30 Mar Ocean Heroes: Barry Orr, International Water Services Flushability Group
“Flushable wipes”. Sound harmless, right? In theory, the term flushable is just a descriptor, applied to products so that consumers know that they can use and flush them without worry. However, the term carries a lot of weight with waste water professionals, many of whom have been embroiled in about a 10 year-long battle with industry over the so-called “flushability” of these products. I spoke with Barry Orr, an international wastewater specialist working in London, Ontario, Canada, about the term “flushable” and how it presents a threat to our waste systems and our oceans.
Alexis: Hi Barry! It’s great to finally have a chance to sit down and chat with you about this really interesting topic. We met on a dive boat about a year and half ago, very far away on the Great Barrier Reef in Australia! Could you start by explaining the history of your engagement with the wipes industry and the term “flushable”?
Barry: Absolutely! So since 2012, the Municipal Enforcement Sewer Use Group (MESUG) in Canada has been looking into the term “flushable”. After noticing a great deal of so-called “flushable wipes” ending up clogging sewage system pumps, we realised there are no standards or regulation on the term: in fact, it was manufacturers who came up with the term for marketing purposes. When we first started discovering this issue, our first instinct was one of collaboration with industry: to this end, we set up a meeting in 2013 with the Canadian Water and Wastewater Association (CWWA), the Canadian Standards Association (CSA) and MESUG, as well as members of the wipes industry to seek a collaborative solution to this growing problem.
To give a bit of context, the wipes industry puts together and distributes a guidance document for all of their brands for what they claim are the best available criteria for testing the flushability of their products. This was what we took issue with, as we felt the guidance document did not have adequate testing guidelines, and allowed very strong wipes to be labeled flushable. We sought to make changes to this guidance document and created a technical working group to address its shortcomings. It is worth noting that at this stage, the industry had released 3 different versions of this guidance document. Each time developed without wastewater industry involvement. For the 3rd Edition they asked several of my US and UK colleagues to review and comment on it. In the end, they excluded them saying they wouldn’t agree, so there was no need to involve them. When we looked at the guidance document, we identified a list of our main concerns and decided that our number one concern was the dispersability of wet wipe products, that is, how much products break up or “fall apart” into the water.
We set ourselves the ambitious target of creating an international standard through the International Standards Organisation (ISO) that could be used by industry when identifying whether or not to label their product as flushable.
A: Okay, so it seems like at this stage, you were trying to work with industry and raise an issue that they may not have had the expertise to address. How did you go about working on an ISO-certified standard?
B: So to get an ISO-certified standard put it place, you need to name experts, go the ISO and put it to the committee, which is made up of member states. Countries then vote to support it, and if others want to participate, you can move forward with the standard. Our first international meeting was held in London, Ontario, Canada, and other meetings occurred in London, United Kingdom and in Grenoble, France. These meetings were good and helped us narrow down the testing criteria that we felt were missing from the current industry guidance documents. Experts raised many concerns, not only over dispersability but also over the drain line connection, which is the connection between the toilet drain and the sewage system.
Moreover, there was a worry about the biodegradability claims that were being made in wipes reinforced with plastic and synthetic fibres, and therefore with questionable biodegradability standards. As it stood, the manufacturer’s testing guidelines for biodegradability allowed brands to use 2 different tests. The most commonly used one was developed by the OECD (Organisation of Economic Cooperation and Development), but this stops the test at 70% biodegradability. This leaves 30% of non-biodegradable materials with every wipe! And so this led us to the pivot on plastics in wipes and how that is affecting waste systems but also the natural water environment.
Many wipes labelled as flushable previous had plastic woven in to reinforce their strength. Now that there has been increasing public attention on plastic, many of these brands have removed the plastic but have been reinforcing their wipes with regenerated cellulose, lyocell, rayon etc. They are pushing these new “eco-friendly” wipes, but these only break down in commercial composting facilities. They are certainly not biodegradable if ending up in our natural water environment.
A: It is so frustrating to see brands use flashy terms like “biodegradability” or “natural products” to trick consumers into making what they think are environmentally responsible decisions. They seem to understand the social capital of those words, but not enough to follow through and be transparent in their manufacturing or labelling choices. How did the ISO standard procedures move forward then?
B: At this point, our working group to develop this standard was actually shut down because the manufacturers hired a lawyer to argue that we were out of scope of the original mandate of the group: we were not supposed to produce a pass/fail criteria, but simply make suggestions. This complaint was ruled valid by the ISO office, but our investigation was still deemed worthwhile, so our mandate changed to a technical report. So in that process we lost the opportunity to create an international standard, but we were still given the chance to investigate this further.
A: How often have we seen this in other environmental movements as well: where the private sector has the capacity, money and time to poke holes in what is otherwise a really valid line of inquiry by the public sector.
B: Exactly. The same thing happened in the US, were a small group of wastewater professionals had been negotiating with the manufacturers on their 4th edition of the guidance document. They worked for 2 years, without getting a counterproposal on the disintegration test. When they finally withdrew, the manufacturers released their own version, saying it was done in collaboration with wastewater. And what’s more, the working group is largely made up of government employees: work keeps marching on and it minimises the amount of time you can work on additional stuff like this. Whereas industry have an enormous budget and they can hire people whose sole focus is just shooting down our work!
A: How frustrating. So what is it like today?
B: We are frustrated but still pursuing this issue. Our group, the International Water Services Flushability Group (IWSFG), made up of many of the same wastewater professionals as in the ISO working group, looked at all the industry tests and pursued them independently to demonstrate where they were falling short. We acknowledged what was already there and what already worked, but suggested small modifications with the same equipment. In this way we were trying to collaborate even though industry representatives were no longer at the table. We sent this publicly available specification to manufacturers and wastewater associations, asking them for comments. We met in 2017 in Madrid to discuss and review the suggested changes to our specification.
A: Did they have valid suggestions?
B: Well, for example, we had sent it out calling it a new standard and we were asked to change the name of it because the word “standard” stipulates that it has gone through the ISO process. We had over 250 comments come through, so we revised it again and met in London, UK in 2018 to get a second round of comments.
Did they have legitimate concerns? Yes, we learned a lot from the comments and put many long hours debating amongst ourselves for the good of the wipe industry.
A: Did industry seem willing to implement the suggested changes to their tests?
B: No, the issue is that the publicly available specification is all voluntary. It was released June 5 2018, at the same time as the industry’s fourth guidance document. And there are noticeable differences between our tests and theirs: for example, the slosh box test, which is conducted to assess the time needed for a product to disintegrate when exposed to mechanical agitation in water.
Industry guidelines decreased the time exposure from 180 minutes to 60 minutes; that was a step in the right direction, but is still far too long. They also raised the amount it has to disintegrate to 60%. In their 3rd edition it only required a wipe to lose 25% of its mass. 25% – can you believe that! They didn’t even have to break apart, just shed some pieces.
But the one thing they did not change was the force in the test. It is the force that really breaks the wipes apart. Their test has so much force it guarantees that their wipes will all pass. Or at least that is how it appears. When the IWFSG developed our test, we compared it to results from real sewer testing. Our configuration of the slosh box produces similar results to the sewer test. The wipes the manufacturers claim break down in their test show up it one piece at the end of the sewer test.
A: For industry players who are not implementing your voluntary tests, how did they react to the specification?
B: Our specification documents was fully rejected in North America, as they felt our modifications were unreasonable. If I remember correctly the president of INDA (The Association of Nonwoven Fabrics Industy)’s comment it was “You wastewater folks are misguided in North America, we are done with Guidance Document 4 and any more talk around flushability. Europe will be our focus”.
A: Wow. So have other countries been more open to change? I saw recently that the UK are implementing a new national standard called “Fine to Flush”, where manufacturers need to have their wipes tested by independent technical experts in order to receive the right to label their products with the “Fine to Flush” symbol.
B: So many of the UK governments representatives who were part of the ISO group were not allowed to participate in the IWSFG because it was non-official, so they came up with their own specification. I should point out that it is very similar to the IWSFG specification, in that it uses way less force to determine whether a wipe disintegrates than the manufacturers guidelines.
It is currently voluntary, but it would be great if this could be part of the ISO. As a traveller, you know that people will bring products from their home country without knowing it may damage the infrastructure of the host country.
What we really want is an international standard and a universal logo to denote flushability. As of now, we have a “do not flush” logo, but there is no standard on the sizing or placement of the logo. In a survey of 100 products in Canada, only 1% were even close to the Industry code of practice, which includes, for example, placing it where it is visible, not under the fold of the product, the size of “do not flush” logo etc…
A: I can just imagine how much damage is being done to our sewage systems and to our marine environments because people are being misled by manufacturers who are printing “flushable” on products that do not belong in the toilet! What is next for your group now?
B: At Ryerson University in Toronto, they recently did a study of flushability using our specification on 101 products in 10 different categories from facial tissue to baby wipes. The only thing that is passing right now is dry toilet tissue but amazingly Ryerson has tested Japanese products and they are meeting the IWSFG specification. So we are looking to work more with Ryerson and investigate more brands. Friends of the Earth is also interested in collaborating with our group to see how to make more people aware of this issue.
A: A lot of exciting stuff on the horizon, then! Barry, thank you so much for taking the time to speak with me today and keep fighting for our sewer system infrastructure and our water environment. Your work is really inspiring and important. I am looking forward to hear how you guys progress on this issue!
You can follow Barry’s work at @yourturnorr on Twitter.