) packages.