Submission by Clean Up Australia
in response to the 
Australian Government Productivity Commission 
Waste Management – Draft Report

Principle Contact: 	Sally Whitelaw               
Position: 		Campaign Manager, Towards Zero Waste
Ph: 			(02) 9552 6177
Fax:  			(02) 9552 4468
Email: 		sally@cleanup.com.au  
Postal Address:	Level 1, 18 Bridge Road, Glebe NSW 2037

THIS SUBMISSION CONTAINS NO CONFIDENTIAL MATERIAL

Commonwealth Productivity Commission
Inquiry into Waste Generation and Resource Efficiency
Product Commission
Locked Bag 2,
Collins St East,
Melbourne, Vic 8003

Plastic Bags

July 2006

The following websites provide further information:
www.cleanup.com.au
www.noplasticbags.org.au

Clean Up Australia is responding to the draft’s section on Government information provision and procurement practices: Information and moral suasion instruments. Specifically the references made to the Say NO to Plastic Bags campaign.

Waste Management Draft Report comment:
‘…..the ‘Say NO to Plastic Bags’ campaign relies on descriptions of the land area that could be covered by plastic bags littered in Australia every year. This provides no indication of the true cost of plastic bag litter and obfuscates to fact that plastic bags contribute only 2 per cent (by number) to the total litter stream and that less than 1 per cent of plastic bags ends up as litter.’

Clean Up Australia response:
•	The following facts are provided to the public via the Clean Up Australia website under ‘Say NO to Plastic Bags’:

o	It is estimated that a total of between 50 and 80 million bags enter the Australian environment as litter every year.

o	It has been estimated that it costs governments, businesses and community groups over $4 million per annum to clean up plastic shopping bags

(Source: Environment Australia, Plastic Shopping Bags – Analysis of Levies and Environmental Impacts (Nolan ITU, 2002) www.deh.gov.au/industry/waste/plastic-bags/bags-analysis.html )

•	Land area estimates are provided so the public can easily conceptualise the large numbers of plastic bags produced and given away each year.

•	Whilst it appears that plastic bags might contribute only 2 per cent (by number) to the Australian litter stream (Nolan ITU 2002) and that less than 1 per cent of plastic bags ends up as litter, it cannot be refuted that the 50 to 80 million that annually end up in the environment are a major environmental threat. 
(source: Environment Australia, Plastic Shopping Bags – Analysis of Levies and Environmental Impacts – Nolan ITU, 2002)

•	The Federal Government’s own Threatened Species Scientific Committee has found plastic bags and other marine debris are a direct threat to 20 marine species including the Loggerhead Turtle, Southern Right Whale, Blue Whale and Tristan Albatross. The Committee included injury and fatality to vertebrate marine life caused by ingestion of, or entanglement in, harmful marine debris as a Listed Key Threatening Process.
(Source: http://www.deh.gov.au/biodiversity/threatened/ktp/marine-debris.html) 

•	It is important to note; the source of the Productivity Commission’s information (Nolan-ITU 2002) quotes this statistic in the following context:

‘Plastic shopping bags appear to be only 2% of the Australian Litter Stream, although reliable data on the total litter stream is unavailable. The impact of this litter is increased due to the material’s persistence in the environment and capacity to injure wildlife, particularly in marine environments.’

In 2005, 32% of all items removed on Clean Up Australia Day were plastic and 7% of all plastic items were supermarket and retail shopping bags.
(Source: Clean Up Australia Day Rubbish Report 2005 - http://www.cleanup.org.au/rubbishreport/sources_rubbish.html)

Waste Management Draft Report comment:
 ‘…It also ignores what suppliers and consumers may do as an alternative to plastic bags and the implications of this.’

Clean Up Australia response:
•	The Clean Up Australia website www.cleanup.com.au and the Federal Government funded www.noplasticbags.org.au website managed by Clean Up Australia list  Retailer Tips, Shopper Tips, Take Action pages, Fun Reuse Ideas, a Bag Selector, Supplier Directory and lots of information and advice on Biodegradable bags. 

These websites also provide links for further investigation including the sources of information quoted in the Draft such as Nolan-ITU 2002 plastic shopping bags.

Waste Management Draft Report comment:
There is always a risk that moral suasion instruments that focus on particular narrowly-defined issue divert government and community resources and attention from broader issues or bigger priorities in waste management. 

PACIA argued: ‘Plastic Bags received icon status well beyond their 2 per cent contribution to the total litter stream… the result of the considerable diversion of Federal, State and local government as well as industry and NGO resources into this campaign style issue has meant that litter and other environmental problems previously being dealt with in order of magnitude and impact have been compromised. Work has been slowed and advances impeded to deal with the issue of the day.’ (sub.120, p.10)

Clean Up Australia response:
•	The above quote provided by PACIA excludes a sentence in the middle which states:
‘PACIA acknowledges the importance of not only eliminating plastic bag litter, as indeed all litter, as well as the value and exposure which icon issues bring in developing broader recognition for the need to improve.’

Clean Up Australia agrees with this statement. The emotive and iconic status of the plastic bag only serves as an example of how individual action can bring about large scale environmental change. To diminish the efforts of retailers, shoppers and governments by suggesting the issue does not deserve such attention is a not only unfounded, but detrimental to future efforts and advances in waste management. 

Conclusion”
The Productivity Commission Draft Report – Waste Management -  does not, in Clean Up Australia’s opinion adequately address the issue of plastic bag waste.

References within the Report to the impact of plastic bags ignore evidence the Federal Government has used to list them as a direct threat to marine mammals, including whales and turtles.

The Federal Government’s own Threatened Species Scientific Committee has found plastic bags and other marine debris are a direct threat to 20 marine species, including the Loggerhead Turtle, Southern Right Whale, Blue Whale and Tristan Albatross.

Despite the Productivity Commission’s assertion that plastic bags make up less than 2% of the litter stream, 9as based on the 2002 Nolan ITU Report) an annual audit of the rubbish collected each year on Clean Up Australia Day, as reported in our annual Rubbish Report, demonstrates plastic bags are among the most common plastic items removed by volunteers.

There is a clear impact on the environment, particularly the marine environment with more than half of the tens of thousands of plastic bags collected on Clean Up Australia Day found on beaches, waterfront areas, in rivers and creeks.
Clean Up Australia would like to see the Productivity Commission acknowledge the usefulness of the ‘Say NO to Plastic Bags’ campaign without marginalising the importance of the issue. 

Singlet-style plastic bag use has decreased by 1.22 billion bags since 2002, as a result of plastic bag reduction campaigns managed by environmental groups nationally. 

Shoppers have shown great enthusiasm and willingness to switch to reusable bags instead of single-use plastic bags, with 81% of Australians support a ban on lightweight plastic bags.
(source: CUA commissioned Newspoll Survey conducted April 2005)