APPENDIX 24
Letter to the Clerk of the Committee from
Dr Peter Spillett, Environment, Quality and Sustainability Manager,
Thames Water Utilities
Thank you for the invitation to provide a written
submission to the Environmental Audit Committee review of the
implementation of the Government's Waste Strategy 2000.
We are committed to supporting the Government
in meeting its targets set out in the Waste Strategy 2000 and
in particular the reduction in landfill use. Our contribution
to this strategy target is reported this year in our independently
verified annual Environment and Conservation Review. The review
reports that by working with our contractors we have successfully
reduced our landfill usage by over 15% compared with 1998 levels.
Thames Water is one of the world's largest water
and wastewater companies, servicing more than 50 million domestic
and commercial customers worldwide. The service we provide, the
type of process we undertake to treat drinking water and wastewater,
and the environmental impact of our operations are directly and
indirectly affected by the composition of products entering the
sewerage system. These wastes either need to be disposed of when
removed from the sewerage system or disposal into the sewage system
controlled at source.
Your e-mail outlines that the Committee will
examine two areas where we would like to provide comment which
relates directly to the disposal of waste to and from the sewerage
system. These are:
1. Current progress with implementation of
the Waste Directive.
2. Producer' responsibility initiatives and
the Integrated Products Policy.
1. CURRENT PROGRESS
WITH IMPLEMENTATION
OF THE
WASTE DIRECTIVE
The implementation of the Landfill Regulations
so far, in our opinion has not been without difficulty. Our main
area of concern surrounds the guidance documentation. For instance,
both DEFRA and the Environment Agency issued draft consultation
documents. These have never been finalised which has created uncertainty.
We also have concerns with the guidance on waste acceptance criteria
as these only establish an interim position until final details
are agreed with the EU; and finally we are concerned about the
programme for issuing new Landfill permits as the staged approach
over 3-4 years will create an unbalanced marketplace and possibly
increased "waste tourism" between waste disposal areas.
We believe the uncertainty that has been created
has lead to a difficult environment for business to both operate
in and plan efficient and effective investment. The downside of
this is that businesses ability to aid the Government in complying
with the EU Landfill Directive and to meet its own waste strategy
targets is being compromised.
2. PRODUCER'
RESPONSIBILITY INITIATIVES
AND THE
INTEGRATED PRODUCTS
POLICY
Wastewater is treated to stringent environmental
standards and closely regulated to ensure that the environment
is protected. The wastewater treatment works are designed to treat
biodegradable wastes and do so very well. However, some non-biodegradable
or persistent materials can enter the wastewater system, which
not only can cause problems at the treatment works, but can affect
the suitability of effluent for recycling to the aquatic environment
and of sewage sludge for recycling to land.
Despite the sludge from the wastewater industry
being recycled to agricultural land, use for land restoration,
production of compost and incineration with energy recovery, certain
consumer products can cause problems for sewage collection and
treatment. Products, which are designed to go in the dustbin,
are often wrongly flushed down the toilet. These can cause sewer
blockages and at the sewage works they have to be removed before
being transported to landfill. This involves both additional energy
and transport.
Thames Water sees the proposals for an Integrated
Products Policy as an important development in this area. We have
communicated our ideas to the European Commission and have provided
information to the Government's Advisory Committee on Consumer
Products and the Environment.
Thames Water also supports the need for the
wider dissemination of product information through the development
of Life Cycle Inventories, strengthening eco-design labelling
schemes to drive market forces towards more efficient products
and to the wider use of life cycle impacts assessments to promote
sustainable thinking amongst manufacturers and customers alike.
We have outlined the key points below:
The main issues for water service companies
We have worked with industry to minimise point
source pollution, wherever practical, through Trade Effluent Discharge
Consents and provision of advice to industry. This has helped
reduce the amount of heavy metals and other non-biodegradable
contaminants entering the wastewater treatment works from industrial
sources. However a major source of non-biodegradable material
and heavy metals are from diffuse sources ie domestic sewerage
and urban surface water runoff. We have divided these sources
into three categories.
1. Products which contaminate water: Some
products contain material that dissolve in water and are then
dispersed to the sewerage system. These include everyday products,
which contain heavy metals such as copper in household plumbing
and active ingredients such as zinc used in medicated shampoos
and creams. Other products available on the domestic market include
timber treatment products, which contain persistent materials
such as hexachlorocyclohexane (HCH or Lindane) and are found readily
available in most DIY stores. Because these components are not
affected by conventional wastewater treatment they pass through
unaltered into the effluent or the sewage sludge stream. These
products, which are in widespread use, will severely curtail sludge
recycling when the new Sludge Directive is implemented.
2. Products intended for disposal to the
sewerage system: Products intended for sewerage disposal can have
a significant impact on the treatment of water and also affect
suitability of sewage sludge recycling to land. These products
include detergents and wet strength toilet tissue. The latter
is a good example of the problems we are faced when new advances
in product design and technology are launched onto the marketplace
without environmental assessment. It is possible that wet strength
toilet paper will not break down easily in the sewerage system
and pose a number of problems; cause an increase in sewer blockages
and overflows, cause clogging of the wastewater treatment process
which increase volumes of waste sent to landfill for final disposal.
3. Products wrongly disposed of to the sewerage
system: There are a range of personal disposable products, which
are inappropriately disposed of to sewer. These include cotton
wool buds, disposable nappies and female hygiene products. Frequently,
these products which contain non-biodegradable components (usually
plastic) are disposed of to sewer rather than through the municipal
solid waste collection system. These products can cause the following
problems, some of which may give rise to a serious public health
risk:
(a) Blockages to the sewer system
(b) Interfere with the wastewater treatment
process
(c) Penetrate fine screens resulting
in litter debris on the riverbanks and beds (this is especially
the case for cotton bud sticks).
(d) Cause littering when sludge is spread
on land.
What are the solutions:
1. Environmental Assessment of Products:
We consider the design stage of a product's life cycle to be key
to reducing the impact of certain products on the wider environment.
There should be new mechanisms to ensure the environmental impact
of the product's whole life cycle is assessed before being launched
into the market place. We support the European Commissions view
that there is a need to develop specific "product panels"
to overcome new product design obstacles but, believe procedures
for environmental impact assessments should primarily be driven
by the relevant stakeholder groups, in agreement with relevant
industry representatives.
Currently, industry use life cycle assessments
to evaluate the whole life cycle impact of its products. They
can be complex, are often misused and can be misleading if assessments
are carried out incorrectly. The use of Life Cycle Inventories
however, if used in a non-misleading and transparent way, can
help manufacturers to take better account of environmental aspects
and improve the life cycle performance of a product.
2. Advice to Customers:—Thames Water
actively supports the "Bag it and Bin it" campaign which
aims to encourage responsible disposal of domestic non-biodegradable
wastes and raise awareness of the problems they cause to the sewerage
treatment process and the wider environment when disposed down
the toilet. Common domestic items causing problems include cotton
buds, disposable nappies, feminine hygiene products, paints, razors
and clothing like tights. Advice is given to householders through
leaflets, press releases and radio interviews.
To help support this campaign we would like
to see manufacturers take greater responsibility for the "end
of life" environmental characteristics of their product eg
publicising the fate of a product on its packaging will educate
users of the correct product disposal route. We would also like
to see the EU take an active role in supporting such initiatives.
3. Educate and steer manufacturers towards
better product design, formulation and information to consumers:
Water is a precious resource and Thames Water has worked for many
years to raise awareness and positively influence the efficient
use of water. We raise awareness amongst the business community
through providing advice, distributing water efficiency leaflets
and sponsoring seminars and workshops on water efficiency and
recycling technology. Therefore, we are keen to support the European
Commission's call for a wider use of eco-labels, to stimulate
customer demands for greener products that have real environmental
benefits.
October 2002
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