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The National Aquaculture Association (NAA) and California Aquaculture Association (CAA) have jointly commented on a draft Statewide Microplastic Strategy proposed by the California Ocean Protection Council in response to state legislation.

The Associations commented in support of the effort by of the California legislature, municipalities and agencies to develop a cohesive ocean and coastal natural and human ecosystem oriented microplastics strategy.

They suggested the risk assessment methodology described by the Council organized Science Advisory Team be implemented to complete an assessment for each plastic compound, product, pathway and use to inform effective actions. The draft appears to be predicated on an assumption of hazard to trigger actions that will occur new regulatory costs and inhibit the use of plastic. This hazard-based approach appears to ignore: 1) the ubiquitous presence of biotic and abiotic particles (e.g., silt, plant fibers, animal fragments) present in the marine environment over the millennia and 2) the capability of marine animals and plants to process natural and anthropogenic particulates.

The Associations recommended research priorities to include:

• Standardize micro- and nano-plastic sampling, analysis, and reporting.
• Conduct comparable environmental and human risk analyses.
• Develop biodegradable plastics that avoid environmental and human health risks.
• Characterize degradation characteristics of the various plastics and ropes used by the marine recreational, commercial and farming communities to ensure the use of the most durable materials possible and their responsible disposal before they start to breakdown.
• Describe new plastic recycling technologies to recover, reuse and remanufacture.
• Encourage micro- and nano-particle research for anthropogenic and naturogenic sourced materials to develop a complete understanding of environmental and human health risk.

They also suggested adding a new statewide strategy of creating recycling capabilities that would redirect exported and landfilled plastic waste to California-based facilities for sorting, processing and remanufacturing under the regulatory oversight of federal, state and local entities.

The Council is accepting public comment submitted to OPCmicroplastics@resources.ca.gov until 5:00 pm Pacific Time, January 21, 2002.

For a copy of the NAA and CAA comment letter, please contact CAA Executive Director, Michael Lee at info@caaquaculture.org. The letter was informed by the NAA’s Plastics Policy which can be accessed here.