Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence

Memorandum submitted by Proctor and Gamble



  Thank you for your letter of 29 January requesting information specifically on our Pringles package but also more generally P&G's approach to packaging and the environment. We very much appreciate this opportunity to provide our perspective particularly on P&G's wider approach to waste management. We would more than welcome the opportunity to talk this topic further with yourself or members of the committee. We have attached an aide memoire for your consideration.

  At the outset we would like to make the following overall Points:

  1.  Others tell us that we are seen at the forefront of global developments in looking into innovative ways of dealing with the problems of the environmental consequences of doing business. We have engineered our product and businesses processes to operate in a manner that increasingly takes into consideration the global impact of our operations. We were one of the first practitioners to apply Life Cycle Analysis techniques to our business operations and continue to refine this environmental tool. We expand on this point in Annex 1. We have also been responsible for developing the definitive academic and technical reference text "Integrated Solid Waste Management; A Life Cycle Inventory by . . . Mc Dougall". A copy will be sent under separate cover (more are available on request).

  2.  Any food package needs to be viewed in its entirety not just how to deal with the pack after it has been used. The current Pringles package offers outstanding product protection (physically and with regard to taste and safety), and goes someway to allowing the use of food components with better nutritional properties, facilitates reduced transport needs, reduced product wastage and includes a significant use of recycled materials eg the structural paper board tube and steel base are 100% recycled material. All of these factors are presented in more detail in Annex Two.

  3.  With respect to packaging more generally, its prime function is to deliver our products in a condition and a quality that meets or exceeds consumer expectations and ensures that the product reaches our consumers in a safe condition. The second function of packaging is to inform the consumer about the product, both visually and textually at the point of purchase and use.

  4.  Please be assured that we do look carefully at all our manufacture, packaging, transport and disposal to determine what environmental impact it has and whether we can reduce that impact. You will of course be aware for consumer goods manufacturers, there is a constant challenge to reconcile perfect product integrity—transit, handling, shelf display, with minimal packaging—it is of course in our own commercial interests to remove unnecessary and wasteful packaging. As you might expect we are also members of Valpack and as such we are already paying for the collection and recycling of our packaging in the UK.

Proctor and Gamble

14 February 2003

Annex 1

Life Cycle Assessment and Integrated Waste Management: The Future of Waste Management


  This is an aide memoir setting out some background in respect of our track record on waste management. We set out the principles behind Life Cycle Assessment and Integrated Waste Management—two processes that P&G have helped to pioneer. We hope this note is of help to members of the committee.

  Procter & Gamble (P&G) is concerned with solid waste as most of our packages and some of our product enters the solid waste stream. As a responsible global consumer products company we take the consequences of our operation extremely seriously and believe what we do needs to be sustainable for the environment, the economy and socially. We invest considerable funds into constantly seeking improvements in the design and manufacture of our own products, and were one of the first practioners to apply life cycle analysis techniques to our operations and we continue to refine this practice. In addition we have been working with others in many countries to help develop improved Integrated Waste Management systems that are environmentally effective, economically affordable and socially acceptable. As part of this, P&G has set up a Global Integrated Solid Waste Management Team, made up of its experts around the world to promote effective integrated systems for municipal solid waste.


  Solid waste management systems need to ensure human health and safety. They must be safe for workers and safeguard public health by preventing the spread of disease. In addition to these prerequisites, a sustainable system for solid waste management must—in our view—be environmentally effective, economically affordable and socially acceptable.

  Minimising cost, and reducing any environmental burden simultaneously is clearly a challenge and will always lead to trade-off between these drivers.

  Waste reduction is the first objective of a sustainable waste management system followed by sustainable management of the remaining waste. Life Cycle Assessment (LCA) is an environmental management tool that attempts to predict the overall environmental burden of a product, service or function, and can be equally applied to waste management systems, where it can be used to predict likely environmental burdens. By selecting appropriate options for dealing with the various fractions of solid waste the environmental burdens of the whole waste management system can be reduced.


  Integrated Waste Management (IWM) systems combine waste streams, waste collection, treatment and disposal methods, with the objective of achieving environmental benefits, economic optimisation and societal acceptability.

  The Key features of IWM are:

    —  an overall approach;

    —  uses a range of collection and treatment methods;

    —  handles all materials in the waste stream;

    —  environmentally effective;

    —  economically affordable;

    —  is socially acceptable.

  "Integrated Waste Management" is a term that has been frequently applied but rarely defined. We have tried to provide a wider explanation of these two important principals behind our overall approach to waste management. We believe it is best defined as a system for waste management that has control over:

    —  All types of solid waste materials. The alternative of focusing on specific materials, either because of their ready recyclability (eg aluminium) or their public profile (eg plastics) is likely to be less effective, in both environmental and economic terms, than taking a multi-material approach.

    —  All sources of solid waste. Wastes such as domestic, commercial, industrial, institutional, construction and agricultural. Hazardous waste needs to be dealt with within the system, but in a separate stream. Focusing on the source of a material (on packaging or domestic waste or industrial waste) is likely to be less productive than focusing on the nature of the material, regardless of its source.

  An integrated system would include an optimised waste collection system and efficient sorting, followed by one or more of the following options:

    —  Materials recycling will require access to reprocessing facilities.

    —  Biological treatment of organic materials will ideally produce marketable compost and also reduce volumes for disposal. Anaerobic digestion produces methane that can be burned to release energy.

    —  Thermal treatment (incineration with energy recovery). This will reduce volume, render residues inert and should include energy recovery.

    —  Landfill. A process that can increase amenity via land reclamation but a well engineered site will at least minimise pollution/loss of amenity.

  To manage all solid waste arisings in an environmentally effective way requires a range of the above treatment options. Landfill is the only method that can manage all waste alone; since recycling, composting and thermal treatment all leave some residual material that needs to be landfilled. In a landfill the organic fraction of solid waste can be broken down if the appropriate conditions for the growth of aerobic and then anaerobic bacteria occur. These relatively uncontrolled biological processes can take several years to start in a landfill and continue many decades after the landfill has been closed. Methane emissions arise from the breakdown of organic material and groundwater pollution may occur due to leaching of toxic materials from the solid waste. Landfilling operations also require large amounts of space. Use of the other options prior to landfilling can both recycle and recover significant parts of the waste stream and reduce the volume and improve the physical and chemical stability of the residue. This will reduce both the space requirement and the environmental burdens of the landfill.


  Any scheme that incorporates materials recycling, biological or thermal treatment technologies must recognise that effective recycling of materials and production of compost and energy depends on markets for these outputs. These markets are likely to be sensitive to price and to consistency in quality and quantity of supply. Managers of such schemes will need to play their part in building markets for their outputs, working with secondary material processors, and helping set material quality standards. They must also recognise that such markets and needs will change over time, so such standards should not be rigid and based in prescriptive legislation, but be set as part of a customer-supplier relationship.


  An effective scheme will need the flexibility to design, adapt and operate its systems in ways which best meet current social, economic and environmental conditions. These will likely change over time and vary by geography. Using a range of waste management options in an integrated system gives the flexibility to channel waste via different treatments as economic or environmental conditions change. For example, paper can be recycled, composted or incinerated with energy recovery. The option used can be varied according to the economics of paper recycling, compost production or energy supply at the time.


  The need for consistency in quality and quantity of recycled materials, compost or energy, the need to support a range of management options, and the benefit of economies of scale, all suggest that Integrated Waste Management should be organised on a large-scale, regional basis.


  For a waste management system to operate effectively public participation is necessary. Whether simply putting bins by the kerbside for collection on the correct day, taking paper or glass to street side recycling containers or sorting out all recyclable material from their household waste, individuals must understand their role in the waste management system and co-operate with the local authorities for the system to work. Low participation rates in recycling schemes can be improved by communication strategies and objections to waste management facility siting can be minimised by public consultation and education.


  The current best example of an Integrated approach to waste management in the UK is Project Integra in Hampshire which was awarded Beacon Council status for 2000-01. Hampshire achieved a collective recycling rate of over 25% (2000-01), with over 90% of households having access to a kerbside collection of recyclables. Hampshire's target: to recycle 40% of household waste by 2005 is very likely to be achieved ahead of schedule. Significant time, effort and financial investment has been made to develop the Integrated Waste Management system in Hampshire (and more waste treatment facilities will come on line over the next few years further improving the overall performance of the County) but this will ensure that the County can provide a truly sustainable waste management system to its residents for the foreseeable future.

  This example clearly shows what can be achieved when an Integrated approach to waste management is adopted.


  An Integrated approach to waste management that takes a holistic approach has three main advantages for society:

    —  It gives the overall picture of the waste management process. Such a view is essential for strategic planning by local authorities, waste management businesses and waste producers. Handling of each waste stream separately is inefficient.

    —  Environmentally, all waste management systems are part of the same system—the global ecosystem. Looking at the overall environmental burden of the system is the only rational approach, otherwise reductions in the environmental burdens of one part of the process may result in greater environmental burdens elsewhere.

    —  To underpin long-term success, each individual unit in the waste management chain should run at a profit, or at least break-even. Within the boundaries controlled by each operator, the financial incomes must at least match the outgoings. By looking at the wider boundaries of the whole system, it is possible to determine whether the whole system operates efficiently and whether it could run at break-even, or even at a profit. Only then can all the constituent parts be viable, provided that income is divided up in relation to costs.

  An Integrated approach to waste management (IWM) and the use of LCA tools (such as those developed by the UK Environment Agency and the US Environmental Protection Agency) can help the UK develop sustainable waste management. We stand ready to play our part.

Annex 2

Pringles Packaging


  The primary purpose of any food and beverage packaging is to deliver product of the highest quality in terms of safety and taste. The pack also has a secondary function of communicating with the consumer what the product is without them needing to try it. The Pringles pack has evolved over 25 years to achieve these objectives.


  The Pringles pack is a recycled paperboard tube with a paper liner and foil liner (Aluminium foil + polyethylene) to provide an oxygen permeable barrier and prevent migration of unwanted components from the pack to the food. The tube also has an outer paper liner for printing the label. It has a recycled steel base, a peelable foil seal (aluminium and Polyethylene) and a polyethylene cap to re-seal the pack once it is opened. The pack is comparable to commonly used Tetra-Pak


  The physical properties of the Pringles tube are specifically designed to facilitate packing of our stacked crisp—as well as protecting its physical integrity during transport and storage. Broken crisps are a big concern to snack consumers and we have found the current design to offer appropriate protection against product breakage. In addition the pack is distributed globally—which reduces manufacturing ouputs—and has to protect the product across the range of conditions from a Siberian winter to a Saudi summer this clearly puts technical pressure (literally) on the pack integrity. Typical breakage levels in bagged snacks are 60-70% compared to only 11% with Pringles.


  The Pringles tube provides an oxygen barrier preventing migration of oxygen or moisture into the pack. The level of protection is significantly greater than all other snack packaging we have tested. The product is packed under nitrogen to exclude oxygen from the pack. This significantly improves the product stability by reducing the oxidation of the fats in the product. Oxidation of fats in savoury snacks leads to stale flavours, typically damp or rancid. The product protection offered by this system not only means the shelf life of the product is extended for the consumer but also has some important nutritional benefits.


  The exclusion of oxygen from the pack during packing and the oxygen barrier, actually allows the use of less saturated vegetable oils during product manufacture. Without this exclusion higher levels of saturated fats or trans fatty acids would need to be used. The process we use allows us to use a healthier vegetable oil with higher mono-unsaturates and poly-unsaturates than we would otherwise be the case.


  The Pringles tube allows us to produce a very compact product. A 200g Pringles tube contains the same quantity of product that would be found in approximately eight standard crisp packs. On a volume basis this equates to approximately a four-fold difference between Pringles and a bagged snack. Therefore the pack volume is substantially smaller than an equivalent number conventionally bagged snacks. This provides significant environmental and economic benefits. Environmental benefits come from the smaller number of lorries needed to transport the product and the consequent reductions in fossil fuel usage, exhaust emissions and vehicles on the road. This also facilitates a more economical transport system ultimately reducing costs for consumers. There are also significant reductions in storage costs at our manufacturing site, distributor warehouses and retail outlets. Calculation of the transport energy differences between the Pringles can and conventionally bagged snacks indicate that the Pringles can costs just over 2000 MJ of energy per metric tonne of product shipped 1,000 km versus 5,000-7,000 for a conventionally bagged product, ie 2.5-3.5 times lower for the Pringles can.


  Due to the protection offered by the pack this allows an 18 month shelf life for the product. Typically conventionally bagged snacks have a far higher proportion of waste product due to the relatively short shelf life of these products. In small outlets in particular such as pubs and corner shops this can be high. The long shelf life of Pringles eliminates most of this wastage due to out of date stock which has consequent environmental implications through reduced waste of raw materials, product manufacture, packaging, transport, etc. The re-sealable nature of the pack allowing the product to be consumed over 10 days after opening also significantly reduces consumer wastage post-purchase.


  Due to the design of the pack it is possible to use recycled packaging material without compromising the safety of the food product inside. Clearly particular care needs to be taken with the food contact materials which is why the inner liner is of virgin material. However, because of the protective nature of this liner we can and do use recycled paperboard in the tube and recycled steel for the base. Clearly extending the use of recycled materials in a safe way, as adopted for the Pringles can, utilises recycled material. By doing this we help create a self-financing market in pack material recycling. Very few other food packs are able to use recycled packaging.


  It is possible to recycle the Pringles can when appropriate facilities exist. The can is largely comparable to a Tetra-pak with the addition of a steel base. The pack has a high energy value and can be readily incinerated to recover the energy from this pack. The steel base being extractable after the incineration process using magnetic separation from the ash. The pack can also be recycled at recycling mills provided they have the appropriate system in place. The inner liner can be separated from the board in the re-pulping process (recycling occurs in Germany). Unfortunately the UK does not currently have the infrastructure to effectively recycle these types of packs although a mill has recently opened in Scotland. Like most household waste the majority of cans still go to landfill wasting this potentially valuable resource and will behave like any other paperboard pack in the landfill environment. The Pringles pack is an extremely small part of the waste stream.

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