Plastic pollution is no longer just an ocean issue—it’s an operational one. Every resin pellet, flake, or powder lost during plastic manufacturing, transport or handling has the potential to escape into waterways. Recognising this, Operation Clean Sweep (OCS) has emerged as a globally adopted, locally critical initiative in Australia—backed by Expanded Polystyrene Australia (EPSA) and many of its members.
But while the industry’s commitment is growing, government responses vary significantly across states. Victoria and New South Wales are taking markedly different approaches to regulating plastic feedstock loss, setting two distinct paths for managing environmental risk and aligning with circular economy objectives.
What Is Operation Clean Sweep?
Operation Clean Sweep is an international initiative originally developed in 1992 by the U.S. plastics industry. Its mission is simple yet powerful:
To help plastics handlers of all kinds—manufacturers, recyclers, logistics operators—achieve zero plastic resin pellet, flake, and powder loss.
In Australia, OCS was introduced in 2015 and has since expanded to over 135 business sites. Industry associations including EPSA, the Vinyl Council, Chemistry Australia, and the Australian Packaging Covenant Organisation (APCO) have taken the pledge. EPSA in particular has championed the program across the expanded polystyrene (EPS) industry, reinforcing that spills aren’t just accidental—they’re preventable with the right systems in place.
Image Credit: Operation Clean Sweep
The Scope of Feedstock Loss
Plastic feedstock includes the raw materials—resin pellets, recycled chips, powder, flakes, and swarf—used in everything from food containers to medical devices. Spills or mismanagement of these materials during manufacturing, packaging, transport or installation can result in microplastics entering stormwater systems, soil, and aquatic ecosystems.
While it is commonly stated that microplastics do not degrade, this view has been challenged by leading polymer scientists. Professor Chris DeArmitt, in Shattering the Plastics Illusion, presents extensive scientific evidence showing that plastics do degrade—though slowly—through natural processes including UV radiation (photodegradation), oxidation, thermal exposure, mechanical stress, and microbial action. These mechanisms gradually break down plastics into smaller molecules, eventually converting them into carbon dioxide, methane, and biomass.
Source: Shattering the Plastics Illusion p69
However, the core issue is not whether plastics degrade eventually, but whether they escape controlled environments in the first place. Feedstock loss—no matter the material’s degradation timeline—represents unnecessary waste, reputational risk, and preventable environmental impact.
That’s why Operation Clean Sweep is critical. It addresses the root cause: loss prevention. By containing feedstock at the source, businesses can avoid the downstream risks of litter, uphold regulatory compliance, and preserve the integrity of Australia’s recycling systems.
Victoria’s Regulatory Crackdown: A Legal Duty to Act
Victoria leads the nation with one of the most robust stances on plastic feedstock loss. Under the Environment Protection Act 2017, businesses that handle plastic feedstock are legally obligated to prevent spills as part of their “general environmental duty” (GED).
As outlined in EPA Victoria’s Managing Plastic Feedstock guide (Publication 1701.1), any uncontrolled release of feedstock is considered industrial waste and must be managed appropriately. Failure to do so is not merely bad practice—it may constitute a breach of the law and can attract enforcement action.
Victorian authorities now explicitly recommend Operation Clean Sweep as a best-practice framework. Businesses are expected to follow a structured risk management process that includes:
- Identifying risks of feedstock loss at every operational stage (production, transport, installation, etc.)
- Implementing physical controls such as bunding, mesh guards, and spill trays
- Regular inspections and audits
- Incorporating feedstock handling into environmental and safety management plans
- Providing training and inductions to staff and contractors
Importantly, these guidelines don’t just apply to manufacturers. Any entity in the supply chain—from transporters to recyclers—must manage the risk of feedstock loss or risk non-compliance with the GED.
Why Victoria’s Approach Matters
By embedding OCS principles into formal regulatory frameworks, Victoria is elevating plastic feedstock management from a voluntary initiative to a core compliance obligation. This aligns with its broader commitment to circular economy principles and helps ensure that recyclable materials like EPS do not become pollution risks.
Image Credit: Operation Clean Sweep
NSW’s Voluntary Approach: Encouragement Over Enforcement
New South Wales, while supportive of OCS, has taken a different tack. Under the NSW Plastics Action Plan, Operation Clean Sweep is acknowledged as a valuable industry initiative—but participation remains voluntary.
The NSW EPA has issued guidance encouraging manufacturers and transporters to prevent feedstock loss. However, there is no direct legislative requirement akin to Victoria’s GED. While this allows flexibility and gradual adoption, it risks leaving compliance gaps in critical sectors like logistics and packaging, where spills often occur in loading bays, gutters, and stormwater drains.
In practice, this means the effectiveness of feedstock loss prevention in NSW often depends on individual businesses taking initiative. While many EPSA members across NSW have voluntarily implemented OCS protocols—such as improved packaging, spill containment, and staff accountability—others may lag without regulatory pressure.
The Risk of a Two-Speed System
The contrast between Victoria and NSW highlights a national inconsistency that could undermine Australia’s broader plastics circularity goals. With the UN Treaty on Plastic Pollution on the horizon, Australia needs a unified position on how it tackles preventable sources of microplastic contamination—especially in critical materials like EPS, which is 100% recyclable when managed properly.
Industry groups like EPSA are calling for harmonised recognition of Operation Clean Sweep across all states and territories, ensuring that environmental protections do not stop at state borders.
EPSA’s Role: Stewardship in Action
As a signatory to Operation Clean Sweep, EPSA actively promotes best practice across the polystyrene industry. Its members include manufacturers, distributors, and recyclers who are committed to:
- Preventing spills at source
- Training staff on responsible material handling
- Reporting incidents and rectifying weaknesses
- Auditing facility risks and investing in site improvements
EPSA also supports infrastructure and innovation that transforms clean EPS offcuts and packaging into recycled building materials—strengthening the link between pollution prevention and product circularity.
In practical terms, this means that clean EPS offcuts from construction or packaging waste collected via initiatives like StyroCycle can be repurposed into sustainable building products. When OCS protocols are followed, this closed-loop system becomes economically viable and environmentally essential.
Image Credit: Operation Clean Sweep
What Businesses Can Do Today…
Whether you’re in Victoria, NSW or beyond, adopting Operation Clean Sweep is a strategic move. EPSA encourages all stakeholders in the plastic supply chain to:
- Sign the OCS pledge and download the manual (www.opcleansweep.org.au)
- Conduct a feedstock loss audit of your site
- Train staff and establish spill protocols
- Install controls to capture and contain any loose pellets or powder
OCS is not a box-ticking exercise—it’s a culture shift. It signals to regulators, customers and communities that your business is committed to preventing pollution before it happens.
A Clear Path Forward
Australia is at a critical juncture in how it addresses plastic pollution. As global regulations tighten and environmental expectations rise, voluntary action must be matched with regulatory consistency.
Victoria has taken strong steps to legislate responsibility for feedstock loss. NSW has the frameworks but not yet the mandate. EPSA and its members are leading by example—but real, systemic change will require national alignment.
By embracing Operation Clean Sweep, businesses not only protect the environment—they futureproof their operations, support the circular economy, and become part of the solution.
How to Implement Operation Clean Sweep at Your Facility
- Sign the pledge at www.opcleansweep.org.au
- Conduct a site audit to assess risk points for spills
- Upgrade facilities with containment systems (e.g., drain mesh, bunds)
- Train staff and build accountability into roles
- Embed OCS into your environmental and safety plans
- Review performance regularly and share your progress
