The case for banning or regulating the use of Styrofoam on the ocean

Submission to the CleanBC – Plastics Action Plan Consultation

The case for banning or regulating the use of Styrofoam on the ocean
Peter Dietsch, professor of economic ethics, Université de Montréal, QC, and part-time resident
of Lasqueti Island, BC
Donald Gordon, Lasqueti Island and Vancouver
September 2019

Executive summary:
On-the-ground community efforts to clean marine debris from beaches in the Salish Sea and
elsewhere on the BC coast have revealed an overwhelming and increasing problem with blocks
of Expanded Polystyrene, also known as EPS or Styrofoam. These large, loose blocks, likely from
dock flotation, quickly disintegrate into millions of microplastic EPS beads when subjected to
wave-driven abrasion against rocks, beaches, and logs. Clean-up of the resulting toxic beads is
extremely difficult, and it has been shown that the beads are often consumed by marine
organisms. Due to the lack of regulation, both the environmental degradation and the cost of
clean-up efforts represent an externality borne neither by the producer of the product nor by the
buyer. The banning or strict regulation of marine use of EPS is long overdue.

1 Identifying the problem
1.1 The motivation to focus on marine Styrofoam use
For the fourth summer running, residents of the gulf island of Lasqueti organized in July 2019
their annual beach clean-up.1 The depressing results: 70 volunteers collected a record two tons
of garbage in half a day. In terms of volume, we filled a 50-foot semi-trailer. Several beaches that
had already been cleaned in the last three years needed to be cleaned again and other beaches
not yet cleaned contributed to mountains of debris.
As is the case with many BC beach clean-ups, unencapsulated expanded polystyrene (EPS), also
known as Styrofoam, represents by far the greatest volume of marine plastic debris collected.
The washed-up blocks of Styrofoam get broken down between logs and rocks, leaving behind a
sea of white polystyrene beads 2 to 4 mm in diameter as well as microplastic particles invisible to
the naked eye. The vast scale and tiny individual size of these beads make them virtually
impossible to clean up. The Lasqueti clean-ups have so far been limited to larger items, aiming to
remove the Styrofoam before it breaks down. The concentration of debris is highest on beaches
exposed to south-easterly winds.
While the public discussion of the use of plastics is headlined by consumer items such as plastic
straws or cups, Styrofoam used for flotation is arguably one of the most pressing environmental
issues for the beach ecosystems of the BC coast today (see also point 1.3).2

1.2 The scale and source of the problem
NGOs such as Ocean Legacy, with whom the Lasqueti clean-up cooperates to dispose of the debris
responsibly, and the Great Canadian Shoreline Initiative, organize beach clean-ups all over the BC
coast. A 2018 UBC study documents the scale of marine pollution in the province and confirms
that “[o]cean sourced debris, was dominated by styrofoam, potentially from docks, boats,
aquaculture and dumping.”3
More anecdotal evidence, still to be corroborated, indicates that the share of Styrofoam is
particularly high in the Salish Sea. Combined with the size and shapes of Styrofoam pieces found
on Lasqueti, this suggests that docks and other installations that can be washed away by storms
do indeed represent one important source of the problem.4 If the debris on BC beaches originated
from further afield – for instance from developing countries in Asia – it would be hard to explain
the high concentration of Styrofoam on Salish Sea beaches, and a lower concentration on the
west coast of Vancouver Island.
Using Styrofoam for flotation is common practice today. The Port of Metro Vancouver, marinas,
BC Ferries, and private docks commonly use large Styrofoam blocks in their floating
infrastructure. Sometimes these blocks are encased in concrete but with the Styrofoam exposed
below. In other applications, the Styrofoam blocks are simply held together by wooden cribbing
to create a floating dock, with the Styrofoam exposed to the elements.

1.3 Environmental impact
The disastrous impact of Styrofoam on both marine life and on humans takes different forms.
Fish, including salmon on the BC Coast, mistake Styrofoam pellets for food and eat it. Even when
docks are not washed away, they are open from underneath, and various animals who burrow
into the foam accelerate the break-down of Styrofoam flotation blocks and the release of EPS
beads into the marine environment. Styrofoam turned into microplastic is ingested by both filter
feeders and fish. Since toxins bind easily with the molecular structure of Styrofoam, Styrofoam
pollution also exposes marine organisms to higher levels of toxicity. Ultimately, when humans eat
fish and seafood, we are equally exposed to microplastics and the attached toxins. The research
on all of these issues is growing at a fast pace.5 What is already clear is that Styrofoam pollution
raises several red flags.
For marine life, the Styrofoam pollution on the BC coast is akin to a slow-motion oil spill. From
a regulatory perspective, it is more insidious, since it obviously does not solicit the same reaction
as an oil spill. It is time that Styrofoam pollution receive adequate attention.
Submission to the CleanBC – Plastics Action Plan Consultation page 3

2 The social cost of marine Styrofoam pollution
Sceptics will object that replacing Styrofoam with other floatation materials will be costly. This
is a dangerous misperception. Here is why.
The private cost of producing Styrofoam and using it for flotation for marine infrastructure or
aquaculture is indeed relatively low compared to other materials (such as air-filled steel or plastic
containers). However, this private cost has to be distinguished from the social cost of marine
Styrofoam use, that is, the environmental and social costs not included in the price of production
and installation: for example, the cost to marine life -- if we can even put a price-tag on this, which
is questionable; the cost to fisheries; the health costs to humans; and the clean-up costs on the
beaches.
Economists call the difference between private and social costs an externality.6 When market
transactions generate negative externalities, leaving the market to its own devices will lead to an
inefficiently high production and consumption of the good in question. It is easy to see why.
People can consume the good without paying the actual cost of using it.
The use of Styrofoam on the ocean is a prime example of a good riddled with externalities: not
only does it represent an environmental disaster, but it is also an inefficient use of society’s
resources in the sense that it would be cheaper collectively to use other materials. Even though
alternative flotation devices such as steel or plastic tanks might be more expensive compared to
Styrofoam for individuals, they are actually cheaper from the perspective of society as a whole.
When vested interests object to a ban or a regulatory framework for using Styrofoam on the
ocean, as they no doubt will, it is essential to keep this in mind.
In addition to the externalities that affect us all, there is also a direct financial impact on certain
key industries in British Columbia. The fishing industry in BC is worth over $1 billion and our
reputation of having clean wild fish is threatened if our waters are polluted. Similarly, the tourism
industry in BC is worth $9 billion and would suffer as well if our beaches are covered in plastic.

3 Policy options
Our evidence and experience make it clear that British Columbia should be banning or regulating
the marine use of Styrofoam, as is being done in other jurisdictions. Three different approaches
are available:
1) It is clear that the social costs of using Styrofoam are higher compared to available
alternative technologies and that, therefore, the case for an outright ban is strong.
2) A more moderate regulatory approach would be to follow Washington State in the United
States in requiring that Styrofoam be encapsulated when used on the ocean.7 However,
given that even encapsulated Styrofoam eventually gets broken up by the elements, this
approach risks being ineffective.
3) A final option is to attempt to internalize the externality by making the polluter pay the
social costs. How could this be done? In theory, two elements would be needed here. The
first is some kind of fingerprinting of Styrofoam used on the ocean (for instance by
embedding a color code into foam blocks). The second is a schedule of the social costs
that either Styrofoam producers or equipment owners or both would have to pay when
some of their foam is found washed up on a beach. In practice, such a system is
unworkable. However, it could be approximated by imposed a 100% surcharge on all
marine use of Styrofoam use, the proceeds of which would then be used for containment
and clean-ups. Such a surcharge would have a strong deterrent effect and favor the use
of alternative flotation materials.
In light of the urgency of the situation, and given that alternative technologies are available,
this submission clearly sees an outright ban of marine use of Styrofoam as the first choice.
 

4 Conclusion
In public policy, it is rare to encounter serious problems to which a relatively straightforward
solution is available. The environmental and social costs of using Styrofoam on the ocean are one
of these rare cases.
The Canadian federal government has rightly made its Oceans Strategy a priority. The BC
government is also rightly focused on revising the province’s policies on the use of plastics
generally. For both levels of government, addressing the Styrofoam pollution of our coasts
through effective regulation should be high on the agenda.

5 Supporters of this call for banning the use of Styrofoam on the Ocean
(in alphabetical order)
- Andrew Fall, Regional Director, Electoral Area 'E' (Lasqueti Island), qathet Regional
District
- Lasqueti Island Local Trust Committee
- Lasqueti Island Nature Conservancy (LINC)
- White Rock and Surrey Naturalists
- Sean Wood, Green Party Candidate for Courtenay-Alberni

footnotes

1 See e.g. https://www.cbc.ca/news/canada/british-columbia/lasqueti-islanders-colle....

2 Abandoned, lost or otherwise discarded fishing gear (ALDFG) is another important issue.

3 Cassandra Konecny, Vanessa Fladmark and Santiago De la Puente, “Towards cleaner shores: Assessing the Great Canadian Shoreline Cleanup’s most recent data on volunteer engagement and litter removal along the coast of British Columbia, Canada”, Marine Pollution Bulletin 135 (2018), 411-17.

4 On beaches close to Aquaculture installations, such as for instance on Denman Island, debris from their
operations is often the single most common item.

5 For one representative study, see for instance Boris Worm, Heike K. Lotze, Isabelle Jubinville, Chris Wilcox, and Jenna Jambeck, “Plastic as a Persistent Marine Pollutant”, Annual Review of Environment and Resources 42 (2017): 1-26.

6 The concept of externality has been fundamental to economics since the 1960s. The 2018 Nobel Prize in economics for William Nordhaus and Paul Roemer was in part awarded for their work on externalities.

7 See the Washington Administrative Code WAC 220-660-380(5)(h): “Flotation for the structure must be fully  q enclosed and contained in a shell (tub). The shell or wrap must prevent breakup or loss of the flotation material into the water. The shell or wrap must not be readily subject to damage by ultraviolet radiation and abrasion.” (https://apps.leg.wa.gov/wac/default.aspx?cite=220-660-380). See also the voluntary environmental stewardship policy of Sewell’s Marina in Vancouver at https://www.sewellsmarina.com/about/environmental-stewardship/.