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/faeces | 381.37
|
Average number of nappies per day 381.37 ÷5.48 =
| 69.59 |
Average dry weight of nappy | 44.64
|
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 notA 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
|