Microbeads - Alliance for the Great Lakes https://greatlakes.org/category/plastic-pollution-great-lakes/microbeads/ Tue, 04 Oct 2022 17:28:06 +0000 en-US hourly 1 https://wordpress.org/?v=6.1.1 https://greatlakes.org/wp-content/uploads/2016/08/cropped-AGL_Logo_Horizontal_FULL_COLOR_RGB_1000px-32x32.png Microbeads - Alliance for the Great Lakes https://greatlakes.org/category/plastic-pollution-great-lakes/microbeads/ 32 32 Tiny Plastic, Huge Victory https://greatlakes.org/2018/06/tiny-plastic-huge-victory/ https://greatlakes.org/2018/06/tiny-plastic-huge-victory/#respond Fri, 29 Jun 2018 17:29:57 +0000 https://greatlakes.org/?p=5872 As of July 1st, the final phase of the nationwide microbead ban will take effect, ending the sale of personal care products containing plastic microbeads by retailers. Microbeads are tiny […]

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As of July 1st, the final phase of the nationwide microbead ban will take effect, ending the sale of personal care products containing plastic microbeads by retailers. Microbeads are tiny plastic particles used as an abrasive in many personal care products, such as facial scrubs, soaps, and shampoos.

Test tubs containing personal care products with plastic microbeads. Photo by Lloyd DeGrane.

When we use products containing microbeads, the tiny plastic pieces don’t dissolve. Instead, they are rinsed down the drain. Because of their small size and buoyancy, microbeads escape treatment by sewage plants and end up in our rivers and lakes.

When research released in 2013 showed the widespread presence of plastic microbeads in the waters of all five Great Lakes, tens of thousands of people around the Great Lakes region spoke out, calling for change. With many readily-available natural alternatives, phasing out the use of plastic microbeads in personal care products was a common sense step.

Researcher analyzes plastic microbeads in personal care products. Photo by Lloyd DeGrane.

The Alliance for the Great Lakes, Illinois Environmental Council, the Shedd Aquarium and other environmental groups teamed up to raise public awareness and promote state legislation to address the issue. In 2014, Illinois was the first state to pass a ban on microbeads. Other states soon followed. And, responding to public pressure, a number of big companies voluntarily phased out the use of plastic microbeads in their products.

In 2015, Congress passed federal legislation to phase out plastic microbeads in personal care products. The national ban on manufacturing these products went into effect on July 1, 2017. And now, the final phase — a national ban on the sale of these products — takes effect July 1, 2018.

Continuing the fight against plastic pollution

The microbead victory is important, and all around good news for the Great Lakes. But it’s just one piece of the plastic pollution puzzle. More than 22 million pounds of plastic enter the Great Lakes every year, and plastic never really goes away. It just breaks down into smaller and smaller pieces known as “microplastics.”

Different types of microplastics, some measuring less than a millimeter. Photo by United States Geological Survey.

Microbeads are one type of microplastic that are deliberately manufactured to be small. Other types of microplastics are fragments or films broken down from larger items.

Researchers have found stunningly high amounts of these tiny plastic pieces in all five Great Lakes, which provide drinking water for 40 million people. They’ve found microscopic pieces of plastic in drinking water, and even beer.

The good news is that we have the power to change the amount of plastic that ends up in the Great Lakes and the waterways that flow into them. As we learned through the microbead campaign and other Great Lakes victories–when we join together, our impact is great!

There are many ways we can continue working together to protect the Great Lakes from taking action to reduce our personal use of plastic, to joining a beach cleanup with Adopt-a-Beach, or pushing for change in our communities.

Act Now for a Plastic-Free Great Lakes

We all have the power to reduce the amount of plastic pollution in the Great Lakes. Add your name to the Plastic-Free Great Lakes Pledge now.

Take the Pledge

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Finishing What You Started: Important victory on plastic microbeads to take effect in 2018 https://greatlakes.org/2018/01/victory-microbeads-2018/ https://greatlakes.org/2018/01/victory-microbeads-2018/#respond Thu, 04 Jan 2018 21:31:08 +0000 https://greatlakes.org/?p=4414 Plastic pollution is ubiquitous in the Great Lakes and the world’s oceans. Tiny plastic particles have been found in everything from drinking water to beer, according to researchers in the […]

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Plastic pollution is ubiquitous in the Great Lakes and the world’s oceans. Tiny plastic particles have been found in everything from drinking water to beer, according to researchers in the U.S. and around the world.

Plastic debris on beach

Adopt-a-Beach volunteers witness the massive volume of plastic pollution first-hand at every cleanup event around the lakes. More than 80% of the litter they pick up each year is made either partially or fully of plastic — from cigarette butts to plastic bottles.

Yet tiny plastic microbeads are one type of plastic pollution that Adopt-a-Beach volunteers are powerless to pick up. Advocates are celebrating a big victory in 2018, with the upcoming implementation of a federal ban on personal care products containing these plastic microbeads.  

Microbead Menace: Tiny Plastic Particles Used in Personal Care Products Threaten the Lakes

Microbeads are tiny plastic particles used as an abrasive in many personal care products, such as facial scrubs, soaps, and shampoos. When we use products containing microbeads, the tiny plastic pieces don’t dissolve. Instead, they are rinsed down the drain. Because of their small size and buoyancy, microbeads escape treatment by sewage plants and end up in our rivers and lakes.

Once in the water, microbeads can absorb toxic chemicals commonly found in the water. And they can be mistaken for food by small fish and wildlife. Studies have shown that fish and wildlife of all sizes consume plastic. The research raises serious concerns about the impacts of microbeads on aquatic life.

You Spoke Out, Manufacturers and Elected Officials Listened

When research released in 2013 showed the widespread presence of plastic microbeads in the waters of all five Great Lakes, tens of thousands of people around the Great Lakes region spoke out, calling for change.

Natural alternatives to plastic microbeads exist, such as ground almonds, oatmeal and pumice. Phasing out the use of these tiny plastic pieces was a common sense step to protect the Great Lakes. Over the following two years, you joined us to call on manufacturers and elected officials to ban plastic microbeads.

Illinois was the first state to take on the issue. The Alliance for the Great Lakes, Illinois Environmental Council, and other environmental groups teamed up to raise public awareness and promote state legislation to address the issue. And, in 2014, the Illinois state legislature passed a bill that phased out the manufacture and sale of personal care products containing plastic microbeads.

Illinois’ action led the way in a national movement, as state after state stepped up on the issue. Throughout the Great Lakes region, similar bans on plastic microbeads were passed in Indiana, Wisconsin, and several counties in New York, and were introduced in the statehouses of Michigan and New York.

Responding to public pressure, companies acted too. Many leading personal care product manufacturers — including Procter & Gamble, Unilever, Colgate-Palmolive, Johnson & Johnson, The Body Shop, and L’Oreal — committed to voluntarily phasing out the use of microbeads in their products.

Ultimately, the U.S. Congress took action by passing federal legislation which was signed into law in December 2015. The law took a phased approach to banning these products, first outlawing the manufacture and then the sale of personal care products containing plastic microbeads. The national ban on manufacturing these products went into effect on July 1, 2017. And now, the final phase — a national ban on the sale of these products — will go into effect on July 1, 2018.

Canada also took notice and adopted a federal ban, ensuring the Great Lakes are fully protected from plastic microbeads. The Canadian ban also goes into effect in 2018, phasing out the manufacture of personal care products with plastic microbeads by January 1, 2018 and the sale by July 1, 2018.

Keeping Up the Momentum In the Fight Against Plastic Pollution

The microbead victory is an important step in addressing plastic pollution, but it’s only one piece of the puzzle. Plastic pollution comes from a wide variety of sources. And unfortunately, it never really goes away. Plastic breaks down into smaller and smaller pieces — into shards, films, and other particles — that are difficult to detect but have a seriously negative collective impact on the Great Lakes.

The good news is that we have the power to change that. We know that when we come together, we can achieve big things.

Adopt-a-Beach volunteers cleaning up a beach in Chicago

Just like we ended the manufacture and sale of microbeads, we can take steps to stop other forms of plastic pollution from entering our Great Lakes. There are lots of ways to have an impact. For example, every year, more than 15,000 Adopt-a-Beach volunteers clean up local beaches. Last year, they removed 18 tons of trash, primarily consisting of plastic. By joining Adopt-a-Beach, you can be part of this 20-ton effort too.

Getting to the Root of the Problem: Pass On Plastic in the New Year

Picking up plastic litter from our beaches stops it from ending up in — and breaking down in — the Great Lakes. But we can do more to stop plastic pollution at its source. Single-use plastic items like plastic bags, water bottles and wrapping are a major culprit. If we don’t use it, it can’t end up in our water. So every time you pass on plastic, you have an impact.
Start the new year off right, and make a personal resolution to reduce your own use of plastic products. Take the Plastic-Free Great Lakes Pledge today.

Help the Great Lakes

Commit to reducing plastic pollution in the Great Lakes. Take the Plastic-Free Great Lakes Pledge today.

Take the Pledge

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Bead-ban campaign brings victory https://greatlakes.org/2016/05/bead-ban-campaign-brings-victory/ https://greatlakes.org/2016/05/bead-ban-campaign-brings-victory/#respond Thu, 26 May 2016 21:47:47 +0000 https://greatlakes.org/?p=721 The tiny plastic microbead — colorful exfoliant in many soaps, toothpastes and facial washes — was no match against our supporters’ fervor to cleanse them from Great Lakes waters. After […]

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The tiny plastic microbead — colorful exfoliant in many soaps, toothpastes and facial washes — was no match against our supporters’ fervor to cleanse them from Great Lakes waters.

After scientists discovered microbeads were evading water treatment and collecting in the waters of the Great Lakes, the Alliance worked to channel public outrage into finding a solution.

Microbeads-test_tubes-Lloyd_DeGrane

Leading a campaign to raise public awareness and promote a legislative fix, the Alliance encouraged many to contact their federal and state lawmakers about banning the beads in favor of readily available, natural abrasives.

The Alliance continued to lead throughout 2015, appearing before a congressional committee in May to support the federal phase out. Molly Flanagan, vice president for policy, testified that plastic comprises more than 75 percent of the trash volunteers with the Adopt-a-Beach™ Program collect from Great Lakes shores. There’s only so much our volunteers can do, she said, adding: “A true solution must focus on the sources of plastic pollution.“

By the end of December, the public — including thousands responding to Alliance action alerts aimed at state legislatures and Congress — scored a major victory: a federal ban on the manufacture and sale of personal-care products containing plastic microbeads.

Scientists worry about the implications for aquatic life and Great Lakes health because once waterborne, microbeads can absorb toxic chemicals and be mistaken for food by fish.

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Alliance statement on signing of Microbead-Free Waters Act of 2015 by President Obama https://greatlakes.org/2015/12/alliance-statement-on-signing-of-microbead-free-waters-act-of-2015-by-president-obama/ https://greatlakes.org/2015/12/alliance-statement-on-signing-of-microbead-free-waters-act-of-2015-by-president-obama/#respond Mon, 28 Dec 2015 21:52:15 +0000 https://greatlakes.org/?p=751 (Chicago, IL) December 28, 2015 – Statement by Molly Flanagan, Alliance for the Great Lakes vice president for policy, on the signing of the Microbead-Free Waters Act of 2015 by […]

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(Chicago, IL) December 28, 2015 – Statement by Molly Flanagan, Alliance for the Great Lakes vice president for policy, on the signing of the Microbead-Free Waters Act of 2015 by President Obama:

“It’s not often that solutions to environmental problems are so straightforward, with clear-cut alternatives so readily available. The Alliance for the Great Lakes applauds President Obama and Congress for recognizing the Microbead-Free Waters Act of 2015 as an easy lift for manufacturers and a clear win for public health, the environment and wildlife.

The quick adoption of this legislation was in response to public demand and mounting regional pressure, with states and local governments taking action across the Great Lakes region. Early leadership by manufacturers who voluntarily pledged to switch from microbeads to natural abrasives helped set the stage for this law. This bipartisan solution will make our Great Lakes and ocean waters cleaner and safer for years to come.”

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Alliance statement on passage of Microbead-Free Waters Act by U.S. Senate https://greatlakes.org/2015/11/alliance-statement-on-passage-of-microbead-free-waters-act-by-u-s-senate/ https://greatlakes.org/2015/11/alliance-statement-on-passage-of-microbead-free-waters-act-by-u-s-senate/#respond Wed, 18 Nov 2015 21:48:18 +0000 https://greatlakes.org/?p=739 (Dec. 18, 2015) – The Alliance for the Great Lakes applauds the U.S. Senate’s vote today to adopt the Microbead-Free Waters Act of 2015 and encourages President Obama to sign […]

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(Dec. 18, 2015) – The Alliance for the Great Lakes applauds the U.S. Senate’s vote today to adopt the Microbead-Free Waters Act of 2015 and encourages President Obama to sign the bill into law when it reaches the White House.

We thank Sens. Kirsten Gillibrand (D-NY), Rob Portman (R-OH), Debbie Stabenow (D-MI) and Mark Kirk (R-OH) for their leadership on this important Great Lakes issue. Today’s vote follows the vote last week in the House where Reps. Fred Upton (R-MI) and Frank Pallone (D-NJ) lead this bipartisan effort.

Plastic pollution is a large and growing problem in the Great Lakes, with plastics comprising more than 80 percent of the litter our Adopt-a-BeachTM volunteers find on Great Lakes shorelines. There’s only so much we can do on land to keep debris and pollution out of the water. Swapping plastic microbeads with natural alternatives in products that range from hand wash to facial wash to toothpaste is a sure route to cleaner, safer water.

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Alliance testimony before Committee on Energy and Commerce Subcommittee on Health: Microbeads in cosmetic products https://greatlakes.org/2015/05/alliance-testimony-before-committee-on-energy-and-commerce-subcommittee-on-health-microbeads-in-cosmetic-products/ https://greatlakes.org/2015/05/alliance-testimony-before-committee-on-energy-and-commerce-subcommittee-on-health-microbeads-in-cosmetic-products/#respond Fri, 01 May 2015 21:16:37 +0000 https://greatlakes.org/?p=673 (May 1, 2015) – Chairman Pitts and Ranking Member Green, thank you for inviting me to appear before this subcommittee to address the threat posed to the Great Lakes by […]

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(May 1, 2015) – Chairman Pitts and Ranking Member Green, thank you for inviting me to appear before this subcommittee to address the threat posed to the Great Lakes by plastic microbeads. My name is Molly Flanagan, and I am the Vice President of Policy for the Alliance for the Great Lakes. For more than 40 years, the Alliance has worked to protect and restore the world’s largest source of surface freshwater with our network of more than 15,000 supporters and volunteers. We are also a member of the governance board of the Healing Our Waters – Great Lakes Coalition, a coalition of more than 120 organizations that share a common goal of restoring our tremendous freshwater asset.

I am here today to support efforts to remove plastic microbeads from consumer products. The Alliance has front line experience with the impacts of debris on our Great Lakes. Over 14,000 of our volunteers are located in the Great Lakes region, working each year to clean up beaches and natural habitats through our Adopt-a-BeachTM program. Further, we have partnered with the National Oceanic and Atmospheric Administration on the creation and implementation of a regional marine debris reduction strategy for the Great Lakes. In 2014 alone, the Alliance for the Great Lakes’ Adopt-a-BeachTM program collected over 50,000 pounds of trash and marine debris from the shores of the lakes. Research from the University of Waterloo and our own estimates based on the data collected by volunteers concludes that over 75% of the items collected are partially or fully comprised of plastic.

There is only so much we can do on the land to eliminate debris and pollution. A true solution to the plastic pollution problem must focus on the sources of plastic pollution. Recent research has shown that microplastics, including plastic microbeads, from personal care and cosmetic products, are present in high concentrations in the Great Lakes. You have the opportunity to stop this needless source of pollution by passing a federal ban on use of plastic microbeads.

Microplastics in the Great Lakes

Microplastics are plastic pieces smaller than 5 millimeters that are either intentionally manufactured to be small or a result of the fragmentation of larger plastic productsi. Their presence is well documented in the world’s oceans, but recent research on the Great Lakes shows concentrations that rival or surpass those found in the marine environment. In 2012, Dr. Sherri Mason of the State University of New York at Fredonia and Marcus Eriksen of the 5 Gyres Institute found microplastic fragments numbering more than 460,000 per square kilometer in Lake Erieii and in 2013, as many as 1.1 million per square kilometer in Lake Ontario.iii In a separate study, researchers on the St. Lawrence River found high levels of microplastics present in sediment samples from the bottom of the St. Lawrence River, indicating that these tiny pieces of plastic move through the entire Great Lakes system and the entire water column.iv

Further analysis concluded that fifty-eight percent of all microplastics smaller than 1 mm collected in the Great Lakes were spherical.v These items were manufacturedvi for cosmetic and personal care products that use microbeads as abrasive or aesthetic additives. These products can contain up to 350,000 plastic microbeads per package.

The threat of plastic microbeads

Too small to be easily spotted and removed, plastic microbeads smaller than 5 mm in size do not appear to clutter beaches and foul shorelines as plastic bottles, cigarette butts or derelict fishing gear do, but they pose a pernicious problem. Plastic microbeads are composed of polypropylene (PP), polyethylene (PE), polyethylene terephthalate (PET), nylon or Poly(methyl) methacrylate (PMMA). These forms of plastic attract and accumulate hydrophobic toxic chemicals, such polychlorinated biphenyls (PCBs), DDT, and polycyclic aromatic hydrocarbons (PAHs), which are unfortunately present in bodies of waters, including the Great Lakes. Plastic microbeads can be perceived as food and ingested by wildlife. An on-going study of fish within the Great Lakes has shown plastic contamination within all 25 species analyzed to-date. Not only does plastic ingested by wildlife directly impact nutritional intake by replacing food sources, it can also leach toxins accumulated on the plastic from the environment.viii

The extremely small size of plastic microbeads allows them to easily wash down drains, through sewer systems, and directly into waterways. A study by the New York State Office of the Attorney General released in April 2015 detected microbeads in the effluent samples of 74% of the wastewater treatment plants participating in the study.ix At a time of limited funding for wastewater treatment plants and other water infrastructure, the potential cost and time necessary to upgrade wastewater treatment plants with yet-to-be-developed technologies that could filter these plastic microbeads far outweighs the cost of preventing their introduction in the system by banning their use in cosmetic and personal care products.

The Great Lakes Cannot Absorb More Damage

Continuing to allow plastic microbeads to enter the Great Lakes when a solution is at hand runs counter to current protection efforts. Adding new sources of stress to the lakes undermines the $1.9 billion in federal investments made to restore them over the last five years through the bipartisan Great Lakes Restoration Initiative. Congressional action and regional collaboration have helped a healthier Great Lakes support recreational fisheries for perch, black bass, walleye, lake trout, salmon, pike, steelhead, and others for millions of anglers that spent an estimated $1.2 billion during Great Lakes fishing trips and $1.3 billion on equipment for activities related to Great Lakes fishing.x When you combine these direct expenditures with the more than 58,000 jobs they create, with salaries totaling $2.1 billion, it adds up to a total impact of slightly more than $7 billion in the entire U.S. economy.xi The health of the Great Lakes is not immune to threats, new and old, including invasive species like Asian carp, harmful algal blooms caused by excessive nutrient runoff from farms and cities and habitat destruction. Needlessly sending billions of plastic microbeads into waters we are spending so much time, energy, and money restoring is simply irresponsible – we do not need to add a new threat to the Great Lakes.

Alternatives Are Available – We Can Solve This Problem

Plastic microbeads were patented in the early 1970s, but were not regularly used commercially until the 1990s. Today microbeads are found in over 100 products including facial wash, body wash, toothpaste and some over the counter drugs.xii Prior to the use of plastic microbeads, many cosmetic and personal care products used abrasive beads derived from materials such as ground almonds, ground walnuts, cocoa beans, oatmeal and sea salt. These products exist in the same market as products that contain plastic microbeads at a similar price point and do not result in plastic particles polluting the Great Lakes.

A number of large companies in the cosmetic and personal care industry have voluntarily pledged to remove plastic microbeads from their products. We applaud these efforts as examples of good corporate stewardship. We also note that these voluntary efforts have a variety of timelines for phase out, may not have a timeline at all, and do not consistently indicate what the company will use to replace microbeads. For example, the concept of marine biodegradable plastic microbeads sounds encouraging at first take. Unfortunately, the only existing standard for marine biodegradability never applied to freshwater and has since been withdrawn for additional review since April 2014. There are no national or international standards for the biodegradability of plastics in ambient water environments. The industry’s first job as good stewards of the Great Lakes must be to demonstrate that alternatives to plastic microbeads can truly and completely biodegrade, or mineralize, in the naturally occurring conditions of the Great Lakes and other water bodies. This should occur rapidly without creating harmful byproducts. Until peer-reviewed scientific research or testing by the American Society for Testing and Materials can provide standards for the biodegradability of plastics that confirm real biodegradability in Great Lakes water conditions, biodegradable plastics should not be exempt from a ban.

Recommendations

We are encouraged that several states, including Illinois, New Jersey, and Maine, have banned plastic microbeads in cosmetic and personal care products. Other states, including Indiana, Wisconsin, Michigan, New York and others, are currently working on bans. The Alliance believes that the right federal regulatory approach can solve this problem. To completely protect the Great Lakes and other water bodies in the United States from plastic microbeads, we urge Congress to pass a federal ban on all forms of plastic microbeads in cosmetic and personal care products that:

  1. Charges the Food and Drug Administration (FDA) with clearly defining plastic microbeads based on current scientific research and standards testing by authorities such as the American Society for Testing and Materials;
  2. If terms such as “synthetic” and “biodegradable” are used in statute and regulation with regard to microbeads, these terms should also be clearly defined by FDA to ensure that substances such as bioplastics are not excluded from biodegradability requirements, and that biodegradability occurs to mineralization in freshwater and marine environments;
  3. Sets a realistic and achievable timeline to phase out cosmetic and personal care products that contain plastic microbeads, beginning one year from the passage of this legislation; and
  4. Ensures that any products marketed and labeled as biodegradable meet Federal Trade Commission standards as articulated in FTC “Green Guides” for environmental marketing claims.

Conclusion

You have a great opportunity before you. We know that an unnecessary ingredient in some cosmetic and personal care products – plastic microbeads – is entering our waterways every day. We have a private sector that understands that the public demands products that do not pollute the Great Lakes and has the tools and knowledge in hand to replace plastic microbeads in products and avoid undermining our work to protect and restore the lakes.

The Alliance for the Great Lakes and our supporters urge the United States Congress to pass a ban on the manufacture and sale of cosmetic and personal care products that contain all forms of plastic microbeads. The Alliance thanks Congressmen Upton and Pallone for introducing this legislation and considering our comments. Representative Pitts and Ranking Member Green, thank you for holding this hearing. I look forward to assisting on any actions this subcommittee can take to support this effort.

References

i Arthur, C., J. Baker and H. Bamford (Eds). (2009). Proceedings of the International Research Workshop on the Occurrence, Effects and Fate of Microplastic Marine Debris. Sept 9-11, 2008. NOAA Technical Memorandum NOS- OR&R-3.

ii M Erikson et al. “Microplastic pollution in the surface waters of the Laurentian Great Lakes.” Marine Pollution Bulletin 77.1-2 (2013): 177-182. Available at: http://www.sciencedirect.com/science/article/pii/S0025326X13006097.

iii Casler, Andrew. “Water contamination brings A.G. microbead ban proposal.” The Ithaca Journal, Feb 19, 2015. Available at http://www.ithacajournal.com/story/news/local/2015/02/19/state-ag-proposes-microbead- ban/23674637/

iv Castañeda, R.A., Avlijas, S., Simard, M.A., and Ricciardi, A. (2014) “Microplastic pollution in St. Lawrence River Sediments,” Canadian Journal of Fisheries and Aquatic Sciences, 71(12): 1767-1771.

v Office of NYS AG Eric Schneiderman. “Unseen Threat: How Microbeads Threaten New York Waters, Wildlife, Health, and Environment.” (2014) Available at http://ag.ny.gov/pdfs/Microbeads_Report_5_14_14.pdf

vi Ibid.

vii 5 Gyres Institute. “Microplastics in consumer products and in the marine environment” Position Paper, 2013. Available at http://5gyres.org/media/5_Gyres_Position_Paper_on_Microplastics.pdf

5 Gyres Institute. “Microplastics in consumer products and in the marine environment” Position Paper, 2013. Available at http://5gyres.org/media/5_Gyres_Position_Paper_on_Microplastics.pdf

viii The National Oceanic and Atmospheric Association. (2011). What We Know About: Plastic Marine Debris. The National Oceanic and Atmospheric Association: Author. Retrieved from http://marinedebris.noaa.gov/sites/default/fles/Gen_Plastichi_9-20-11_1.pdf

ix Office of NYS AG Eric Schneiderman.” Discharging Microbeads to Our Waters:
An Examination of Wastewater Treatment Plants in New York” (2015) Available at http://www.ag.ny.gov/pdfs/2015_Microbeads_Report_FINAL.pdf
x Southwick Associates, Sportfishing in America: An Economic Engine and Conservation Powerhouse, American Sportfishing Association, Multistate Conservation Grant Program, 2007. Hereinafter cited as “Southwick Associates 2007.”

xi Congressional Research Serice “Asian Carp and the Great Lakes Region”. Available at https://www.fas.org/sgp/crs/misc/R41082.pdf

xii Office of NYS AG Eric Schneiderman. “Unseen Threat: How Microbeads Threaten New York Waters, Wildlife, Health, and Environment.” (2014) Available at http://ag.ny.gov/pdfs/Microbeads_Report_5_14_14.pdf

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