OFR Comment Letter for the General Services Administration (GSA) to reduce single-use plastic and packaging
Background: In July 2022, the General Services Administration (GSA), the largest purchaser of goods and services in the United States, sought public feedback on their plan to reduce single-use plastic. Surfrider Foundation submitted comments with other NGOs asking for a swift and strong plan to eliminate the purchase of single-use plastic and focus on reuse in government agencies.

On December 26, 2023 GSA released the next step, a proposed rule, however, this rule does not lead to any actual plastic reduction. It only focuses on voluntary purchasing of sustainable plastic packaging only and does not focus on plastic products at all. Additionally, it lacks clear progress metrics and implementation plans. In this comment, we urge GSA to strengthen this rule.

The deadline to sign on to this comment is COB 02/25/2024. To sign this letter, please fill out the Google form below. This letter is only for Ocean Friendly Restaurants, not for individual signers. We will list the restaurants represented as part of the letter.

Language below:

We, the undersigned Surfrider Foundation Ocean Friendly Restaurants (OFR), submit the following comments regarding the General Services Administration (GSA)’s proposed rulemaking to reduce single-use plastic packaging.

While the proposed rule is a step in addressing plastic pollution, we believe GSA, the largest purchaser of goods and services in the United States, can do more to reduce single-use plastic at the source. We request that the GSA include reduction of all single-use plastic products, not just packaging, in the final rulemaking, as these are items commonly found polluting our beloved beaches and waterways.

Most importantly, we recommend that GSA includes metrics for determining plastic reduction as well as mandates for switching to plastic-free products. Each restaurant represented here is required to follow a set of criteria to be a part of the Ocean Friendly Restaurants Program. The criteria focuses on shifting away from single-use plastic, especially items such as bags, bottles, straws, utensils, and expanded polystyrene foam. Currently, 550 restaurants participate in the program spanning 28 states and Puerto Rico. We estimate that, collectively, OFRs serve over 101,000 single-use plastic free meals a day. We believe all government agencies should be required to reduce certain single-use plastic products and packaging. If small restaurants like us can do it, then the General Services Administration can, too.

With GSA’s purchasing power, there is an opportunity to not only reduce demand for single-use plastics, but to also drive the markets toward reusable and other plastic-free materials. It’s no secret that plastic-free products are more expensive than single-use plastic products. Despite this, many of our OFRs have seen cost savings by making the switch to plastic-free options. One OFR in Florida saves over $3,000 a year by only offering paper straws upon request. Another OFR in California saves $900-2,000 a year by running a glass bottle return system after reaching their break-even point. This shows that single-use plastic reduction can be good for business, but the initial purchase of plastic-free products is still a hurdle for most restaurants. With GSA’s help, plastic-free products will become more readily available and thereafter more affordable for small businesses.

The General Services Administration has the opportunity and responsibility to turn the tide on plastic pollution. Please take our comments into consideration when finalizing the proposed rulemaking. Visit surfrider.org/ofr to learn more about the Surfrider Foundation’s Ocean Friendly Restaurants Program.

Sincerely,
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