SFI0069

Written evidence submitted by Friends of the Earth

1.               Introduction

1.1.1.      Friends of the Earth welcomes the opportunity to submit evidence to this inquiry. Friends of the Earth England, Wales and Northern Ireland (“Friends of the Earth”) has been working on waste and resource use issues since its very first campaign in 1971, when activists tried to persuade Schweppes to maintain what we would now call a deposit-return scheme on its drinks bottles.

1.1.2.      Since then Friends of the Earth has been one of the most influential campaigning organisations regarding reducing waste and promoting resource efficiency, at local, devolved, national, EU and international levels.

1.1.3.      Friends of the Earth launched a campaign on microfibres in September, which aims to raise awareness of the problem with the general public and encourage clothing brands and manufacturers to find solutions to the problem through better design of textiles and clothing, and with measures to capture microfibres shed during the manufacturing process. As part of the campaign, Friends of the Earth launched a public petition which has 34000 signatures to date.

2.               Executive summary

2.1.1.      The use of plastic for clothing textiles is widespread, yet little understood by the public as shown by a recent poll by YouGov. The washing of clothing has been shown to release significant quantities of plastic microfibres into the aquatic environment, estimated to be in the range of 150 to 3000 tonnes of fibres per year in the UK. Plastic microfibre contamination is also found in agricultural land, atmospheric fall out and a wide range of food and drink products.

2.1.2.      Friends of the Earth urges the Environmental Audit Committee to recommend that the Government develops a Plastic Pollution Action Plan to reduce plastic usage, in the face of wide-spread and irreversible environmental contamination with this material. Friends of the Earth also calls on the fashion and textile industry to implement measures in the manufacturing process to capture fibre shedding, while also researching longer term solutions to the issue.

3.               Submissions

3.1.          The use of synthetic textiles

3.1.1.      Plastic has been used to make fibres for textiles since 1939 when nylon was first used for stockings. Globally, oil is used for approximately 60% of clothing material feedstock according to data from 2010[1].

3.1.2.      A report by WRAP[2] found that viscose, polyester, acrylic, polyamide, polyurethane and polypropylene made up 45% of new clothing and household textiles in the UK in 2009 which was the most recent date that data was available. These are all common oil-based plastic fibres, apart from viscose which is made from cellulose but behaves in a similar way to oil-based plastic.

3.1.3.      A YouGov poll commissioned by Friends of the Earth found that 45% of adults don’t know that new clothes can be made from or contain plastic[3].

3.1.4.      Other than oil-based synthetic fibres, cellulose-based synthetic fibres are also well-established textile materials. Common names for these materials include rayon, viscose, lyocell, modal and cupro. These materials are made from plant matter that has been chemically treated to break it down, then spun into fibres. While it is often claimed that these synthetic cellulosic fibres are biodegradable, there is evidence of their persistence in the environment. Waste water treatment companies from around the world have recommended that any product that claims to be ‘flushable’ such as wet wipes, should not be made from viscose as it fails to degrade in waste water treatment facilities and causes blockages[4].

3.1.5.      Rayon fibres have also been found in deep sea sediments[5], causing doubt that these materials are a solution to microfibre shedding. Rayon has also been found in the digestive tracts of commercial fish species, along with other synthetic fibre types[6].

3.2.          Fashion industry as a source of microplastic pollution

3.2.1.      Microplastics are defined as plastic particles of 5mm or less, and have been found in almost all environmental compartments that have been studied. As researchers began to investigate microplastics in the marine environment and their effects on marine life, they often classified the shapes of the plastic particles as a way of distinguishing them from each other, for example as ‘spheres or pellets’, ‘flakes’, ‘fragments’ and ‘fibres’.

3.2.2.      There are many uses of textiles made from plastic, including for carpets, the maritime and fishing industry as netting and ropes, and industrial uses. Maritime uses are likely to represent a significant source of microplastic pollution as they are used at sea so have a direct pathway into the environment. However, research examining the liquid effluent from Waste Water Treatment Plants (WWTP) has shown that it contains large quantities of plastic microfibres, demonstrating a land-based source of this type of pollution.

3.2.3.      A number of studies have demonstrated that there is significant quantities of microfibres in the washing water effluent of standard home washing machines when clothing made from synthetic materials are washed. The first to measure microfibres from washing machine effluent was Browne et al. in 2011[7] who hypothesised that this was a major source of microplastic contamination in the marine environment and found that a single clothes wash generated 1900 fibres. Since then a number of other researchers have confirmed this hypothesis, but drastically increased the estimate of number of fibres released per wash. This is discussed further in section 3.3.

3.2.4.      It is likely that the fashion industry’s contribution to microfibre pollution begins at the textile manufacturing phase, continues in garment factories and then from the washing of clothing during the use phase. Fibre release is the result of numerous mechanical processes including the cutting of textiles, abrasion and piling of fabrics.

3.2.5.      Pathways to the environment are not very well studied for the manufacturing phase. Release from household washing machines is better understood and discussed further in section 3.3. The pathway for microfibre release from washing machines is via the wash water effluent into the household drainage and onto WWTP which can release the filtered water into rivers or directly into the sea. Once at the WWTP, a percentage of plastic fibres will settle into the sludge, and the rest are released into rivers or the ocean. The percentage of fibres that are removed via sludge is dependent on the type of WWTP. In a study for the European Commission, Eunomia Consulting[8] reviewed various studies on the retention of microplastics in WWTP across Europe and found that the retention rates ranged from 17% to 99.7% for tertiary treatment plants. In the UK, approximately 50% of the population is connected to tertiary treatment plants, with the rest served by secondary plants which will have a lower rate of microplastic retention.

3.2.6.      Fibres that settle into the sludge are still at risk of being released into the environment if the sludge is spread on agricultural land as fertiliser. Fibres have been found in terrestrial soil up to fifteen years after sewage sludge was spread on the land[9], suggesting that fibres are present in the sludge and that they persist in soil. The impacts of plastic microfibres in agricultural soil has not been studied, but there are implications for food production and farm animals. In the UK, up to 80% of sewage sludge is spread on farm land according to the most recent data available from 2010-11[10].

3.2.7.      It is not only marine and aquatic environments that are contaminated with plastic microfibres from textiles, researchers are finding them in many places. For example, one study demonstrated significant quantities of synthetic fibres in atmospheric fall out over Paris[11]. Fibres have been found in tap water, beer and table salt[12]. This suggests wide-spread contamination by this type of pollution.

3.3.          Quantities of microplastics released from clothing

3.3.1.      Numerous studies have attempted to quantify the number or weight of microplastics released by clothing during normal washing, but they are rarely comparable or reach the same conclusions on quantities, partly due to differing methodologies. Currently there is no standardised methodology for monitoring fibre release, however a voluntary commitment by several textile supply chain trade associations in 2018 committed to developing one[13]. While a public announcement on the intention to develop a methodology was made, there has so far been little information made public on the progress of this work.

3.3.2.      A report for the European Commission[14] attempted to collate the various studies on the release of microfibres and estimate a value for the release of microfibres in Europe. They noted the difficulties in comparing studies with different methodologies and assumptions, but attempted to reconcile these differences and extrapolate figures to provide estimations on the amount of fibres generated from clothes washing and the amount likely to be released into water ways in the European Union. They produced a range of figures based on different studies. According to Eunomia, the number of fibres released per average washing load is 3.2 to 17 million fibres. From the same study, they estimated that the weight of fibre release per clothing wash is 0.5g to 1.3 grams.

3.3.3.      An upcoming report commissioned by Friends of the Earth from Eunomia Consulting calculated that the quantity of plastic microfibres generated from clothes washing in the UK is around 4000 tonnes per year. The quantity released into the aquatic environment after WWTP filtration in the UK would be in the range of 150 to 3000 tonnes of fibres per year.

3.4.          Impacts of microfibre pollution

3.4.1.      The environmental and biological impacts of microplastics in general are well documented, it is reasonable to assume that they will be the similar for microfibres. Studies on the environmental and biological impacts of microfibres specifically are limited and needs further research.

3.4.2.      Chemical additives are often added to plastic to achieve specific functional properties, and these can leach out during the production, use and disposal of the plastic. A study by Lithner (2011) found that >50 % of the plastics that are produced are hazardous based upon their constituent monomers, additives and byproducts according to UN and EU frameworks[15]. The same study conducted leaching and toxicity tests on synthetic textiles. The toxicity tests were conducted on the water flee (Daphnia magna) and 83 plastic types and synthetic fibres were assessed. Textiles made from various plastic fibres were found to produce some of the most toxic leachates out of the tested materials.

3.4.3.      A number of marine animals consumed for food by humans have been shown to ingest plastic microfibres in the wild. Most studies have found microfibres in the digestive tracts of marine species which humans normally remove before consumption, however they have also been found in the guts of shellfish such as mussels, shrimps and oysters which are consumed with the digestive tracts. A study which sampled wild caught and cooked mussels for sale in supermarkets found that the mussels prepared for human consumption had significantly more microfibres compared to live mussels which would suggest additional contamination during processing[16].

3.4.4.      A Belgian study estimated that the average consumer of mussels could be ingesting 11,000 microplastics per year[17].

3.4.5.      Microfibres are also found in fish species, one study looked at microplastic polymers from 10 fish species from the English Channel[18]. Of the 504 fish examined, 37% had ingested a variety of microplastics, with the most common being polyamide and rayon, further evidence that semi-synthetic cellulose based textiles also pose a risk to the environment.

3.4.6.      Studies have demonstrated human inhalation of microfibres with evidence of some persisting in the lung tissue[19]. There is some evidence of occupational health risks for textile factory workers. According to the review study Gasperi et al. (2018): ‘Interstitial lung disease is a work-related condition that induces coughing, dyspnoea (breathlessness), and reduced lung capacity in workers processing either para-aramid, polyester, and/or nylon fibers’.

3.5.          Research into solutions

3.5.1.      Research into solutions is still at a very early stage, and many recommended solutions are either the result of individual studies with no replication to date, or are untested for efficacy.

3.5.2.      An obvious solution would be to stop using plastic to make clothing, however this would likely have many more environmental issues. The environmental problems with the production of natural fibres such as cotton, wool and silk are well documented. They include water and land use, high use of chemical fertilisers, pesticides, use of hazardous substances during manufacture, and social issues related to worker conditions and modern-day slavery.

3.5.3.      Many solutions that have been proposed by the EU funded Ocean Clean Wash[20] project involve changing clothes washing techniques to reduce abrasion. Small changes such as washing at a lower temperature, ensuring a full load of washing, using liquid detergent and fabric softener, and air drying instead of using a tumble dryer may all help in reducing shedding emissions.

3.5.4.      While currently under-studied, the design of textiles and clothing may also have a significant impact on the quantities of fibres shed. The length of the yarn, type of weave, method for finishing seams and the design of clothing all seem to be factors in shedding rates.

3.5.5.      The concept of adding filters to all washing machines to capture fibre release is one that is often discussed by relevant stakeholders. There are a number of drawbacks to this approach. One issue is the number of washing machines in use. Retroactively fitting all machines with filters would be very complex and costly, and mandating all new machines to be fitted with filters would result in a slow change as machines tend to last for many years before being replaced. There are also concerns around energy consumption to force washing water through a fine mesh filter, or the time it would take for water to gradually drain through it.

3.5.6.      Another downstream solution that is often discussed in relation to microplastics is adding additional filters to WWTP. Eunomia study for the European Commission estimated that costs across Europe to upgrade existing WTTP to increase microplastic retention would be €1.49 billion per year[21].

3.5.7.      Manufacturers could develop and implement best practice measures to collect fibres shed during the manufacture of the textiles and clothing. One study[22] found that new garments shed significantly more microplastics in the first wash, and quantities reduce in subsequent washes. By placing filters on effluent pipes from any washing in the garment factories, significant quantities of microfibres could be prevented from entering the environment.

3.5.8.      While there is currently no ‘silver bullet’ solution for the problem of microfibre pollution yet, as the issue becomes better understood and more research is invested, reductions in this type of pollution will be possible.

4.               Recommendations

4.1.1.      Friends of the Earth urges that the precautionary principle be followed to reduce microfibre pollution urgently despite the gaps in knowledge. It is undisputable that significant amounts of plastic pollution are released by the fashion industry.

4.1.2.      While further research into impacts and possible reduction strategies is needed, some basic measures could be implemented in the short term to limit fibre release from the manufacturing stage of clothing. Friends of the Earth urges all companies involved in the sale and manufacture of plastic clothing to take responsibility for this pollution and look at measures for its reduction.

4.1.3.      Microfibre pollution is further evidence of the damaging impact of societies’ over-reliance on plastic. To tackle the plastic pollution problem, and to fulfil commitments made in the Government’s 25 Year Environment Plan, a clear action plan to reduce the use of plastic in all but the most essential applications should be developed.

November 2018