Recovering International Recyclables from In-Flight Service (2020)

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4 CHAPTER 1 – INTRODUCTION AND BACKGROUND International air travel continues to grow, and along with it, the quantities of foreign waste from in-flight service. Airlines and airports have efforts in place to manage and reduce waste from these activities; however, the extraction and eventual recycling of recyclables from international in-flight service are often overlooked. Policies and protocols for the handling of waste from international flights are developed to prevent contamination of flora and fauna of the recipient country, which becomes responsible for handling the waste. Despite these potential threats from waste, the occurrence of contamination from these sources is not well documented. A low or non-existent contamination rate may be due to a host of reasons, including the stringent handling and processing prescribed methods. These may include incineration, steam sterilization, and disposal in approved landfills to ensure the protection of host countries from potential disease and infestations. Global findings suggest that the recycling of international waste from in-flight service still occurs despite perceived policy constraints or threats of disease. In general, the higher the attention and importance placed on recycling, the higher the recovery rates. Yet, when compared to other airline environmental initiatives, recycling appears to have a lower priority compared to Greenhouse Gas (GHG) reduction. The USDA APHIS Recycling Material Exemption provides for clear direction on exemptions (USDA 2016) on how the aviation industry and its operators can handle these NCRM. Findings also suggest that the recovery of NCRM is more advanced in settings that already have stringent domestic recycling programs in place. Operational success in one area encourages emulation for international recovery efforts. In general, the production of QW or lack of NCRM recovery results from the absence of globally accepted practices; contamination of recyclable materials in-flight; limited stakeholder engagement; and increasingly complex material streams. Addressing these issues would help decrease QW production. In some cases, a policy may restrict NCRM handling from being separated, collected, or recycled, and stakeholders’ perceptions of these policies may have shaped how airlines choose to handle recycling from international flights. Further findings suggest that in some markets, policies do promote NCRM recovery. For example, in instances where stakeholders worked with a unified collection strategy, a more significant potential in improving recovery was uncovered. Existing QW handling methods minimize the risk of pathways for invasive pests and pathogens. These practices stem from ensuring protection of national economies and industries from contamination. To ensure contamination prevention, QW is removed from inbound international aircraft, and either sent for incineration or steam sterilization before being transported to a local landfill. To minimize the risk of entry of pests and pathogens into the U.S., Customs and Border Protection (CBP) negotiates compliance agreements for handlers and ensures protection of the country. Compliance agreements issued by CBP authorize haulers, cleaners, and handlers to manage the collection and movement of this waste. The CBP or USDA also ensures the regulation of processing facilities with compliance agreements.

5 1.1 Regulated Garbage Regulated garbage is the term used to describe waste that arrives and remains in the U.S. from other countries. The USDA APHIS Recycling Material Exemption defines regulated garbage as unconsumed fresh fruit, vegetables, meat or other plant or animal material, and other refuse of any character whatsoever that has been associated or exposed to any such material. The following is the regulation on the policy definition of regulated garbage extracted from Title 7 Code of Federal Regulations 330.400 - 330.403 and Title 9 Code of Federal Regulations 94.5, regulated garbage is not allowed to be imported, except from Canada (last modified Aug 20, 2018): 1. Regulated Garbage (Foreign Food Waste) includes, but is not limited to, food scraps, table refuse, food wrappers or packaging materials and other waste material from stores, food preparation areas, crews’ or passengers’ quarters and from aircraft or ships generated during international travel. Regulated Garbage also means meals and other foods that were available for consumption by passengers or crew on an aircraft but were not consumed. Plastic disks or plastic waste contaminated with foreign source food and garbage will be managed as Regulated Garbage (U.S. Navy). 2. According to 9 CFR 94.5, regulated garbage is defined as “All waste materials that is derived in whole or in part from fruits, vegetables, meats or other plant or animal (including poultry) material, any other character of refuse whatsoever that has been associated with any such material” (U.S. Code of Federal Regulations). 3. Additionally, 9 CFR 94.5 (c) (2) states “Garbage on or removed from a means of conveyance is regulated garbage, if, when the garbage is on or removed from the means of conveyance, the means of conveyance has been in any port outside the United States and Canada within the previous 2-year period” (USDA, APHIS 1998). Industry Storage Guidance (FAA) Section 121.577 of the U.S. Federal Aviation Regulations (FAR) prohibits an airline from movement while on the surface, taking off, or landing with any lose items not adequately stowed following FAR Section 121.589 (FAA 1994). These regulations do affect where airlines can store specific items during movements on the ground and throughout critical phases of flight. The FAR may impede recyclable collection if the storage of cans is left unsecured during critical stages of flight. Having these cans in the galley, for example, could affect an evacuation or pose a safety issue during heavy braking upon landing. These storage guidelines sometimes limit the ability of cabin crews to separate and store recyclables. Chapter 33 of the FAA Cabin Safety and Flight Attendant Management, Section 6 Safety Assurance System, addresses additional storage options. It stipulates that if a receptacle in the cabin of the airplane, including the lavatory, is intended for the stowage of carry-on baggage, cargo, or trash; it must meet structural, restraint, and fire containment requirements to ensure flight, ground, and emergency landing load conditions (FAA 2018). U.S. Policy & Regulations U.S. policy and regulations, as noted by the objective of the study, indicate recycling may occur in a controlled environment. Non-U.S. Laws/Practices The goal of non-U.S. laws and practices is to maintain the separation of recyclables from specific food items. There are distinctions and similarities in policies from around the world, which dictate how materials can be handled. These policies are rooted in avoidance of certain foods being comingled with QW, rather than an overarching exclusion of recycling entirely.

6 1.2 Quarantined Waste (QW) and NCRM The term Quarantined Waste is defined as: all waste material derived in whole or in part from fruits, vegetables, meats, or other plant or animal (including poultry) material, and other refuse of any character whatsoever that has been associated with any such material on-board any means of conveyance, and including food scraps, table refuse, galley refuse, food wrappers or packaging materials, and other waste material from stores, food preparation areas, passengers’ or crews’ quarters, dining rooms, or any other areas on means of conveyance. For purposes of this part, garbage also means meals and other food that were available for consumption by passengers and crew on an aircraft but were not consumed (U.S. 2014). For the Primer, regulated garbage will be referred to as QW. In general, QW originates from an area with different policies and regulations from the port in which it is offloaded, disposed of, or handled. With the identification of waste or recyclables as QW, the extraction of recyclables cannot occur due to possible contamination. Items from international in-flight service that are not contaminated and thus, and whose recycling is permitted will be referred to as NCRM. 1.3 History Contamination of IRIFS can arise from certain foods and pests or pathogens from those foods. These potentially invasive species are non-native and may cause environmental harm to plant and animal life, including risk to humans in the receiving country. Often, disruption to native flora and fauna can occur if invasive species are left to spread uncontrollably in a host country. These disruptions could hypothetically cause environmental and economic damage. In the event contamination occurs and requires rectification with high financial or other investments, their reversal may not be feasible. Therefore, protecting national borders against pests and pathogens becomes a necessary goal. However, protecting against biological invasions is difficult because those whose actions result in invasions, (in the case of this report, airlines or their related supply or collection mechanism for example) would seldom bear legal responsibility (Perrings et al. 2005). Quarantine practices can be traced as far back as 1347-1352 during the Black Death plague epidemic, where the plague was spread by sailors, vermin and cargo arriving in Sicily (Mafart and Perret 1998). By the middle of the nineteenth century, scientists and health administrators began to reach consensus around the need for sanitary conditions for diseases such as cholera (Tognotti 2013). Thus, restructuring of international regulations was formed and approved by a number of International Sanitary Conferences (Howard-Jones 1975). The basis of the conferences played a significant role in the formation of the World Health Organization in 1948 (WHO 2018). In the U.S., for more than 100 years, the Department of Agriculture has been developing and enforcing agricultural regulations to prevent harmful insects and microorganisms from entering the country. Currently, the USDA's APHIS heads up this effort. APHIS was established in 1972 (USDA, APHIS 2015). The USDA's first task involved the livestock industry. Bans were placed on U.S. meat exports, affecting the sale of these products in European markets. Therefore, attention was required to be paid to the development of practices for the control of diseases (USDA, APHIS 2012). 1.3.1 Ship Industry Maritime transport played a significant role in the development of current global QW and NCRM protocols. The historical reference of incidences also highlights the link of how policies may have been based on risk mitigation. There also appears to be a historical connection between early ship practices and the policies on which QW handling procedures are based.

7 The International Convention for the Prevention of Pollution from Ships is also a significant influencer of environmental protocols. Established in 1973, and later amended in 1978, it is an international agreement on how ships can minimize pollution both from accidents and routine operations (IMO 2018a). The shipping industry has always played a significant role in the global movement of people and goods. In the late 1960s, however, and with the advent of jet propulsion, air transport soon became the primary choice for many. The International Marine Organization (IMO) is one such group that originally focused on waste at ports. Most of their efforts today, however, are rooted in reducing garbage being discharged at sea (IMO 2018b). 1.3.2 Aviation Industry It was not until the 27th World Health Assembly in 1974 that the then Director-General of the World Health Organization, Dr. Halfdan Mahler professed the need for responsibility for the proper handling of waste from international traffic (WHO 2009). Also, in that year, with air traffic hovering around 420 million passengers (World Bank 2018), and in light of future expected growth, the need was identified to ensure the safety of food, water, and the waste derived from the increased activity of international travel. The outcome of these activities produced the second edition of the Guide to Hygiene and Sanitation in Aviation in 1977 (WHO 2009). Thus, waste disposal practices would have to ensure the protection of public health while not breaching the high standards of hygiene (WHO 2009). Stakeholders in transportation management were identified and recommended to work with health authorities giving guidance on what was to become recommendation WHA27.46 aimed at improving the safety of waste handling practices (WHA 1974). Then, the International Health Regulations (2005) were implemented and became a legally binding agreement for all 192 WHO Member States. These regulations revolved around reducing the spread of disease through international ports. The agreement also provided guidance on ensuring health protection measures would be undertaken in the event of an outbreak. 1.4 Airports and Recycling 1.4.1 NCRM Collection Limited examples were found of airport operators who managed NCRM recovery. These examples include airports in Germany, Japan, and the Netherlands, which all demonstrated some form of separation and collection of NCRM. Conversely, airports in countries such as the U.S., Canada, and Australia mostly incinerated recyclables entirely and, in Australia’s case, even unconsumed aluminum-contained beverage products were destroyed. ACI, a non-profit organization representing the world's airport operators, has consistently cited waste management and recycling programs as the key to being responsible members of an integrated community. ACI has demonstrated support for domestic collection programs, and these local programs ensure recyclables are diverted from landfill. The Eco Airport Toolkit, published by the International Civil Aviation Organization (ICAO), also indicates that successful airport waste management implementation has the potential to positively impact airport authorities, customers, and the surrounding community at large (ICAO 2018). Recycling typically brings with it reduced waste and reduced handling costs as well as increased environmental benefit. In a survey conducted by Keep America Beautiful, the top two reasons why people recycle are to reduce the amount of waste to landfill (51%) and to conserve Earth’s resources (43%). The same study also points to the increasing trend that 68% of millennials prefer to buy consumables from companies that use packaging that can be recycled (Keep America Beautiful 2016). Recycling program adoption has been shown to stem from behaviors rooted in a number of human factors including from the mitigation of guilt to private values and social norms (Viscusi et al. 2011). Increased

8 personal interest in recycling may also be associated with the emotion or reaction to a feeling or obligation to compensate for a person’s perceived causing of environmental damage (Baumeister 1998). In our global review of Airlines, AAFK, it was found that 88% of stakeholders were interested in collaborating to find a more workable solution for the recovery of NCRM. Stakeholders also have the ability, through access to both intellectual capital and resources, to reach these goals given their experience in the management of complex issues. Airline NCRM is essentially the sum of its proactive actions given the procurement, consumption, and collection from their activities. Airport NCRM from its international terminal operations is also typically quarantined as it falls under the same policies regulating IRIFS. This waste includes international passengers' discarded material after deplaning. Thus, recovering international recyclables from airports and in-flight service is potentially a controllable process given that it is contained within a closed and controlled airport setting. Airport buildings have limited space, which is occupied by tenants at a cost, and allocating non-revenue- generating space to waste handling may not be feasible. Managing waste typically functions as an off-site managed process. Similarly, on-site facilities for waste and recycling are rare. One such example, however, is Gatwick Airport (LGW), in the UK, which has demonstrated how the shift to on-site management of materials can work. Future airport developments are now also incorporating the inclusion of on-site source separation of materials. London Heathrow (LHR) is also spearheading advanced recycling programs through the utilization of technologies processing plastics on-site. In the case of LGW, collection and transportation mechanisms generally in place to haul these materials away from airports are avoided due to on-site processing. This airport processes waste into energy and reduces the environmental load associated with the disposal while increasing the sustainability footprint of these airports. In spearheading programs like this, airport operators can affect more control on the variables lost when relegating the management of waste to third parties. Waste reduction can help airport operators increase their revenue generation, and offset operational costs associated with handling when reducing their dependence on waste management companies to process their recyclables off-site. Airport buildings may be spread out across thousands of acres, often serving different needs. Since the movement of nonessential ground vehicles is discouraged, recycling efforts involving increased logistics along with increased truck movements may not be feasible from many of these satellite buildings. These factors, as well as cost, were cited by airports that did not have elevated recycling programs and mentioned challenges such as servicing waste programs for remote buildings due to proximity, traffic constraints, and cost. To ensure efficient waste management, airports typically contract multiple providers to service buildings. Market volatility coupled with reduced commodity prices for recyclables may limit recycling program development. Complex material streams within single-stream collection programs may increase contamination incidences and ultimately increase the cost associated with separating recyclables. Material complexity or conversely, the lack of a homogenized waste stream, limits the extraction of value and may restrict airport participation. To extract greater value from recycling, guidelines for airports include investing in recycling infrastructure to allow for increased participation. Some airports, however, do not yet focus on these initiatives because such initiatives do not currently have high ROIs. To handle NCRM, airports would need to develop a separate collection mechanism to allow for handling and recapture. This added infrastructure would aid their workforce in separating materials. NCRM items intended for single-use do not typically have value and therefore are discarded.

9 Airports NCRM programs are limited as they would need to earmark increased areas for its handling. Airports and their stakeholders have concerns about penalties that come with quarantine violations and therefore avoid handling them. The risk versus reward in this instance often acts as a hindrance to increased NCRM extraction and QW handling. If any recyclables come into contact with quarantined items, they, in effect, become QW and thus, need to be treated as such. In some cases, even if recyclables are only suspected of having been exposed to QW, they need to be treated accordingly. Given their size, airports face challenges in delivering a concerted collection effort of NCRM. According to senior staff at numerous airlines and airports, since international airlines do not budget additional resources for the increased activity to handle NCRM, these materials are often discarded. Given the costs of waste services, airports have found challenges in allocating more resources to these types of added functions. Some airports do take an active role in creating working groups with airlines; other airports have a range of difficulties in espousing a platform to support increased needs for waste and recycling storage. Airports are pursuing sustainability at a feverish pace as both internal and external interest in sustainability programs has increased. Airport and airline executives typically allocate resources to programs demonstrating bottom-line benefits. Airports, like airlines, manage a host of environmental issues outside of recycling. Most are focused on delivering sustainability balance, including wildlife hazards, greenhouse gas management, air quality, de- icing, and noise management, among others. Sustainability issues typically require an operational cost to implement correctly, and unless programs generate revenue or save money, these efforts may likely develop slowly. 1.5 Pest and Pathogens Pathogen Pathway Analysis as defined by the USDA is an evaluation of the entire process from start to finish that examines the risk of adverse effects within a population and models specific combinations of pathogens and products. 1.5.1 ISPM 11 Pest Risk Analyses (PRA) are conducted by APHIS in line with the International Standard for Phytosanitary Measures No. 11 (Secretariat, International Plant Protection Convention 2016) in conjunction with the Food and Agriculture Organization of the United Nations (FAO). 1.5.2 Pathways APHIS has identified QW as a pathway to potentially contain threatening unknown pest and pathogens. ISPM 11 also describes pathways through natural spread, packing material, mail, garbage, and passenger baggage etc. These pathways could deliver pests and could risk native flora and fauna and along with it, economic repercussions to the U.S. economy. 1.5.3 Review Multiple agencies were engaged and consistent evidence was found that policies were based on risk minimization versus specific research. These findings were supported by interviews with governmental bodies. This led to the conclusion that policies were not based on specific case studies. It was also found that policies were focused on reducing or eliminating potential threats of diseases rather than remedies, specific issues, causes and/or effects. Discussions with the Canadian Food Inspection Agency (CFIA) and APHIS also confirmed this conclusion. 1.5.4 Pathway Analysis The USDA APHIS analyzes present, future, and emerging threats to animal health to estimate the likelihood of a damaging event, and to determine potential pathways of introduction and spread. (USDA, APHIS 2018)

10 APHIS uses data to provide epidemiological assessments of issues affecting animal health. These assessments form the basis 1.5.5 PRA Pest Risk Assessments are divided into three broad steps and, as per ISPM 11, they include the following assessments: categorization of the pest; probability of pest introduction and spread; and potential for economic and environmental impacts. The above ensures phytosanitary protocols with regard to pests and pathogens. Invasions by non- indigenous species pose a problem of increasing magnitude and threaten the stability of ecosystems and their economies. Despite the potential enormity of this problem, relatively little is known about the importance of various invasion pathways (Liebhold et al. 2006).