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


Memorandum submitted by Absorbent Hygiene Products Manufacturers Association (AHPMA)

BACKGROUND

  The Absorbent Hygiene Products Manufacturers Association (AHPMA) represents the non-competitive interests of the UK manufacturers of infant disposable nappies, feminine hygiene products and adult incontinence products.

  The members understand that the Committee has been discussing disposable nappies and would like to enter the attached document as representing the industry's position.

SUMMARY

  There has been much debate surrounding the environmental impacts of disposable and reusable cloth nappies over recent years. The challenge to reduce levels of household waste and volume of waste sent to landfill has been taken up by Local Authorities who are now examining ways to encourage the removal of disposable nappies from the waste stream.

  Much of the debate has been ill-informed with counter arguments as to the real environmental impact of the different systems. Several Life Cycle Analyses have shown that both systems have an environmental impact and that no one system is more beneficial than the other. The Environment Agency has commissioned a Life Cycle Analysis that is currently underway to determine the true situation. The results of this study are expected to be ready for publication in a few months.

  Landfill sites have been used in the UK as the preferred method of waste disposal for generations and as a consequence the vast majority of used disposable nappies have been sent to landfill sites when discarded. As there is now a need to reduce the level of material sent to landfill, disposable nappies have been targeted as a potential for reducing these levels. Research has shown that disposable nappies do not take up additional landfill space as they spread out to fill void space between rigid materials. It should be emphasised that disposables are compatible with all forms of solid waste management, not just landfill.

  Disposable nappies are the preferred choice of over 90% of parents and research indicates that the reasons for this are they believe them to be comfortable, hygienic, healthy, cost effective, convenient and in keeping with today's lifestyle.

  The Strategy Unit Report "Waste not Want not" has recommended adopting a scheme similar to that operating in West Sussex which involves paying parents a subsidy to agree to convert to cloth nappies. The scheme has been under way since 1999 and to date has signed up 1,400 babies representing 4% of the live births in West Sussex. This is less than the usual percentage of parents expected to opt for cloth nappies in the UK. Women's Environmental Network (WEN) claim 15% penetration of cloth nappies, AHPMA between 5 and 10%. The costs detailed in the SU Report would be £80 per tonne. Should the West Sussex response level be replicated across the whole country, the Government would be subsidising parents who would probably have opted for cloth nappies anyway and there would be little reduction in disposable usage, the primary objective.

  The industry has contributed to reducing the impact of its products through technical improvements. The average volume and weight has been substantially reduced over the past decade.

  AHPMA submits that proposals to penalise the disposable nappy industry for the lack of alternative waste management options over which the industry has no control, is neither acceptable nor compatible with fair trading practice.

LIFE CYCLE ANALYSIS STUDIES

  A number of life cycle analyses (LCA) have already looked at the environmental impacts of reusable nappies and disposable nappies, and the conclusions from the majority of these studies is that both types of nappy system have an impact on the environment albeit in different areas: disposable nappies contributing to solid waste and reusable nappies consuming large quantities of energy, detergent and clean water, the latter acknowledged to be a diminishing global resource.

  A government sponsored LCA is currently underway, and is due to be reported on in 2003. One of the reasons for commissioning this study was to provide additional clarity over the true situation with regards to both nappy systems. AHPMA, and its member companies, welcome this study and are co-operating fully with both the Environment Agency and the consultancy appointed to run the analysis.

  The results from this study are important to ensure parents and stakeholders are aware of the facts on both types of nappy systems. This is particularly important in view of the rising level of misleading information on disposable nappies over the past five years. This has formed the basis of several Advertising Standards Authority rulings in the past year where leaflets from reusable nappy retailers (eg BORN, Cotton Bottoms) and from the main environmental campaigning group, Women's Environmental Network (WEN), have been found to be in breach of the codes of advertising conduct.

  AHPMA contends that it would be appropriate to wait for the conclusions from this LCA study, before determining whether additional programmes and resources should be placed to discourage the use of disposable nappies, in favour of reusable products. This would be a consideration for WRAP who has a mandate that there must be a clear environmental benefit for action in pursuing any recommendation following from the SU Report.

DISPOSABLE NAPPIES AS A PERCENTAGE OF HOUSEHOLD WASTE

  The estimates of the proportion of disposable nappies in household waste vary from 2% to 7%. There has been a widely expressed view over recent years that the average is 4% or higher. However, in the Prime Minister's Strategy Unit Report published in November 2002 the estimate is 2.4%1. This figure was established by Dr Julian Parfitt Chief Analyst to Waste and Resources Action Programme (WRAP)2. This reflects the current levels of usage and the reduced weight of disposable nappies achieved by manufacturer over the past decade. The percentage is far less than many other identified categories of household waste as indicated in the chart3 included in the SU Report.

DISPOSABLE NAPPIES COMPATIBILITY WITH ALL FORMS OF SOLID WASTE MANAGEMENT

Landfill

  Most of the questions about disposable nappies have focused on their disposal in landfills. Today, landfills are constructed with environmental protection as a first priority. These sites use clay or plastic "liners" where solid waste is added in a series of layers and covered with heavy soil, thereby preventing water from seeping through it and percolating into underground water supplies.

  Disposable nappies behave like other forms of MSW and are readily compressed and contained in landfill4, 5. Neither the ingredients of the nappy nor the contents can migrate from properly constructed and maintained landfills. Test conducted under a variety of conditions simulating landfills demonstrate that these materials do not present any public health or environmental safety risk6, 7.

COMPACTION CHARACTERISTICS OF DISPOSABLE NAPPIES IN LANDFILL

  As there are currently few cost-effective and widely acceptable reuse or recycling schemes in use, most solid waste will continue to be disposed in landfill at least for the foreseeable future. However, to extend the useful life of landfill sites, reduce costs, or to remove perceived problem materials, landfill disposal of certain bulky or recyclable items is increasingly prohibited or under scrutiny. Disposable nappies are among these items and indeed in some States in the USA and certain countries including the UK there have been concerted efforts to keep nappies out of landfill based on the perceived impact they have on landfill space.

  In order to ascertain the true impact of disposable nappies in landfill research was undertaken and published in Resources, Recycling and Conservation that concluded the following:

    "It can be reasonably concluded that from the statistical analysis of the experimental data that used disposable nappies do not take up any "real" volume in a typical landfill when present in amounts less than 10% by weight of the total waste mixture ie, below the 10% level, nappies merely fill in voids that would otherwise remain unfilled"8.

Incineration

  Today, waste incineration with energy recovery (waste-to-energy-incineration) is playing an increasingly important part in the integrated waste management system of many modern societies especially in the EU.

  Waste-to-energy incineration is used to achieve a range of valuable waste management objectives, including volume weight reduction, rendering material inert prior to landfilling and energy recovery. Nappies and other hygiene products can be incinerated in properly functioning incinerators including those designed for energy recovery. They do not in any way adversely affect safety or regulated emissions from waste-to-energy incineration processes, relative to average municipal solid waste, and are compatible with waste-to-energy operations and energy recovery systems in incineration plants8.

  The key elements supporting these statements are:

    1.  Disposable nappies consist of commonly used materials which can safely be incinerated under a variety of combustion conditions and do not form unusual or uniquely toxic emission products.

    2.  The high quality of nappy materials positively affects the ash quality in terms of heavy metal load because of their low or undetectable amounts of heavy metals compared with average municipal waste.

    3.  The low ash content of nappies ensures a very high weight/volume reduction (90%) during incineration and thus limits ash production to less than 10% by weight compared to 25% or more for average municipal waste.

Recycling

  In recent years recycling has been receiving increasing support as it facilitates waste reduction and encourages the conservation of natural resources. Different projects have focused on comprehensive investigations of technical and economical feasibility, with a major emphasis on characterising major markets for re-cycled pulp and plastic.

  Recycling has also been studied for hygiene paper products like disposable nappies. Results indicate that while a commercial operation is technically feasible, the economic feasibility of recycling nappies was found to be constrained to a limited set of conditions, mostly related to the high cost of collecting soiled nappies as an individual fraction of waste9. Although interest in nappy recycling continues, (some small companies have started commercial ventures), current information indicates that it is not economically feasible in most areas. In addition, no environmental benefits have been demonstrated for separate recycling of a relatively small waste fraction like hygiene absorbent products10.

Composting and Biogasification

  Composting and biogasification take advantage of the inherent biodegradability of the organic portion of solid waste. In well-designed and well-managed facilities, putrescibles and non-recycled paper waste can be broken down into carbon dioxide, water and compost.

  Studies around the world (Germany, France, Belgium, Switzerland, Austria, the USA, Canada and South Korea) have concluded that current disposable nappies are compatible with a broad range of available composting and biogasification technologies11-15.

  During composting and biogasification inert materials such as plastic from nappies need to be separated from finished compost. There are a variety of technologies available to accomplish this that are being employed at composting facilities designed to handle a broad fraction of solid waste (not restricted, for example, to garden waste).

DISPOSABLE NAPPIES ARE THE PREFERRED CHOICE OF OVER 90% OF PARENTS

  Industry's "in house" data estimates that there are over 90% of parents exclusively using disposable nappies and this rises to around 97% with occasional users, for example, when travelling, away from home or on holiday.

  These estimates are supported by the Mintel Market Intelligence Report published in April 2002. The report indicates an even higher penetration for disposables. The data published states disposable nappy penetration among mothers with children under one year as being consistently in excess of 95% and indeed rising to 99% in 2000. Volumes are therefore very susceptible to the birth rate that has declined steadily over recent years. As a consequence there has been very strong competitive pressure between the major brands resulting in average prices falling substantially. A further reason is that disposable nappies are classified as "Known Value Items" (KVI) This means they are included in the weekly shopping basket of goods that is measured to judge which supermarket chain offers the best value. The reduction of shelf prices has been shown to be approaching 20%. Mintel says the average cost of a disposable nappy fell from 15.1 pence each in 1997 to 12.3 pence in 2002. These figures cover all products including own label brands that account for 9% of the total.

  For parents it is easy to understand why they prefer disposables when considering the availability, choice, convenience, and constant product improvements that have taken place over recent years coupled with the ever decreasing cost and sustained advertising.

  It is against this scenario that the SU Report recommendation will have to succeed in persuading parents to change to using home laundered cloth nappies through offering a subsidy of £18 per household per year during the time they have young babies in nappies.

WEST SUSSEX REAL NAPPY SCHEME

  The SU Report recommendation 16 quotes the West Sussex scheme as the role model for the proposal to convert 550,000 households away from using disposable nappies to cloth nappies. This proposal is designed to divert 124,000 tonnes a year away from landfill based on an estimate of 225 kg per household per annum. The cost over the three year start up period is budgeted at £24 million. This has been calculated at £18 per household per annum based on the West Sussex experience.

  It therefore follows that if each family produces 225 kg per annum and costs £18 in subsidy to be persuaded to change to cloth nappies then the cost per tonne to convert them would be as follows:

  1,000 divided by 225 X 18 = £80

  This would be extremely costly and does not take account of the increased environmental burdens going to water courses and increased energy use for laundering reusables or the cost. Current average landfill fees are circa £50 per tonne and AHPMA believes the proposed subsidy would be better spent on supporting green waste schemes where a more significant amount of material would be diverted from landfill. This would help the UK to meet the new regulation limiting the amount of biodegradable material entering landfills.

  A presentation by Ms S Lee of West Sussex County Council on 10/02/0316 revealed that since inception in 1999 there have been 1,400 children enrolled in the scheme. This equates to 4% of the live births West Sussex. Therefore it can be concluded that the scheme has not succeeded in converting more than the usual number of parents who would have been expected to use cloth nappies anyway but has cost the community charge payers of the county £18 per annum for each of the families enrolled into the scheme. The administration costs are not known at this stage as the scheme has not yet been audited either internally or independently.

  If the West Sussex example is followed (which does not guarantee exclusive cloth nappy use), and the same conversion rate is achieved across the country, the proposal will not deliver anywhere near the objectives set out in the recommendation and there will be little if any reduction in the volume of nappies sent to landfill.

PRODUCT DEVELOPMENT AND TECHNICAL INNOVATION

  There have been a number of technological developments over the past decade that have reduced the dry weight of disposable nappies. The average weight in 1993 as detailed by Haskoning17 was 55.7 grams whereas the current average weight being used by the Environment Agency, which is at present undertaking a Life Cycle Analysis, is 44.64 grams, a reduction of 19.9%. They have also used the Ciba Geigy Scientific tables which give the average weight of urine and faeces passed by a child over its first 2.5 years of life. The average weight of faeces and urine is 381.37 grams per day. These scales are considered by paediatricians to be applicable today even though they are some years old.

VOLUME AND WEIGHT OF DISPOSABLE NAPPIES

  Using the average weight of dry nappies plus the daily weight of urine and faeces the average child passes, allows a calculation to be made of the annual tonnage of soiled disposable nappies. With an average consumption of 5,00018-22 nappies (verified by the different referenced Life Cycle Analyses ) over the 2.5 years or 5.48 nappies per day, this would result in an average weight of 114.23 grams per soiled nappy.
grams
Daily weight of urine/faeces381.37
Average number of nappies per day 381.37 ÷5.48 = 69.59
Average dry weight of nappy44.64
Therefore average weight of soiled nappy 114.23


  The volume of disposable nappies sold during 2001 was 2915 million23. Therefore, the total weight for the year 2001 calculated using 114.23 grams was 332,980 tonnes. Assuming 5% were incinerated then the total tonnage sent to landfill would have been 316,331 tonnes.

  Individual AHPMA member's "in house" data puts the average soiled nappy weight at 110 grams which would have meant a total of 320,650 tonnes or 304,618 tonnes sent to landfill.

  The total household waste figure given in the SU Report for England in 25.1 million tonnes. The English population is 83.6% of the UK as a whole and the extrapolated volume of household waste for the whole country would be 30 million tonnes. Therefore using these data disposable nappies would account for 1.05% of the total household waste, nothing like as much as others have claimed. It also reflects that disposable nappy waste has been falling, in contrast to the overall growth of waste, mainly driven by the technological advances in product design and declining birth-rate.

  Parfitt24 estimates the total to be 500,000 tonnes using DEFRA Municipal waste data and 408,000 tonnes via the sales volume and soiled nappy route.

  Therefore it is likely the actual weight of used disposable nappies in the UK is between 300,000 and 500,000 tonnes with some 95% being disposed in landfill

FAIR TRADING CONDITIONS

  The proposed scheme under recommendation 16 of the SU Report would use taxpayers money to favour one commercial industry over another. If successful the scheme could cause a large number of jobs to be lost in the UK/EU that would be replaced with jobs outside the EU as virtually all cloth nappies are imported from non-EU countries. AHPMA members believe this to be incompatible with fair trading.

CONCLUSION

    —  Disposable nappies contribute between 1and 2% of household waste sent to landfill sites in the UK.

    —  They are compatible with other forms of solid waste management.

    —  The total tonnage is a minute fraction of all waste sent to landfill.

    —  They do not impact on the overall volume of space in landfill.

    —  They are the preferred choice of over 90% of parents.

    —  The proposed scheme to persuade parents to use cloth nappies is based on the West Sussex scheme that has not been successful.

    —  The costs would be very high at £80 per tonne.

REFERENCES

  1 "Waste not, Want not—A strategy for tackling the waste problem." Strategy Unit November 2002. www.strategy.gov.uk

  2 "Analysis of household waste composition and factors driving waste increases" Julian Parfitt WRAP December 2002.

  3 SU Report "Waste not,Want not" Chapter 2. Figure one page 22.

  4 Light, K L, Chirmuley, D.G., Ham, R.K., 1995, "A laboratory study of the compaction characteristics of disposable diapers in landfills." Resources, Conservation, and Recycling, 13: 89-96.

  5 Pohland, F G, Cross, W H, King, L W, 1995, "Fate of absorbent gelling material on disposable diapers codisposed with shredded municipal refuse in simulated landfills.", Int. Nonwovens Journal, 7(2): 42-46.

  6 Sobsey, M D, Wallis, C, Meinick, J L, 1975. Studies on the Survival of Entroviruses in an Experimental Model of a Municipal Solid Waste Landfill and Leacheate. Appl. Environ. Microbiol., 30: 565-574.

  7 Hubert, M S, Gerba, C P, Abbaszadegan. M, et al. Study of the persistence of enteric viruses in landfilled disposables diapers. Environ Sci Technol. 1994; 28: 1767-1772.

  8 Miyomori, K, 1991, Incineration Test for Disposable Diapers, EDANA's 1991 International Nonwovens Symposium, Monte Carlo.

  9 Rittmann, B E, Sutfin, J E, Henry, B, 1992. Biodegradation and sorption properties of polydisperse acrylate polymers. Biodegradation, 2: 181-191.

  10 Ministerie van Volkshuisvesting Ruimtelijke Ordering en Milieubeheer, Environmental and technical-economic assessment of diaper/inco waste treatmenet options in the Netherlands, Final Report, no. 1994/24.

  11 HAPCO Position Paper, Absorbent Hygiene Products and Incineration, 1996, EDANA Brussels, Belgium

  12 Little, A D, 1992. "Report on Disposable Diapers Recycling Programme" United States.

  13 Ministerie van Volkshuisvesting Ruimtelijke Ordering en Milieubeheer, Environmental and technical-economic assessment of diaper/inco waste treatment options in the Netherlands, Final Report, no. 1994/24.

  14 Gellens, V, Boelens, J, Verstraete, W, 1995, Source separation, selective collection and in reactor digestion of biowaste. Antonie van Leeuwenhoeck, 67: 79-89.

  15 Verschut, C, Brethouwer, T D, 1994, TNO-report "Composting of a mixture of VFG waste and used paper diapers".

  16 "What encourages people to use Real Nappies? Results of Recent Research" Sophie Lee, Teresa Ridge. "Reduce Waste, promote Real Nappies!" Conference, Birmingham 10/02/03.

  17 Haskoning 1993. Further Research Environmentally Approved Diapers. Prepared for the Dutch Foundation for Environmental Product Labelling. Nijmegan, The Netherlands. 2.2.1.

  18 Dall, O, Tift, J, 1994. Screening Life Cycle Assessment for Comparison of Diapers. Final Report I/S Okoanalyse, Denmark. 1.2.

  19 Lentz, R, Franke, M, and Thome-Kozmiensky, K J,1989. Vergleichende Umweltbilanzen fur Produckte am Beispol von Hoschen-und Baumwollwinden. In: Kozepte in der Abfallwirtschaft 2. EF Verlag fur Energie-und Umwelttechnik GmbH (Schenkel, W und Thome-Kozmiensky, K J, edds).

  20 Beverly J Sauer, Carol C Hildebrandt, William E Franklin and Robert G Hunt. Franklin Associates, Ltd., Resource and Environmental Profile Analysis of Children's Diaper Systems. December 1993.

  21 Vizcarra, A T, Liao, P H, and Lo, K, 1994 "A Life Cycle Inventory of Baby Diapers subject to Canadian Conditions." Environmental Toxicology and Chemistry, 13 (10):1707-1716.

  22 Franklin Associates Ltd., 1992. "Energy and Environmental Profile Analysis of Children's Disposable and Cloth Diapers, Revised Report." Table 1.1. Prepared for the American Paper Institute Diaper Manufacturers Group.

  23 Mintel Market Intelligence Report Disposable Nappies and Baby Wipes. April 2002.

  24 "How much nappy waste is out there?" Dr Julian Parfitt, Senior Analyst at WRAP. "Reduce Waste, promote Real Nappies!" Conference, Birmingham 10/02/03.

  All of these papers are held at the offices of AHPMA and can be inspected at any time or copies provided.

AHPMA

February 20 2003


 
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