By: Cynthia Palmer, Senior Petrochemicals Analyst
Date: April 6, 2026
About: Docket #EPA-HQ-OAR-2025-0068-0001
To: Environmental Protection Agency
I’m Cynthia Palmer, Senior Analyst for Petrochemicals at Moms Clean Air Force. I oppose EPA’s proposal to remove pyrolysis from the OSWI rules.
Burning plastic in pyrolysis combustors releases dioxins, PFAS, formaldehyde, particulate matter, heavy metals, and other toxic chemicals.
Exposure to this pollution increases the risk of cancers, birth defects, Alzheimer’s, respiratory ailments, and other harms.
Due to the potent carcinogens released by burning plastic and other trash, Congress included the solid waste combustor rules, section 129, in the 1990 Clean Air Act amendments. The Act defines “solid waste incineration unit” to encompass “any facility which combusts any solid waste material…” In its very first standards implementing section 129, in 1995, EPA went out of its way to specify that pyrolysis is a form of solid waste combustion and is covered by the Act.
The Clean Air Act includes no other way to regulate pyrolysis incinerators.
By illegally removing pyrolysis from the OSWI rules, the EPA would allow these incinerators to burn plastic trash without any pollution controls, monitoring, or reporting requirements.
Plastic waste is solid waste, despite the plastics industry’s Orwellian claim that it is not. And as Congress understood, pyrolysis units are incinerators -- they combust the plastic waste in the first chamber – where there is oxygen from external sources and from the plastic itself – and in the second chamber, where gases from the first chamber are burned.
The emissions are exceedingly dangerous: the relatively low temperatures at which these incinerators operate – well below 1000 degrees Celsius -- combined with the reduced level of oxygen, and with the chlorine in PVC plastic, can promote the generation of incomplete combustion products such as dioxins, furans, PAHs, PCBs, and formaldehyde.
EPA’s proposal is a giant gift to the plastics industry.
- It would incentivize incineration on-the-cheap without pollution controls at a time when the plastics industry is eyeing the possibility of building dozens or even hundreds of these plastic incinerators in towns across America.
- It would play into the industry’s pursuit of national mandates for “recycled plastic,” giving credits for plastic burning based on a deceptive accounting scheme known as mass balance.
- And it would enable these incinerators to bypass local zoning laws that forbid the siting of incinerators next to schools, daycares, and playgrounds.
The plastics industry wants to use this decades-old incineration technology to make plastic trash vanish from sight -- by burning it -- turning plastic into air pollution, heavily contaminated fuels, and hazardous wastes. Rebranding plastics incineration as “recycling” and “manufacturing” helps to justify their plans to triple plastics production.
We oppose the removal of pyrolysis incinerators from the OSWI rules and we urge EPA to put children’s health above plastics industry profits.
Thank you.