EIM0025

Written evidence submitted by the Marine Conservation Society

Introduction

1.The Marine Conservation Society (MCS) is the UK charity dedicated to the protection of the UK’s seas, shores and wildlife. MCS campaigns for clean seas and beaches, sustainable fisheries, protection of marine life and their habitats, and the sensitive use of our marine resources for future generations. MCS produces the annual Good Beach Guide, the Good Fish Guide on sustainable seafood, organises volunteer projects and surveys such as Beachwatch, the Beachwatch Big Weekend and Basking Shark Watch. Beachwatch is an annual clean up and survey of UK beaches which we have been running for over 22 years. We therefore have the most comprehensive data set of marine litter in the UK. We also have a team of technical and policy experts who engage in debate and development with government, regulators, businesses and partners, to minimise the impacts of plastics on the marine environment and it is in this capacity, and with this experience, that we offer our contribution to this timely enquiry.

Executive Summary

2. Over the past few decades, microbeads and other microplastics have increasingly been used in products such as facial and body washes and scrubs, toothpastes, cosmetics and washing powders. MCS is firm in its belief that this should not be the case. A ban is required on the use of microplastics in all personal care products, household washing powders, cleaning products and industrial blast media. For all these products alternative, less environmentally harmful substitutes are available.

3. Microplastics in the marine environment are a serious concern, because of the large densities in which these items are found on UK beaches in sand, mud and subtidal sediment samples. They also found throughout the water column. Because of their size they are readily eaten by animals at all levels of the food web from plankton to whales forming an obvious hazard to marine wildlife, and potentially to human health.

4. There is currently no legislation in the UK or EU specifically regulating the use of microplastics in cosmetic and personal care products, nor is there any legislation covering the discharge of microplastics in treated sewage. Across Europe, cosmetic microplastics could be contributing between 2,461 and 8,627 tonnes or 4.1% of microplastics per year to the marine environment (Sherrington et al. 2016).

5. A huge amount of research is currently taking place to try and ascertain the dangers of microplastics. This is a complicated and difficult task given the inherent complexities in biological systems and their interactions with the environment. MCS therefore believe that the precautionary principle should be considered in the case of microplastics and action needs to be initiated now.

6. The precautionary principle is detailed in Article 191 of the Treaty on the Functioning of the European Union (EU) and “enables rapid response in the face of a possible danger to human, animal or plant health, or to protect the environment. In particular, where scientific data do not permit a complete evaluation of the risk, recourse to this principle may, for example, be used to stop distribution or order withdrawal from the market of products likely to be hazardous.” 

7. Furthermore on the subject of the burden of proof the treaty states “In most cases, European consumers and the associations which represent them must demonstrate the danger associated with a procedure or a product placed on the market, except for medicines, pesticides and food additives.  However, in the case of an action being taken under the precautionary principle, the producer, manufacturer or importer may be required to prove the absence of danger."

8. Although some companies have opted to voluntarily identify and phase out the use of microplastics in some of their products, the pressure to do so has come primarily from the NGO sector. Similarly, the drive to assess and to monitor the efficacy of companies in taking forward their voluntary commitments, and any financial implications associated this, have been largely borne by the NGO sector.

9. MCS firmly believes that stopping these microplastics at source is the most efficient way forward. Costs to remove them during waste water treatment are considered to be prohibitively expensive and complex. The UK has a clear opportunity to lead the way either by banning the production and sale of products containing microplastics in the UK, and/or by leading the push for a ban at EU level. MCS is committed to this objective too, and will assist in facilitating a supportive public narrative, and navigating this path from a legal and policy perspective as best we can.

How do microplastics impact on marine plants and animals? What economic consequences could result from increased microplastic pollution in the ocean?

10. Microplastics impact through:

•                   Ingestion through feeding causing blockages and/or physical harm.
•                   Reducing movement and fecundity (the ability to reproduce).
•                   Ingestion of toxins added to plastics (e.g. fire retardants and plasticisers,) or adsorbed onto the surface of plastics from seawater. e.g. Polychlorinated biphenyls (PCBs) and heavy metals.

11. Microplastics have the potential to be ingested by filter feeds since their size and specific gravity makes them similar to their natural food sources (Brilliant and MacDonald, 2000). The organisms negatively impacted by ingesting microplastic range from the small zooplankton (e.g. Cole et al., 2013) to larger marine animals such as fin whales (Fossi et al., 2016) as well as being found in mussels bound for human consumption (Van Cauwenberghe & Janssen, 2014). Ongoing research on fish in the Thames has found that 80% of Flounder, a bottom feeding species and 20% of Smelt, which live in the water column, have plastic in their guts. http://www.bbc.co.uk/news/science-environment-34408414. Studies on species common for human consumption such as mussels have shown transition of microplatics to beyond the gut (Browne, 2008; von Mos et al., 2012), with negative impacts also recorded in the commonly farmed Pacific oyster (Crassostrea gigas) (Sussarellu et al., 2014).

12. Marine litter, in a broader sense, can cause serious economic damage that manifests itself as direct losses for coastal communities, tourism, shipping and fishing. Potential costs across the EU for coastal and beach cleaning was assessed at almost €630 million per year, while the cost to the fishing industry could amount to almost €60 million, which would represent approximately 1% of total revenues of the EU fishing fleet in 2010 (European Commission). Filtering microplastics from the marine environment would be extremely challenging, expensive and impractical. Stopping the microplastics at source is undoubtedly and significantly more efficient than trying to remove it once in the aquatic environment. WaterUK have stated that “We recognise the potential environmental threat posed by microplastics. The particular form of plastics used in personal care products is almost impossible to treat in a conventional sewage treatment works, and we support the principle of preventing pollution ‘at source’ where this is the most effective and appropriate option.”

13. It has been estimated that £250 million pounds could be saved if microplastics were not present in the marine environment. The cost of microplastics to the aquaculture sector (given a proxy value of £300m) have been estimated as 0.02-0.7% per year of their value (van der Meulen, 2015). 

14. Sector costs could also be incurred if ingested microplastics affect commercial fish and shell fish stocks, or sales as the public become more aware of the issue and express concern through their shopping habits.

How do the main sources of microplastics differ in (a) scale of output and (b) the importance of their environmental impacts? How should these relative impacts direct policy priorities?

15. Primary Microplastics are derived from:

1. Microplastics/beads from personal care products
2. Washing powders and household cleaners
3. Industrial blast media
4. Pre production pellets and powders
5. Fibres from washing clothes

16. Secondary microplastics are derived from:

• Break down of larger objects

17. There is currently no exhaustive list of all the products that contain microplastics. With the exception of cosmetic products, products are not legally required to list all of their ingredients on the label. The contribution (both absolute and relative) from different microplastic sources vary widely, and there remains disagreement. In their report commissioned for DG Environment, Eunomia estimates that the output from cosmetic products is 3-4% (Sherrington et al. 2016).

18. However, what is crucial is that for primary sources 1 to 3, the inclusion of microplastics in these products is unnecessary from a product performance perspective, since adequate alternatives are available. The use of microplastics in therefore avoidable, and furthermore bring no obvious societal benefit. This lack of clear benefits and the clear potential for harm, points to the need to totally remove the use of microplastics in such products, thus removing any potential for harm. In our considered view and based on our own extensive engagement with companies who produce these products, a voluntary approach to phasing out the use of this ingredient only targets some of the products currently using microplastics and will therefore achieve limited progress and accountability. Legislative bans would be the most effective way of reducing this form of pollution.

19. Source 4 is the raw ‘feedstock’ of most plastic items and is the form in which plastic is generally shipped round the world. This source can be minimised by adherence to, or imposition of, high quality control systems in production, packaging and transport, to prevent loss into the aquatic environment.

20. Primary source 5 may the most problematic to solve, but filters for washing machines which would capture synthetic fibres have been mooted. http://www.plasticsouplab.org/showcases/washing-machine-filter/

.What impact could microplastics have on human health? Are there knock-on impacts for Government policies, on e.g. food standards?

21. As microplastics are so small, aquatic life at all stages of the food web ingest them. Plankton, sea birds, fish, turtles and other aquatic life have all been found with plastic in their stomachs. Microplastics are found in mussels bound for human consumption (Van Cauwenberghe & Janssen, 2014). It has been estimated that an average European seafood consumer ingests 11,000 plastic particles a year (Van Cauwenberghe & Janssen, 2014).

22. Microplastics not only release toxic chemicals into the surrounding water and into the tissues of animals that ingest them, but also attract toxic chemicals onto their surface. The fate of these chemicals, if ingested by marine life, is the subject of intense research and there is real concern that toxins may be passed up the food chain and ultimately to ourselves as seafood consumers. A recent study has shown that accumulation of chemical pollutants in fish that ate microbeads from personal care products sorbed with pollutants (Wardrop et al 2016). If accumulation effects do occur, these could have knock on effects for food standards in fish and shellfish as well as implications for the fishing industry as a whole.

Other countries, including the USA, have taken action against microbeads in personal care products. What kind of impact would a similar ban in the UK have on the environmental situation around microplastics?

23. A ban on microplastics in personal care products would be a first step in stemming the flow of microplastics to the marine environment. With other countries already banning them, this would create a level playing field for UK and potentially EU retailers. Although a relatively small component of the overall microplastic load, banning these would be an easy first step that paves the way the further research into ways of restricting the entry of microplastics into the environment.

24. A further easy step, would be banning the use of microplastics in household cleaning products and detergents, and to make such schemes as Operation Clean Sweep more effective or even mandatory. The latter could be achieved through modification of the Environment Agency Discharge consents.

To what extent do larger pieces of plastic in the ocean contribute to microplastic pollution, and how can this be dealt with?

25. All larger pieces of plastic in the ocean will eventually become microplastics. Therefore the most effective way to reduce microplastics, both environmentally and financially, is to tackle plastic pollution at source so that items do not reach the oceans.

26. There has been an increase of over 65% in the average density of beach litter on surveyed UK beaches since 2006. Figure 1 illustrates the steady increase in beach litter levels since 1994, despite yearly variations, with the highest ever recorded in 2015.

27. Figure 1. Litter levels from MCS, The Great British Beach Clean 1994 – 2015

28. For small plastic pieces <2.5cm, there has been a 16.4% overall increase since 2013, and a 97.3% increase from 1998 levels. Small plastic pieces were approximately 30% of plastic pieces recorded in 1998. They are now around 50% of the total. Figure 2 shows the increase in small plastic pieces.

29. Figure 2. Number of small plastic pieces from MCS, The Great British Beach Clean 1998 – 2014

30. As with all littering and waste the problem is easiest to deal with at source. For Primary microplastics the simplest solution is to design products without microplastics. For secondary microplastics, this includes such actions as proper waste management, incentives not to litter, e.g. charges and deposit schemes, as well as the redesign of products to contain less plastic and for products to be more easily recyclable.

31. Potential Solutions for Primary microplastics:

• A ban on microplastics in personal care products, household detergents and cleaning products and blast media
• Ensure that initiatives such as Operation Clean Sweep, which was set up by the plastic industry, as a voluntary scheme to change operational practises in the plastic industry, have true transparency and that reductions are recorded and audited. After more than a decade, the scheme still needs many more companies in the UK to sign up to it for it to be effective. In general, the loss of microplastics through poor plastic management is not seen as a critical issue for companies.
• Water discharge permits to include a limit or prohibition on plastics discharged to the environment.
• Add microplastics to the list of pollutants managed by discharge consents to aquatic environments.
• Support development of a filter to catch micro plastic particles from washing machines, potentially by providing innovation grants. Studies have shown that a single synthetic garment in a washing machine can produce >1900 fibres per wash.(Browne et al., 2011, Leslie et al., 2011)

32. Potential Solutions for Secondary Microplastics:

• Drink containers Deposit Refund Schemes- a single bottle can result in hundreds or thousands of secondary microplastics. Ensuring that a single use item has a value would help to reduce the number littered.
• Charge for single use coffee cups- incentivising multiple use cups/refillable cups.
• Better design for reuse and recycling of plastic items.
• Ensure that marine litter is recognized as a specific problem and addressed in general waste legislation e.g. national waste policies.
• Encourage fishing for litter initiatives following the KIMO model, removing barriers to the processing or adequate disposal of marine litter collected, by ensuring that vessels can land non-operational waste collected at sea at any participating harbour at no extra cost.
• Adopt binding and ambitious waste prevention, resource efficiency and recycling targets and measures and place the concept of a circular economy at the heart of waste/litter policy.
• Appropriate labelling of items such as wet wipes, cosmetic wipes, nappies and tampons as non-flushable (the public are generally unaware that these often contain or are composed of plastics).
• A nationwide education campaign informing the public not to use the toilet as a ‘wet bin’.
• Strengthen eco-design and product sustainability standards, requiring manufacturers to minimise packaging, use recycled materials and design for reuse and recycling.
• Replacement of plastic/polystyrene containers at fast food outlets/cafes/street vendors/festivals with easily recyclable or reusable items.
• Bans on polystyrene food and drink containers.
• Requirement for fast food outlets to supply and regularly empty windproof bins.

How comprehensive and certain is our knowledge about the scale of microplastics and their effects on the natural environment? What should research priorities be, and who should fund this research?

33. There is a large body of research on the scale and effects of microplastics.  Current research is trying to ascertain the dangers of microplastics both to marine life and human health. This is a complicated and difficult task given the inherent complexities in biological systems and their interactions with the environment.  As a result, the precautionary principle must be used when deciding on the best courses of action to reduce the microplastic load in our seas and oceans.

34. Research priorities should be focussed on the potential toxicity effects to marine life (particularly studies in the natural environment), potential harm to human health and finding alternatives to microplastics. This research should be funded through a combination of Governments (national and EU) academia and industry.

How effective is international cooperation around these issues, and what more can be done?

35. There is good international cooperation at the NGO level. The Beat the Microbead Campaign has a membership of 82 NGOs from 35 countries and was instrumental in getting some of the first commitments from companies such as Unilever to remove microbeads from their products. In the UK, MCS is currently campaigning together with Greenpeace, Flora Fauna International and the Environmental Investigation Agency to call for a ban on microbeads and our petition has now reached over 250,000 signatures. This kind of public awareness and pressure should and can be brought to bear, to ensure that more can be done.

36. D10 of the Marine Strategy Framework Directive has pushed marine litter up the agenda and microbeads are now recognised as a problem by many of the Regional Seas Conventions such as OSPAR. The OSPAR Regional Action Plan on Marine litter has a series of actions to reduce Marine Litter. Actions 42, 46, and 47 state:

• 42. Investi­gate and promote with appropriate industries the use of Best Available Techniques (BAT) and Best Environmental Practi­ce (BEP) to develop sustainable and cost-effec­tive solu­tions to reduce and prevent sewage and storm water related waste entering the marine environment, including micro parti­cles
• 46.  Evaluate all products and processes that include primary micro plas­tics and act, if appropriate, to reduce their impact on the marine environment.
• 47. Engage with all appropriate sectors (manufacturing, retail etc.) to explore the possibility of a voluntary agreement to phase out the use of micro plasti­cs as a component in personal care and cosmeti­c products. Should a voluntary agreement prove not to be sufficient, prepare a proposal for OSPAR to call on the EU to introduce appropriate measures to achieve a 100% phasing out of micro plas­tics in personal care and cosme­tic products.  The lead parties for this action are - Germany and Netherlands with the par­ticipati­on of Belgium, UK and Seas at Risk (SAR).

References

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Browne, M.A., Dissanayake, A., Galloway, T.S., Lowe, D.M. and Thompson, R.C., 2008. Ingested microscopic plastic translocates to the circulatory system of the mussel, Mytilus edulis (L.). Environmental Science & Technology 42, 5026-5031.

Browne, M.A., Crump, P., Niven, S.J., Teuten, E.L., Tonkin, A., Galloway, T., Thompson, R.C.  (2011). Accumulation of Microplastic on Shorelines Worldwide: Sources and Sinks. Environmental Science & Technology. 45: 9175-9179.

Cole, M., Lindeque, P., Fileman, E., Halsband, C., Goodhead, R., Moger, J., Galloway, T.S., 2013 Microplastic ingestion by zooplankton. 2013 Environ. Sci. Technol. 47(12) 6646-6655, DOI: 10.1021/es400663f

European Commission  http://ec.europa.eu/environment/marine/good-environmental-status/descriptor-10/index_en.htm

Fossi, M., Marsili, L., Baini, M., Gianetti, M., Coppola, D., Guerranti, C., Caliani, I., Minutoli, R., Lauriano, G., Finoia, M., Rubegni, F., Panigada, S., Berube, M., Ramirez, U. & Panti, C. (2016). Fin whales and microplastics: The Mediterranean Sea and the Sea of Cortez scenarios. Environmental Pollution, 209: 68-78. http://www.sciencedirect.com/science/article/pii/S0025326X12004122

Leslie, H.A., van der Meulen, M.D., Kleissen, F.M., Vethaak, A.D. (2011). Microplastic litter in the Dutch marine environment: Deltares/IVM-VU Report No.1203792-000

Sherrington, C., Darrah, C., Hann, S., Cole, G., Corbin, M. (2016). Study to support the development of measures to combat a range of marine litter sources. Report for European Commission DG Environment. http://ec.europa.eu/environment/marine/good-environmental-status/descriptor-10/pdf/MSFD%20Measures%20to%20Combat%20Marine%20Litter.pdf

Sussarellu, R., Suquet, M., Soudant, P., Lambert, C., Fabioux, C., Corporeau, C., Laot, C., Le Goïc, N., Quillien, V., Mingant, C., Petton, B., Robbens, J., Huvet, A., 2014. Microplastics: long term exposure affects oyster reproduction, Annual conference of the National Shellfisheries Association, Jacksonville, USA, March 29 – April 2.

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Van der Meulen, M.D., Devriese, L., Lee, J., Maes, T., Van Dalfsen, J.A., Huvet, A., Soudant, P., Robbens, J., Vethaak, A.D. (2015) Socio-economic impact of microplastics in the 2 Seas, Channel and France Manche Region: an initial risk assessment. MICRO Interreg project Iva: www.vliz.be/imisdocs/publications/270945.pdf

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Wardrop, P.,  Shimeta, J., Nugegoda, D., Morrison, P.D.,  Ana Miranda, A., Min Tang, M., Clarke, B.O. (2016) Chemical Pollutants Sorbed to Ingested Microbeads from Personal Care Products Accumulate in Fish. Environmental Science & Technology, 50 (7), 4037–4044. http://pubs.acs.org/doi/abs/10.1021/acs.est.5b06280

April 2016