New Environmental Focus for Legislation – Plastics13 February 2017
Regulations around seafood packaging are naturally strict due to the speed of its decomposition. Seafood quickly and easily deteriorates due to factors like contamination, physical damage and badly managed temperature control during the various transport and handling processes spanning the time it is caught to the point of end consumer purchase.
Like many industries, the materials used in all steps of seafood transport and end product packaging revolve around various forms of plastic. Ironically, it is the oceans where our seafood comes from that have the more severe issues with general plastic waste pollution, not to mention vast amounts of discarded aquaculture plastics. The pollution is killing and poisoning enormous amounts of bird and marine life, and in turn, changing the ecology of the oceans.
Australia’s Seafood Packaging Requirements
Seafood packing requirements are strict in substance and application, and understandably so. The Guide to Australian Primary Production and Processing Standard for Seafood provides an excellent guide for Australians as to the packaging requirements of seafood. The rules can be summarised into three main points:
(a) Seafood businesses must only use packaging material that is fit for its intended use.
• For example, frozen seafood may require cartons that are leak-proof and with high stacking strength. Also, if the packaging is important for keeping seafood cool, it must be insulated and/or suitable for use with ice or coolant.
(b) Seafood businesses must only use packaging that is not likely to cause contamination of the seafood.
• Packaging material should be clean and protected from contamination. This includes contamination from chemicals in the packaging itself.
• In relation to the use of plastics specifically, the Australian Standard 2070-1999 Plastics Materials for Food Contact Use is a useful guide which specifies materials and procedures for the production of plastic materials for food contact.
(c) Seafood businesses must take all reasonable measures to ensure seafood does not become contaminated.
• Reasonable measures include:
o Ensuring packaging area and equipment are clean.
o Being aware of, and implementing, any specific conditions of packing particular types of seafood.
o Preventing damage during packing.
As you can see, Australia’s packaging requirements are primarily concerned with the safety of the packaged seafood itself, with little consideration given to the broader effects of the types of materials used on the environment. In turn, environmentally harmful materials such as plastics have become commonplace in Australia’s seafood packaging industry.
Plastic in the seafood packaging process
There is a considerable amount of high and low density plastics in the seafood packaging processes. Some of the plastic products used in the packaging process of seafood, like corrugated polypropylene boxes, are recyclable and fortunately they can be recycled many times over. The term recyclable (able to reuse thus reducing the need for additional raw materials), should however never be confused with biodegradable (decomposed by living organisms resulting in no pollution). Plastic, even the soft plastics, will never naturally decompose on their own. Hence any plastic we have ever used and discarded is likely still in existence in some form, somewhere, whether as large pieces like bags and containers or broken-up pieces.
Recyclable and Non-Recyclable Plastic Packaging
Transport packaging includes hard plastic fish bins made from high density polyethylene which providing returned correctly can be reused many times. This also applies to the insulated bins for bulk transport and the lids for the plastic containers. Once these items are broken, they need to be disposed of correctly and even then, can they be processed into other recycled items.
The list of non-recyclable single-use plastic is longer. Thicker tougher polyethylene plastic bags are required to avoid puncture and leakage during transportation. For increased insulation the packaging process often uses double bags requiring twice the plastic. Add to that, the polyethylene liners helping mitigate leakage and the ice bags and coverings on gel packs to keep seafood cool in land and air transport. The end consumer is also part of the plastic chain given fresh fish in freezer bags and smoked fish in vacuum packed plastic.
The move to ban or limit plastic in seafood packaging
The early 2000’s saw a sustainability project run by Seafood Services Australia and supported by the Australian Government. They worked with an Australian Fish and Seafood Wholesaler and other technology companies to research, develop, trial and evaluate new technologies in seafood packaging. A major focus of the project was targeting replacement of the plastic containers used for road transport of fresh chilled fish.
Prior to the project, it was identified that a number of new, more environmentally friendly packaging products had recently been developed. This was a positive meaning a number of options were available for the road transportation trial.
Expanded Polystyrene (EPS) works well as an insulator however it lacks in strength so despite being 100% recyclable, the frequency of reuse is possibly less than plastic, which may have economic repercussions. EPS recycling is e process is product segregation, collection, reprocessing, export and conversion into other products.
Corrugated fibreboard boxes with additional internal metallic liners or external reflective covers improve the cooling management of the container’s contents, containers made with a combinations of products, for example EPS container with an external fibreboard. Corrugated fibreboard containers can also be dipped in wax to increase container strength as well as improving waterproofing. Foil covers and wrapping for product stored and transported on pallet.
The project assumed EPS would be the logical choice but EPS was still considered environmentally unfriendly as well as expensive to ship when empty. They then built a separate prototype non plastic reusable packing box. To stop the boxes leaking slime onto pallets, a single use bio-degradable liner was successfully developed, enabling the packing boxes to be reused. Also coming from this project was development and use of reusable gel packs replacing ice in the boxes. Overall the trial box met all expectations.
Airlines also accept sustainable materials as options for seafood transportation containers however there are restrictions around the reuse of fibreboard and polystyrene for air transport, as per QANTAS Seafood Air Transport Regulations 2013.
There are many statistics on the millions of tonnes of plastic rubbish entering the world’s oceans annually and many sad pictures of the damage and death to bird and marine life both when they eat it or get caught in it. It has taken a long time but finally the support for and passing of ‘no plastic’ legislation is gaining momentum in various industries and countries. A good example is the banning of single-use plastic shopping bags. The tests have been done for the seafood industry and now the public, business and governments are listening to alternatives.
Known as “The Fish Lawyer” for her specialisation in aquaculture, marine and fisheries law, Katherine Hawes is the principal of Aquarius Lawyers. With over 20 years’ legal and business experience, Katherine’s expertise lies in advising and representing organizations and businesses on issues pertaining to the marine environment. To find out more about Katherine, please see http://www.aquariuslawyers.com.au/