Written evidence submitted by Professor Richard Thompson OBE FRS (PW0027)
I am Professor of Marine Biology at the University of Plymouth. I have been working on the challenges associate with the accumulation of end of life plastic in the environment and in managed systems for over 20 years. My team were the first to describe microplastics in the ocean in our 2004 paper. We went on the show their global distribution and accumulation in remote locations including the deep sea and Arctic. We demonstrated their accumulation in commercially important fish species and evaluated the associated risks. The main contributor to microplastic accumulation in the environment is the fragmentation of larger items of plastics and much of my current focus is on examining potential interventions on land in terms of design be mechanical separation and behavioural change.
My team have provided key evidence to Environmental Audit and Select Committee hearings on water quality, plastic bag taxation, micropalstics and synthetic fibres in fashion. Our evidence directly informed UK legislation to prohibit the use of micropalstics in rinse-off cosmetics. In 20 years of working on this topic, never has there been the alignment of public policy and industrial sectors in agreement that currently levels of plastic waste accumulation are unsustainable. This presents a unique opportunity to change the way we currently design, use and dispose of plastic items in order to retain benefit, but dramatically reduce impact. The UK Government have made significant commitments to helping achieve that goal. This enquiry is timely and much needed in order to maximise our potential to deliver on those commitments.
1. What measures should the UK Government take to reduce the production and disposal of single-use plastics in England? Are the measures announced so far, including a ban on certain single-use plastics and a plastic packaging tax, sufficient?
To address the challenge associated with the accumulation of plastic both as waste and as litter the UK Government needs to take steps to reduce plastic use and increase the rates of collection and appropriate disposal. The focus on single use-items is appropriate as a starting point because packaging and other single use applications account for the majority (around 40%) of all plastic items produced. While many of these items bring societal benefit, such benefits are short lived compared to the persistence of plastic waste and litter. However, I would argue that measures to reduce unnecessary usage is a better place to focus than trying to regulate production, which may be overseas.
It is also important to recognise that many single use items of plastic bring societal benefit and plastics may well be the best material to deliver that benefit. For example, a PET bottle for a soft drink; represents a lightweight format, which if designed appropriately can have compatibility with recycling. Regrettably many PET bottles are not designed with recycling in mind and present challenges in terms of separation or viability of the recyclate due to sleeves mad e of polymers other then PET or colourings that reduce value.
The challenge then is in identifying and reducing unnecessary use of plastics while at the same time retaining beneficial usage; and ensuring such usage is coupled to appropriate waste collection and management. Unfortunately in the context of this ‘call for evidence’’ an appropriate evidence base contrasting these trade-offs is almost entirely lacking. Measures to help reduce unnecessary use of plastics - microbeads in cosmetics, single use carrier bags, drinking straws are a good place to start, but the real challenges lie in working out the best strategies for more essential items- food and drink packaging, sanitary and medical applications etc.
What is needed is a full life cycle analysis including externalities of the raw materials, the generation and collection efficacy for the associated waste and the potential for the material to be used in a closed-loop circular economy. This analysis needs to include the use of various types of plastic as well as alternative materials. It is only by considering the evidence around alternative material choices and product formats in parallel that we can gather sufficient evidence to reach informed decisions on Questions 1 and 2. That evidence needs to take a trans-disciplinary approach considering economic, societal and environmental perspectives. A key aspect of that will be to understand likely consumer behaviour in relation to product choice, packaging format and responsible disposal; and to establish how best to influence any behavioural changes that might be needed to achieve success.
So in summary are current measures sufficient, in my view they are not and that is partly because with better evidence we could be more targeted and efficient in our actions.
2. How should alternatives to plastic consumption be identified and supported, without resorting to more environmentally damaging options?
Please see my response to Question 1 - we need independent evidence to objectively compare alternative materials from the sourcing of the material, through production, use and disposal. The question is not so much how do we identify alternatives [to plastic] it is how do we identify the best material(s) in terms of utility while in services as well as overall environmental footprint. The product design stage has rarely considered optimising for end of life and this hinders recyclability. So we do not necessarily need alternatives to plastics, rather we need to learn to use plastics, or any alternative material, more responsibly than we have done previously.
3. Is the UK Government’s target of eliminating avoidable plastic waste by 2042 ambitious enough?
This sounds like a nice target, but the difficulty is in the rather ambiguous use of language. What constitutes ‘’avoidable’’ plastic waste. Putting this another way is unavoidable plastic waste, all of the waste problems the government were unable to fix by 2042? A quantitative waste reduction target would be easier to measure success against.
4. Will the UK Government be able to achieve its shorter-term ambition of working towards all plastic packaging placed on the market being recyclable, reusable or compostable by 2025?
This seems unlikely, but actually, I am more concerned about the objective itself. In the absence of the evidence needed on the trade-offs (Question 1) its is impossible to identify which strategy: recycle, reuse, compost is the most appropriate for any given application. Therefore, there is a risk we could be driving toward new ways of doing things that are not necessarily any better. In addition, the terminology used refers to material properties, not to waste management. Simply because an item is ‘’recyclable’ in theory does not mean it will be feasible or viable to recycle it in practice. Similarly redesigning products so that they are ‘compostable’ brings little benefit if they do not reach an appropriate composting waste stream. This is especially concerning if the application itself was avoidable / unnecessary in the first place - if so changing to a ‘’compostable’’ product does not address the issue of unnecessary waste. So to be effective the target needs to be tightened and must to consider measures in relation to the waste hierarchy of reduce, re-use recycle. Only by doing so will we ensure unnecessary products or excessive packaging are avoided irrespective of their material type or its properties.
5. Does the UK Government need to do more to ensure that plastic waste is not exported and then managed unsustainably? If so, what steps should it take?
Yes absolutely, the UK has relatively advanced infrastructure for waste collection, separation and subsequent management, including recycling. Export should only be considered where the UK is unable to deal with the waste appropriately itself AND there is absolute confidence that the country the waste is being exported to has such capacity and that it deals with the waste appropriately. It seems immoral to export our waste to nations that have lower ability to process that waste than we do here in the UK. We need to develop a strategy to ensure we are able to handle the majority of our waste relatively locally to its generation. Measures to achieve this need to consider the materials used and product design in order to maximise the potential for waste management in the UK for example via recycling.
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