Marine litter strategy for Scotland: consultation analysis

3. Strategic Direction 1

Strategic Direction 1: Improve public and business attitudes and behaviours around marine and coastal litter, in co-ordination with the National Litter and Flytipping Strategy.

Context

3.1 Research suggests that the majority of marine litter originates from terrestrial sources. Meeting the challenge of addressing marine litter levels will depend on businesses and individuals, whether at sea or ashore, playing their part by recognising and taking responsibility for their own actions.

3.2 There are currently a range of initiatives aimed at reducing marine litter, raising awareness of the problem, or changing behaviour.

3.3 The refreshed Marine Litter Strategy for Scotland further proposes a range of new actions up to 2027, including for example:

• A review of enforcement of the terrestrial littering and flytipping regulations.
• The development of a waste management system to improve recycling routes for end-of-life fishing gear.

Question 1: To what extent do you agree or disagree that the planned actions under each objective will contribute to the achievement of Strategic Direction 1?

3.4 Table B1 to Table B4 (Appendix B) provides the frequency tables to Question 1.

3.5 The vast majority of respondents (individuals and organisations) agreed (i.e. either agreed or strongly agreed) that the planned actions under each of the four objectives would contribute to the achievement of Strategic Direction 1:

• Encourage positive behaviour and deter littering and flytipping (85.5%).
• Improve waste management in the fishing and aquaculture sector, by establishing systems to support the collection and recycling of gear (86.9%).
• Improve waste management for collected marine litter (87.4%).
• Reduce sewage related debris (SRD) through a behavioural change campaign (84.6%).

3.6 While in agreement overall, organisations with a focus on the issues of coastal development and conservation, or communities, expressed the highest levels of disagreement (note: absolute numbers are small).

Question 2: Do you consider there to be any omissions or gaps in the planned actions identified under Strategic Direction 1 in the Consultation Document that could help to contribute towards its achievement?

3.7 More than half of respondents considered there to be omissions or gaps in the planned actions identified under Strategic Direction 1 (57.4%), Table B5.

3.8 More specifically, organisations were more likely to report that there were omissions or gaps compared to individuals.

Omissions or Gaps Identified

3.9 The wider qualitative feedback has been grouped under each of the four objectives identified for Strategic Direction 1.

Encourage positive behaviour and deter littering and flytipping

3.10 The action under this objective is 'in co-ordination with the National Litter and Flytipping Strategy delivery team, strengthen the enforcement of litter and flytipping regulations'.

3.11 Around one-quarter of respondents who identified omissions or gaps in Strategic Direction 1 provided qualitative feedback on this action, mostly individuals.

3.12 The main issues identified were as follow:

• The most common response was that there needs to be a greater level of enforcement of existing regulations to prevent littering, flytipping and irresponsible waste disposal.
• Various suggestions were made to aid increased enforcement, namely:
  • Increase funding to enforcement agencies.
  • More active patrols of flytipping hotspots.
  • Increase the severity of punishment e.g. higher fines.
  • Target enforcement at the sources of problem litter e.g. fast-food retailers, cigarette butts and single use plastic items.
• Some respondents emphasised the need to incentivise responsible waste disposal, both by making it easier to dispose of litter and offering financial incentives.
• Some hold the view that public awareness campaigns have been limited in their overall effectiveness and that there is scope for improvement in such campaigns to encourage lasting behaviour change.
• There were a few comments which focus on the need for more technological solutions, and specifically the tagging and tracking of litter so that it can be traced back to the source for enforcement purposes.
• There were various comments advocating for an EPR scheme. Such schemes oblige producers to bear responsibility for the environmental impacts of products they place on the market and are incentivised to reduce these impacts (i.e. considering the whole lifecycle of a product; encouraging reuse, repair and remanufacture; and addressing the costs of recycling and disposal).

3.13 The following quotes illustrate the range of views expressed:

"Local Authority funding is being depleted, without additional resources available to them they cannot successfully deter littering at local level, funding needs to be provided for community safety teams or equivalent personnel, to issue fines, and fines associated with littering need to be far greater than currently and action taken against those who do not pay."

ONUS SWSCOTLAND

"We think the gap here relates to engagement from business. If you apply the principle of producer responsibility and make businesses more accountable for the litter for which they are a primary source (such as fast food/takeaway establishments) then they may be incentivised to run their own public awareness campaigns and to invest to provide extra/better disposal facilities for litter that comes from their business."

KIMO UK

"Illegal fly tipping has become a lucrative criminal activity, made worse by the cost and extra effort required for correct disposal. Behavioural change will therefore be difficult, but we could make correct disposal easier, and provide incentives to do so."

Individual

"There needs to be more strongly worded approach to the behaviour of industry, including the fishing and offshore oil industries. They must be made to take responsibility for the damage done and penalised heavily if they fail to do so."

Individual

"Littering and fly-tipping is increasing because companies are pushing ever more single-use/unnecessary produce on consumers, along with excessive packaging. Until this is curbed by penalising companies financially e.g. via EPR, it will not get better."

Friends of Dumbarton Foreshore

Improve waste management in the fishing and aquaculture sector, by establishing systems to support the collection and recycling of gear

3.14 Approximately one-quarter of respondents who identified omissions or gaps in Strategic Direction 1 provided qualitative feedback on the objective to 'improve waste management in the fishing and aquaculture sector, by establishing systems to support the collection and recycling of gear'.

3.15 The main point raised was not related to any specific action – rather it was a more general point on the evidence presented in the Consultation Document. More specifically, some respondents disagreed that most marine litter originates from terrestrial sources. For example, some respondents based in island communities, largely those organisations with a focus on the issues of coastal development and conservation, or communities, reported that most marine litter in their localities stems from the fishing and aquaculture sectors.

3.16 A related point put forward was that the composition of waste in rural and island communities is different from that in other areas – it is said to contain far more waste from the fishing and aquaculture sector.

3.17 A quote outlining some of these concerns includes the following:

"In April 2021, following a marine litter networking and learning exchange event, Scottish Islands Federation (SIF), working with the groups and individuals that took part in the event, set up an Island Marine Litter Working Group. This Group is made of island representatives from across the islands – Shetland, Orkney, Bute, Outer Hebrides, Eigg, Raasay, Skye, Tiree, Gigha, Islay and Arran - and all are active in marine litter and island beach cleaning.

In the experience of the Working Group, and its wider network of island marine litter groups, with the exception of islands in North Ayrshire, marine litter collections comprising 70-90% of waste from the fishing or aquaculture industry is the norm, and therefore, while we very much support the national Marine Litter Strategy, the situation on the ground in islands feels at odds with point 4.4. in the introduction to Strategic Direction 1 which states, "research suggests that the majority of marine litter originates from terrestrial sources".

Scottish Islands Federation

3.18 There was also considered to be a lack of financial and other support available for the voluntary sector and others that support and undertake litter removal initiatives. This was said to limit their ability to tackle the issue.

3.19 Under the specific planned action to 'develop a waste management scheme that assures improved management of end-of-life fishing gear' there were several comments which support the need for actions to increase the recycling of fishing and aquaculture gear, primarily through encouraging the fishing and aquaculture sectors to do more in this area and making it easier to recycle gear.

3.20 It was also considered important that action is taken to help prevent the loss of gear at sea. Responses advocated the use of best practice for the design, storage, and use of fisheries and aquaculture gear.

3.21 Related to this, a number of respondents noted that the focus on end-of-life fishing gear overlooks the dumping or loss of non-end-of-life gear and other single use plastics (e.g. bottles, etc) that come from fishing boats.

3.22 There were a small number of comments from various organisation groupings that felt that there is an overemphasis in the Strategy on waste from the fishing sector and too little a focus on waste from the aquaculture industry, which some said made up a considerable portion of collected waste on beaches.

3.23 It was highlighted that aquaculture sites have established waste management plans that ensure end-of-life materials are disposed in a way that is compliant with legal requirements and that these are monitored through regular internal and external audits.

3.24 Quotes illustrating these issues are provided below:

"We would also recommend, as part of the work to develop this waste management scheme, an extra focus on preventing gear being lost in the first place. This may also tie into the circularity work in action 2 on the CEN standard. Best Practice Guidelines to ensure Fisheries and Aquaculture gear is designed, stored and used need to reduce the risk of loss into the marine environment. Support for the industry must be provided as part of this work to ensure suitable measures or incentives are in place so a reliance on clean-up is not create".

Marine Conservation Society

"It is important to establish IMMEDIATE measures to ensure that ghost fishing gear waste can be appropriately disposed of NOW. Not in 2 -5 years' time when new systems have been developed to recycle it. Volunteers have lifted around 8 Tonnes from the beaches between Monifieth and Arbroath since April 2019. Angus Council have to pay another Local Authority to send it to landfill as we no longer have a landfill in Angus and it can't go to 'Waste to Energy'."

East Haven Together (EHT) and Angus Clean Environments (ACE)

"The rubbish found on our beaches is often not 'end-of-life', but discarded (perhaps through accident) but with no effort to recover it. We have witnessed the carefree attitude with which equipment is discarded, not only causing pollution but a marine hazard to vessels and marine mammals, while it is afloat at sea."

Skye Tide Tidelines

"Although the long-term aspiration is to have capability for processing marine litter in Scotland, we would like to see existing facilities enabled to take plastics collected and taken off the coast. We understand the difficulties with fishing nets clogging machines but the ability is there to reprocess plastics but the lack of demand for the hard plastics collected (and the contamination/quality) means that anything being picked up is likely to be landfilled or shredded for fuel rather than recycled."

Solway Firth Partnership

3.25 The planned action to 'work with the European Committee for Standardisation (CEN) to develop a standard for the circular design of fishing gear to facilitate better waste management and reduce environmental impact' attracted a few comments. There was broad agreement that fishing gear needs to be made of more easily recyclable material.

3.26 The Scottish Environment Protection Agency (SEPA) proposed some additions to the Strategy in this area around developing innovative fish farming systems which capture and make use of waste products, including single use plastics and other marine litter. SEPA further noted that they are currently working with industry to drive innovation in this area.

3.27 Further, the Scottish Fisherman's Federation highlighted that any circular design of fishing gear could only work if newly designed nets can catch fish in a sustainable and profitable way.

3.28 Quotes illustrating these points included the following:

"Work required with manufacturers regarding fishing gear waste, nets/rope etc. Apparently, it's made from various mixes of polymers not easily or financially viable to recycle. So they need to be made from recycled materials and be recyclable at end of life and it's needs to financially viable. The producers of goods need to take responsibility for the waste disposal of them it should not be up to the purchaser/consumer".

ONUS SWSCOTLAND

"There is one company in the EU, based in Denmark, that recycles polyolefin ropes and nets; the kind used by most Scottish fishermen, fish farms and the shipping industry. To ship plastic abroad from Scotland to Denmark is prohibitive both in cost and environmental footprint….Has the Scottish Government considered incentives to recycle polyolefin ropes and nets here?".

Plastic@Bay

3.29 There were relatively few comments concerning the planned action to 'extend access to Port Waste Reception Facilities to fishing vessels'.

3.30 A key point raised was that there is considered to be a lack of recycling/disposal facilities at Scottish ports, particularly at smaller ports in more isolated locations.

3.31 The Scottish Fishermen's Federation also noted concern regarding additional costs that may be imposed on fishing vessels, particularly with regards to Port Waste Reception facilities. The Federation felt that keeping facilities low cost could greatly enhance the chances of fishermen using them.

Improve waste management for collected marine litter

3.32 Relatively few consultation responses made explicit reference to the planned action that sits under this objective, namely to 'explore the potential to support the waste sector to consider recycling opportunities for degraded and contaminated marine plastics, including fishing gear'.

3.33 Much of the wider commentary, as noted above and below, focused on stopping marine litter at source.

3.34 The two main points raised were as follows:

• Crown Estate Scotland reported that there were limited facilities for the recycling of fishing and aquaculture gear in Scotland and most material must be exported or sent to landfill. They supported improving facilities for reusing/recycling this material.
• It was noted that there were currently no UK based companies that specialised in disposal of these materials and they have to be shipped to the EU for processing. A point raised was that industry has difficulty in disposing of end-of-life gear in an environmentally sustainable manner and there could be a commitment in the Strategy to establishing the required infrastructure for the processing of this waste.

Reduce sewage-related debris (SRD) through a behavioural change campaign

3.35 The action under this objective, namely to 'develop, launch and run an awareness raising campaign to promote behaviour change and highlight inappropriate flushing of wet wipes and sanitary items containing plastics down the toilet', attracted a high level of feedback.

3.36 On the one hand, organisation respondents including SEPA and Crown Estate Scotland, among others, were all broadly supportive of the planned public awareness raising campaign, with some noting a willingness to collaborate with Marine Scotland on this.

3.37 Quotes illustrating this point included:

"Scottish Water recently launched our new 'Nature Calls' campaign and we will work with Marine Scotland to update Strategic Direction 1."

Scottish Water

"SEPA would add: SEPA is working with Scottish Water to support source control for inappropriately flushed items as part of the Improving Urban Waters Route Map and is amplifying communications surrounding Scottish Water's Nature Calls campaign.

Scottish Water's Route Map for Improving Urban Waters has the following actions for this:

• Support the Scottish Government to develop proposals to ban single use plastic products, such as wet wipes, and to improve labelling to promote correct disposal.
• Develop and roll out a campaign to educate customers to reduce instances of flushing items which impact the sewerage system.
• Continue to support UK-wide and create new Scottish initiatives to reduce retail and consumer access to products that are inappropriately flushed to help reduce disposal of these items to the sewer."

SEPA

3.38 On the other hand, a more common response from individuals expressed scepticism at the efficacy of the planned behavioural change and awareness raising campaign, and noted that it would need to be much better than previous campaigns to have any significant and lasting effect.

3.39 Many respondents (e.g. largely individuals, including a campaign response) felt that wet wipes and/or other single use plastic items should be banned or reformulated, rather than relying on public awareness raising.

3.40 The main points raised by this cohort of respondents can be summarised as follows:

• There was acknowledgement across the responses that wet wipes are a significant contributor to marine litter. Some want a complete ban on wet wipes, while others felt that it should only be wet wipes containing plastic.
• Some go further and express support for a wider ban on single use plastic items altogether.
• A common view expressed was that awareness raising and enforcement alone may be insufficient to reduce wet wipes and plastic pollution, and that a ban may be the most effective solution.

3.41 The following quotes help to illustrate the range of views provided:

"Ban the sale of wet wipes containing plastic in Scotland."

Individual

"Reduce the amount of plastic and non-biodegradable waste occurring in the first place. If not possible to ban products which are single use and easily discarded badly, heavily tax them. I think trying to change behaviours of the lazy will never succeed, but if the waste thrown / discarded / flushed by them is less harmful or less consumed then discarded efforts will be more effectively targeted to solving the problem of harmful waste products in the sea."

Individual

"Change the requirements for sanitary, baby materials wipes etc to make mandatory these items to be made of 100% biodegradable materials as soon as possible."

Individual

"We need to ban single use plastic wipes. 25 wipes per 100m of beach are found during litter picks on Scottish beaches…As well as this, companies who have created this pollution problem should be made to pay for clean-up operations by law."

Individual

3.42 Some industry respondents raised concern about the wider implications of any potential bans or reformulations of wet wipes. The main points raised in the consultation responses were as follows:

• There can be confusion among the public between biodegradable and flushable wipes.
• That wet wipes are a diverse product used for a variety of functions, including for consumer purposes (e.g. baby wipes, household wipes), professional wipes used in hospitals and care settings, and industrial wipes. Here, responses noted that professional and industrial use wet wipes are generally disposed of via a secure waste system and are less likely to contribute to marine litter.
• That many users of wet wipes do dispose of them properly and may be penalised by any ban on wet wipes containing plastic or wet wipes in general.

3.43 The following quotes help to illustrate the range of views provided:

"Berry Global, as a member of EDANA [the international industry association representing the nonwovens and related industries], supports the need for a behavioural change campaign. However, the focus should not be on the composition (i.e., the presence of plastic), but rather the inappropriate flushing of all non-flushable wet wipes (i.e., those wet wipes neither designed nor marketed as flushable) regardless of composition."

Berry Global

"While there is no place for waste plastic in the environment, it must be acknowledged that many hygiene products, including wipes (irrespective of whether they contain plastic or not) are wrongly disposed of via the toilet. Therefore, Cosmetic, Toiletry & Perfumery Association (CTPA) believes that it is fundamental to inform consumers so that they are encouraged to dispose of wipes correctly. CTPA would suggest the requirement for clear on-pack labelling to advise whether products can be flushed or should be disposed of with household rubbish backed up by a solid, awareness campaign."

Cosmetic, Toiletry & Perfumery Association (CTPA)

"The terms 'biodegradable' and 'flushable' are frequently being confused and a switch to biodegradable plastic free wet wipes would not address the underlying problem of inappropriate disposal of the product via the toilet… Consumer education is key, and it is vital to encourage consumers to dispose of wipes correctly.

It will be critical to acknowledge that a ban on plastic containing wipes on its own would not solve the issue of wipes in the environment. Many wipes are incorrectly disposed of via the toilet which in turn can end up in the environment due to storm sewage overflow discharges from sewage plants.

To summarise, we feel that there are two critical components to prevent wet wipes ending up in the environment and these are:

• To stop consumers disposing of wipes incorrectly, regardless of their composition (which could be addressed by consumer education campaigns and on-pack product disposal labelling).
• To stop any unnecessary storm sewage overflow discharges/pollution incidents.

Wet wipes provide convenient and essential cleaning solutions to many consumers, from babies to adults both in the home, in social care situations and on the move. Wet wipes have become essential to today's hygiene practices."

Nice-Pak International Ltd