Wet wipes containing plastic - proposed ban: strategic environmental assessment

4 Environmental baseline

4.1 Introduction

4.1.1 This section of the Environmental Report describes the character of the environment which may be affected by the proposed ban on the manufacture, supply and sale of wet wipes containing plastic. The focus of this baseline information is therefore on: biodiversity, flora and fauna; water quality, resources, and ecological status; and material assets. This reflects the scope of the assessment as described in Section 3.3.

4.1.2 Marine litter is caused by a range of materials, but the most common of these is plastic.

4.1.3 Marine litter poses a number of problems across the economy, environment, and society. These detrimental effects include damage to marine wildlife, as well as wider ecosystem deterioration, public health issues, impacts on aesthetics, and a wider range of economic impacts across industries reliant on our coastal and marine environment.

4.1.4 Marine litter threatens the realisation of a shared vision for ‘clean, healthy, safe, productive, and biologically diverse marine and coastal environments, managed to meet the long term needs of nature and people’. It may also impact upon Scotland’s strategic objectives, most notably to become a greener, wealthier and fairer, safer and stronger, and healthier Scotland. It is essential that Scotland’s marine and coastal resource is protected from the damage caused by marine litter, including sewage-related debris such as wet wipes containing plastic.

4.2 Biodiversity, flora and fauna

4.2.1 This section of the SEA identifies and characterises current environmental baseline conditions for biodiversity, flora and fauna. It considers current pollution of coastal and marine environments and the effect this has on associated species and habitats, and their interactions.

4.2.2 Marine litter causes negative impacts to biodiversity, flora and fauna through ingestion, entanglement, entrapment, and smothering. Plastic marine litter may also act as a vector for contaminants. The inherent nature of the origin of items of sewage-related debris, i.e. items used for sanitary purposes or having contact with bodily fluids, means they can also be vectors of disease. Reduced pressure from this type of sewage-related debris could reduce the risk of harm caused to biodiversity, flora and fauna.

4.2.3 The impacts described above can cause impairments to how individuals of a species move, seek prey, feed, avoid predators, reproduce, and interact with other individuals of the same species and individuals of other species. These impacts can cause impairments to the functioning of a habitat, the number and variety of species it can host, the number of individuals from each species it can host, and the functions it can provide including nesting sites, spawning grounds, and nursery grounds. In turn, this can affect the ecosystem services that we benefit from including the availability of commercial food species, and carbon sequestration.

4.2.4 The environmental baseline for this topic is drawn from national data on beach litter, including that of sewage-related debris items such as wet wipes, and environmental research studies undertaken by Scottish Government and other organisations as appropriate.

4.2.5 The Marine Conservation Society (MCS) runs two strands of its UK-wide beach litter citizen science surveys: Beachwatch, which runs all year round, and through which MCS has been collecting data for over 30 years; and the Great British Beach Clean (GBBC) which gives a snapshot of beach litter over the period of a week every September.

4.2.6 Both MCS and the Marine Directorate use both the Beachwatch dataset (all year round surveys) and the GBBC dataset (September surveys) to derive statistics describing wet wipe loadings, and loadings of all SRD, around Scotland. The MCS also derives statistics around the whole of the UK. Note that SRD includes all sanitary items, such as sanitary towels, cotton buds, pant liners, etc., as well as wet wipes.

4.2.7 Figure 1 shows how the annual average number of wet wipes calculated for all surveys on Scottish beaches (i.e. the Beachwatch dataset) has changed from 2005 to 2022. The years 2005 to 2010 had low numbers (on average less than 5 wet wipes per 100m of surveyed beach). After 2010 numbers began to rapidly increase to a maximum in 2018 (114 wet wipes per 100m surveyed beach). After 2018 there was a decline that may have been associated with the Covid-19 pandemic, but numbers since 2021 have again begun to increase.

4.2.8 The overall trend over the full period 2005 to 2022 shown in Figure 1 suggests that over that period the average number of wet wipes per 100m of surveyed beach is increasing by about 50 wet wipes every 10 years.

4.2.9 In addition to this data, some additional statistics can be presented.

4.2.10 The average number of wet wipes per 100m of surveyed beach from all MCS beach litter surveys in Scotland (i.e. the Beachwatch dataset) from 2015 to 2022 was found to be 81.

4.2.11 The average number of wet wipes per 100m of surveyed beach from all GBBC surveys in Scotland from 2015 to 2022 was found to be 48, and that during the GBBC in 2022, wet wipes (both those that contain plastic and those that are plastic-free) were the 2nd most commonly found item in Scotland^[22].

4.2.12 MCS has recently adopted using the median figures in their analysis, to bring this in line with the analysis methodology used by OSPAR. This gives a mixed picture across the years when comparing Scotland to the rest of the UK.

4.2.13 MCS noted that between 2015 and 2022, the median number of SRD items found per 100m of surveyed beach in Scotland has exceeded the UK median by 33% in 2015, 60% in 2018, 27% in 2019, and 48% in 2020, was less than the UK median in 2017 by 33% and in 2021 by 50%, and was equivalent to the UK median in 2016 and 2022.

4.2.14 In 2019 the Marine Directorate published a report on Pilot Scottish Beach Litter Performance Indicators (SBLPI). These proposed indicators aim to allow the Scottish Government to monitor the state of litter on its beaches, as well as to evaluate the success of its policies in reducing sources of marine plastics and litter. Regional analyses of trends in abundance of wet wipes found as beach litter have been conducted.

4.2.15 Wet wipes are one of the items used in the SBLPIs. Scotland’s Marine Assessment 2020^[23] (SMA2020) showed the number of wet wipes found on our beaches in the Clyde, Forth, and East Coast (North) regions was increasing at a faster rate than any other single item. Each of these three regions has shown an increasing trend of more than 2 standard deviations per decade, the category of greatest change within the SBLPIs.

4.2.16 Two additional key messages of the SMA2020 report were:

• The proportion of sanitary items in the Clyde and Forth regions is approximately ten times higher than elsewhere in Scotland; and
• Sanitary items are on the increase in the Clyde region and in Firth of Forth harbours.

4.2.17 The overall conclusion from this section is that wet wipes containing plastic are a prevalent and persistent marine litter item in Scotland and their numbers are increasing. Their presence is adding to plastic pollution within the marine environment, which will be posing the types of risk of harm to biodiversity, species and habitats as described in 4.2.2 and 4.2.3.

4.3 Water quality, resources, and ecological status

4.3.1 This section of the SEA identifies and characterises current environmental baseline conditions for water quality, resources and ecological status. It considers current microplastic pollution in coastal and marine environments and the effect this has on water quality and the overall ecosystem.

4.3.2 Plastics degrade over time and through exposure to sunlight and wave action in the marine environment. Plastic breaks down into fragments, and eventually into micro and nano plastic fragments which are not visible to the human eye. These fragments can be ingested by species at all trophic levels, from zooplankton to the largest marine mammals. In turn, micro and nano plastics can be ingested by humans, through consumption of commercial species. A reduction in this anthropogenic pressure and an associated improvement in water quality could reduce the risk of harm caused to the health and resilience of marine species as well as ultimately to human health.

4.3.3 The impacts described above can affect the fitness of individuals of a species, which in turn can cause impairments to how those individuals seek prey and feed, which ultimately may affect how they move, avoid predators, reproduce, and interact with other individuals of the same species and individuals of other species. If micro and nano plastic pollution causes these extra burdens to individuals, this can lead to cumulative negative effects on one or more species. This may lead to a reduction in the population of particular species, as well as increases in population of other species, which overall can affect the ecological status of the whole ecosystem.

4.3.4 The Marine (Scotland) Act 2010 provides a framework to help balance competing demands on Scotland's seas. It includes a duty to protect and enhance the marine environment. The management of marine litter falls under the scope of marine planning within the Act.

4.3.5 Please see 4.2.5 to 4.2.14 above.

4.3.6 The overall conclusion from this section is that wet wipes containing plastic are a prevalent and persistent marine litter item in Scotland. Their presence is adding to micro and nano plastic pollution within the marine environment, which will be posing the types of risk of harm to water quality and marine ecological status as described in 4.3.2 and 4.3.3.

4.4 Material assets

4.4.1 This section of the SEA identifies and characterises current environmental baseline conditions for material assets and evaluates how these baseline conditions are likely to change due to the introduction of the proposed ban. The scope of built assets is defined within this Report as new or existing infrastructure required for managing sewage and waste water.

4.4.2 The UK’s sewer system was designed to manage waste water with the added debris of toilet paper only. It was not designed for the waste management of plastic debris. UK sewers allow domestic waste water to mix with rainwater. During periods of heavy rainfall, holding tanks are designed to overspill to prevent sewage backing up into homes and dwellings, and as a result release untreated dilute sewage into rivers, waterways, and the sea through CSOs.

4.4.3 Physical screens are used on some CSOs to prevent larger solid debris from entering waterways and causing litter and pollution. These screens cannot capture every single item, and in particular small items such as cotton buds or flexible items such as wet wipes can pass through these screens and end up in the waterway.

4.4.4 A reduction in pressure on the sewer assets from sewage-related debris such as wet wipes could reduce the risk of harm caused by a poorly functioning sewer system, or harm from planned spills of untreated sewage from CSOs.

4.4.5 The impacts described above can lead to the impairment of an effectively functioning sewer system, through the blockage of pipes, damage to screens which in turn can lead to more sewage-related debris entering waterways, and the overspilling of sewage during heavy rainfall.

4.4.6 Scottish Water acknowledge some assets need to be upgraded or improved, and aim to achieve this through the Improving Urban Waters – Route Map.

4.4.7 In 2020 there were around 36,000 blockages within the public waste water network that Scottish Water needed to resolve^[24]. Over 80% of these were due to inappropriate disposal of items, including wet wipes, nappies and sanitary towels. These 36,000 blockages cost around £7 million to clear. Reducing inappropriate disposal of sanitary items in the sewer network will help to reduce the number of blockages, which in turn will help reduce environmental pollution incidents. A ban on wet wipes containing plastic will not eliminate blockages entirely, as wet wipes not containing plastic and other SRD items will continue to arrive in the sewer system as long as incorrect disposal of such items continues to occur.

4.4.8 Scottish Water aims to improve understanding of the source of SRD pollution by increasing monitoring of CSOs through expanding the network of permanent Event Duration Monitoring (EDM) facilities across the CSOs in Scotland. The intention is to install approximately 1000 EDM facilities in CSOs that are discharging to the highest priority waters (including all designated shellfish and bathing waters) in 2023 and 2024. There will be further evidence gathering and consideration of the installation of EDM facilities in approximately a further 2,600 CSOs, with the consideration of further monitoring as part of Scottish Water's Improving Urban Waters - Route Map.

4.4.9 Development of solutions will be prioritised at CSOs confirmed as being high priority as a result of significant SRD impacts on the environment. The intention is that solutions for 108 CSOs will be designed and developed by 2024. Further CSO solutions will be designed and developed at CSOs confirmed as being medium priority, subject to Scottish Water investment prioritisation and planning^[25] by 2027. Implementation of solutions should reduce the quantity of SRD released during spill events.

4.4.10 The overall conclusion from this section is that wet wipes, including those containing plastic, are a prevalent and persistent item of sewage-related debris found in the sewer system in Scotland. Their presence is adding to plastic debris found within the sewer infrastructure, which will be posing the types of risk of harm to material assets as described in 4.4.2 to 4.4.5.

4.5 The likely evolution of the baseline in the absence of the proposed ban

4.5.1 Without the proposed ban on the manufacture, supply and sale of wet wipes containing plastic the current situation will be likely to continue, if not to deteriorate further. As noted at Section 2.4, business and public behaviour change measures implemented to date have not altered the situation, and the use of wet wipes has increased due to the Covid-19 pandemic. Certain manufacturers have produced wet wipes that do not contain plastic and meet the Fine to Flush standard, but these are generally restricted to moist toilet tissue wipes, and there is no incentive or push to change the formulation of other types of wet wipe. Only a ban on the manufacture, supply and sale of wet wipes containing plastic will result in manufacturers changing to produce non-plastic wet wipes.

4.5.2 Without the proposed ban, wet wipes containing plastic will continue to be flushed down the toilet and littered, posing a threat to biodiversity, habitats and species. Wet wipes that arrive in water bodies or in the sea will break down into micro and nano plastics, causing pollution and reducing the water quality status, which in turn will affect the species and habitats within the water body. Wet wipes that arrive in the sewer system will continue to cause blockages and potential damage to infrastructure.

4.6 Enhancement measures

4.6.1 If a ban on wet wipes containing plastic were implemented, the alternative products on the market would be made from cotton, paper, or other non-plastic substrates. It is expected that these would not pose the same risk of harm to the marine environment, nor would they add to the burden of marine plastic litter that currently exists. Despite this, there is a benefit of continuing with awareness raising campaigns to make the public aware that these items could still end up as litter, and that proper disposal is still required.