February 10, 2017 Submissions No Comments

Department of Environment and Heritage Protection

Waste Policy Unit,

GPO Box 2454,

Brisbane, QLD 4001

27 February 2017


RE: Submission on Discussion Paper: Implementing a lightweight plastic shopping bag ban in Queensland

Thank you for the opportunity to provide our views on the State Government Discussion Paper: Implementing a lightweight plastic shopping bag ban in Queensland

Wildlife Preservation Society of Queensland (Wildlife Queensland) is one of the longest established and most respected wildlife conservation groups in Queensland. As a key community organisation, we represent over 6500 supporters and local branches throughout the state. Wildlife Queensland is a strong voice for our wildlife and its habitat.

Wildlife Queensland welcomes the decision by the State Government to ban lightweight, single use plastic shopping bags as a critical first step in reducing plastic pollution. We welcome this action in the context of the Government’s stated longer-term plan to reduce plastic pollution.

  • We support the inclusion of so called ‘degradable and biodegradable’ bags in the proposed ban
  • We support the introduction of a ban as soon as practical and certainly by 2018, accompanied by a public and retailer education program
  • We urge the Government to include a number of other problematic products/practices in this proposed ban, specifically the mass release of helium-filled balloons and single use bait bags
  • We also urge re-consideration of heavier (department store) bags in a ban; these should be subject to either a ban or levy
  • We support the establishment of an ongoing improvement process to examine other problematic, disposable plastic products for future policy action.

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    Our Comments

    We welcome the decision to ban lightweight, single use plastic bags in Queensland and include degradable and biodegradable bags in that ban. We welcome the fact that this has bi-partisan support. A ban will dramatically reduce the impact on wildlife, particularly sea turtles and sea birds. It will dramatically reduce the wasteful practice of dumping plastic bags in landfill and reduce fossil fuel use in the production of single use plastic bags.

    Marine debris is identified as a major threatening process for the long-term health of the Great Barrier Reef in the Reef 2050 Long-Term Sustainability Plan. A James Cook University (JCU) study also found that reef corals were ingesting plastics and starving as a result. The CSIRO Marine Debris Report 2014 stated that ‘two thirds of the rubbish found along our coastline is plastic, with most coming from local sources’.

    The banning of plastic bags and the restricting of other plastic products found in the waste stream will reduce marine debris and the plastic pollution problems faced by the Great Barrier Reef.

    We note the horrendous toll that discarded plastic bags are having on wildlife, particularly sea turtles and sea birds. DEHP figures show that 70% of loggerheads found dead in Queensland waters have eaten plastics, and University of Queensland (UQ) studies show that 36% of turtles found dead in Moreton Bay died due to ingestion or entanglement. CSIRO studies show a significant number of seabirds eating plastics with projection suggesting that 95% of species will be eating plastics by 2050. Whilst plastic bags only represent a proportion of this plastic, they are the easiest product to remove from the litter/waste stream and are particularly dangerous when ingested.

    The banning of single use plastic bags was supported unanimously in the 2016 Senate Inquiry Report on the impacts of Marine Debris in Australia.

    The alternatives to single use plastic bags are well known and we encourage everyone to use their own non-plastic BYO bags instead. Using your own bag is a simple solution to a very large problem for the environment.

    We note that the largest single source of plastic bag litter is landfill. An estimated 47% of wind-borne litter from landfill is plastic bags. Discarded plastic bags in landfill is therefore not an acceptable situation as it creates litter and perpetuates poor waste practice. The agenda should be the reduction in waste to landfill and greater source separation, both ambitions undermined by the continued discard of single use plastic bags.

    We note that evidence from South Australia and the ACT, where bans on single use plastic bags are in place, shows that plastic bag litter has been substantially reduced, most consumers have changed their behaviour and use BYO/reusable bags and in both jurisdictions the bans retain significant popular support.

    The banning of single use, lightweight bags (35 microns and below) is consistent with existing bans imposed by four other jurisdictions (SA, NT, ACT and Tasmania). The ban, when implemented, represents a significant step forward in addressing Queensland’s litter and plastic pollution problems.

    In Queensland, an estimated 800 million to 1 billion+ plastic bags are used every year; a ban on high density polyethylene (HDPE) lightweight bags will eliminate a vast majority of these from circulation, and avoid their wasting in landfill or littering of the environment.

    However, a ban on lightweight plastic bags only represents a first step in addressing ‘disposable’ and littered plastic items. This measure (banning lightweight plastic bags) must be seen as a first step and will require the state committing to further policy action on plastic packaging and other problematic plastics.

    We urge the State Government to include a number of other problematic items in its proposed ban and instigate an on-going process, either independently or with other jurisdictions, to identify other problem, single-use plastics and find and introduce suitable alternatives to these or put in place measures to prevent these problem plastics from being used.

    We recommend the establishment of a taskforce for this purpose prior to the introduction of a plastic bag ban in Queensland, with a report back to Government within one year from the introduction of a plastic bag ban.

    Our comments are expressed below under these three required policy components:

    • The current QLD proposed ban
    • Additional items that should be added to the current policy, and
    • Future plastic actions to examine items to be included in future policy improvements.

    As the discussion paper seeks views on four specific questions we have included our views on these questions:

    The Current Proposed Ban

    Wildlife Queensland endorses and supports the joint position by major, state and regional environment and community organisations in Australia (Joint Position on Plastic Packaging February 2016).

    This supports a ban on single use HDPE plastic bags up to 70 microns. This micron range includes the heavier, department store type bag. We take the view that this could be introduced in two phases, starting with bags of 35 microns and below. The proposed ban on lightweight (under 35 microns) is therefore consistent with our position, as long as it is identified as ‘phase one’. However, we see no reason why a ban/levy on heavier bags could not be introduced now.

    Our position also includes the banning of lightweight, so-called ‘degradable or biodegradable’ bags. The proposed ban correctly includes both ‘degradable and biodegradable’ bags. Degradable bags are designed to break into smaller pieces, and, as a result, resemble food for wildlife even more than standard plastic bags. Biodegradable bags contain agents to slow down their decomposition when in contact with liquid, so that they can be useful as a carrier bag. This means that they decompose slowly in the marine environment. Some experts estimate that they take up to two years to decompose. By that time, they have already done the damage.

    Because they are ‘biodegradable’ they tend to be littered more often as consumers think that discarding these bags is acceptable.

    We note that in November 2016, following the Queensland announcement, the South Australian Government expanded its ban to include ‘degradable and biodegradable’ bags. The Queensland proposed ban has both encouraged, and is now consistent with, the ban in South Australia, a state generally regarded as an international and domestic leader in waste and litter policy.

    Wildlife Queensland and its supporters acknowledge that the proposed ban in Queensland is consistent with our joint group’s position, as long as it is seen as a first step.

    We wish to re-iterate that the introduction of a ban must be associated with a public and retailer education program to explain the changes, why these are being made and the best alternative practices that can be adopted.

    pic 1 for submission

    Excerpt from Joint Position on Plastic Packaging February 2016

    Additional Items (additional to a single use plastic bag ban, including degradable/ biodegradable bags)

    As outlined in this joint position and referenced above, Queensland policy measures should be expanded to include other identified problematic plastic items that are often important components of the litter stream and particularly dangerous to wildlife. The Government, in its announcement, referenced the plastic bag ban as a critical step in its Plastic Pollution Reduction Plan. We believe the three most obvious products/practices that should be added immediately are:

    • Mass release of helium-filled balloons
    • Bait bags, and
    • Heavier LDPE (department store style) plastic bags.

    Mass release of helium filled balloons

    ‘If one was to dump 1000 balloons on the roadway, the action would incur a penalty for littering. What gives us the right to dump many thousands of balloons in the ocean? That is very likely where helium filled balloons will end up.’

    What goes up, Must Come Down – Lance Ferris, Australian Seabird Rescue article.

    Include a ban on the mass release of helium balloons in Queensland. Mass releases of these balloons is an act of littering under the Waste Avoidance and Resource Recovery (WARR) Act in the first place, and should not be permitted or endorsed by State or local Government agencies. These balloons also have a huge impact on wildlife from both ingestion and entanglement. We note that the State Government already has an administrative ban on mass releases at any government associated events.

    Released balloons rise up to eight kilometres above land and then ‘brittle fracture’ and return to Earth. The remnants of the balloon and any associated strings tend to resemble jellyfish or squid.

    US Fisheries and Wildlife studies estimate that these balloons take as long as 12 months to degrade; some researchers suggest even longer (Kathy Townsend, UQ).

    In studies of dead Moreton Bay sea turtles conducted from 2006 to 2011, researchers found that pelagic turtles had a preference for rubber debris, of which 78% was found to be balloons. They also found a correlation with colour, with most balloons found in stomachs being either red or orange. A similar finding was made about debris found in short-tailed shearwaters (Lord Howe Island) where red and orange balloons were the majority found. These, by colour, most closely resemble red arrow squid, a food source for both species.

    We note that mass releases of helium balloons (over 19) has been banned in New South Wales for some years and that there is a similar ban on the Sunshine Coast, although we note that these are not well policed.

    pic 2 for submission

    Single Use Bait Bags

    Bait bags represent a major litter problem as they are often discarded at fishing spots by some fishers. There are an estimated three million used in Australia annually.

    There have been proposals to provide bait in biodegradable bags but this practice has never eventuated. However, the problem with biodegradable bait bags is that they would be seen as ‘environmentally friendly’ and therefore more likely to be littered. As previously outlined ‘biodegradability’ does not mean a product is safe or will decompose quickly.

    We support the practice of using re-usable containers for bait. These could either be self-provided by fishers or provided by bait shops with a take-back scheme put in place. Bait bags should be included in the current ban measure.

    Heavier Department Store Bags

    Heavier, department store plastic bags – predominantly low density polyethylene (LDPE) – are identified in the Discussion Paper as a problem, with the suggestion that they be the subject of voluntary action to reduce their use. We note that the National Litter Index estimates that heavier LDPE bags represent 38% of plastic bag litter.

    Wildlife Queensland recommends that LDPE bags be included in the policy measure but that case-by-case exemptions be allowed where the retailer can demonstrate effective management and/or minimal risk of reaching the marine environment.

    If these management processes cannot be demonstrated we recommend an immediate ban or levy be imposed, as part of the current policy measures.

    Given the intention to seek a voluntary reduction approach, the measures most likely to be considered under voluntary action are on-going customer education programs by retailers, a phase-out/ban or introduced levy. Retailers are unlikely to favour an on-going education program, so a phase-out or levy would be the options chosen anyway.

    With a ban on lightweight bags introduced in 2018, will supermarkets supply heavier bags as an alternative? If so, does it not make sense to address heavier bags now and avoid confusion and differing retailer approaches?

    Continuous Improvement Process

    As identified by the state, this proposed policy is set in the context of a longer-term Plastic Pollution Reduction Plan. The joint group’s position calls for an expert taskforce to identify and report back to government on recommended actions to restrict other forms of single use plastic packaging.

    We recommend that this process and taskforce be established as soon as practical, with a report of future action and recommendations provided to government within one year of the plastic bag ban. A review should include the identification of alternative products and practices to single use plastic packaging.

    Wildlife Queensland has identified a number of single use plastic items that should be included in the first review of policy action. We suggest that an ongoing Continuous Improvement Strategy be adopted so that the state can address all problematic plastics in the future. We have listed initial products and these include:

    • Beverage Containers – addressed through Queensland proposed Container Refund Scheme 2018
    • Plastic bags – addressed through Queensland proposed Plastic Bag Ban
    • LDPE bags – proposed voluntary action
    • Plastic microbeads – identified for Commonwealth/state action, but not confirmed
    • Plastic Nurdles – no action confirmed
    • Plastic disposable food ware – no identified action (beyond limited success litter awareness). Note that festivals such as Woodford Festival and the Gold Coast Commonwealth Games have policies in place to eliminate most single use plastic foodware
    • Plastic straws – no identified action (beyond limited success litter awareness)
    • Single use plastic take-away containers – no identified action (beyond limited success litter awareness)
    • Polystyrene cups and lids – no identified action (beyond limited success litter awareness)
    • Bin liners – no identified action
    • Polystyrene packaging – no identified action/no Extended Producer Responsibility policies
    • Release of helium balloons – administrative ban for government associated events
    • Bait bags/discarded fishing tackle – no identified action (beyond limited success litter awareness)
    • Beverage container ring pulls – no identified action (beyond limited success litter awareness) – film, trays, barrier bags – no identified action (beyond limited success litter awareness)
    • Retailer supplied (putrescible) single use plastic packaging – film, trays, barrier bags – no identified action (beyond limited success litter awareness)
    • Microplastic litter – from tyre dust, clothing, assorted plastic product fragments, cigarette filters, etc.

    Specific Questions Posed in Discussion Paper

    Public Discussion Paper, Implementing a lightweight Plastic Shopping Bag Ban in Queensland

    The Questions the Discussion Paper Asks:

    1. What are the appropriate timeframes and transitional arrangements to implement a plastic bag ban in Queensland?

    We want a ban to be implemented as soon as practical and certainly by 2018. However, it is important that it is implemented properly and fully understood, so it is effective. A key feature prior to the introduction of a ban is an education program for both consumers AND retailers. Everyone needs to understand why a ban is being put in place and what alternative practices they should follow. It is important that these education programs are properly funded and achieve their outcomes. It is important that the ban applies to all retailers and is introduced at an appropriate time.

    1. Do you agree that biodegradable bags should be included in a ban?

    Absolutely. Degradable bags are designed to break into smaller pieces and resemble food for wildlife even more than standard plastic bags as a result. Biodegradable bags contain agents to slow down their decomposition when in contact with liquid – so that they can be useful as a carrier bag. This means that they decompose slowly in the marine environment. Some experts estimate that they take up to two years to decompose. By that time, they have already done the damage. Because they are ‘biodegradable’ they tend to be littered more as consumers think that they are okay to discard, because they are biodegradable!

    1. Do you support the Queensland Government working with other states and territories to encourage industry to reduce the number of heavier weight plastic department store bags?

    We need to reduce and eliminate all so-called disposable plastic items. They all end up in landfill – which is not a good choice – or littered in the environment. Landfill is the largest single point source for littered plastic bags and wind-borne plastic litter. Alternatives to thicker bags, such as consumers using their own bags, must be encouraged. The best way to do this is to ban thicker bags or put a price on them.

    1. What else can be done by the Queensland Government to address plastic pollution?

    The release of helium balloons in Queensland should be added to the plastic bag ban now. Similarly bait bags and heavier LDPE bags should be added.

    Other problematic and so called ‘disposable’ plastic items such as polystyrene cups and plates, straws, plastic foodware, and assorted plastic packaging and food trays should be added to a list of problematic plastics for future policy consideration. Discarded fishing tackle is a significant litter problem.

    Microplastics-fibres, film, pellets and beads also need to be managed either through bans, take-back schemes, filtration systems or simply using alternative, non-disposable items. Cigarette butts are plastic fibres and are usually contaminated with chemicals. Microplastics are increasingly recognised as an emerging problem for the environment, wildlife and human health. The state needs to seriously examine these.

    Micro plastics are pieces or fragments of plastic products that range from nanometres to a few millimetres in size. They are usually fragments of film (bags, wrappers), foam (packaging, polystyrene, tyres), pellets (microbeads, nurdles) or fibre (clothing, cigarette filters).

    Synthetic plastics are derived from oil and have, depending upon their use, other compounds and chemicals added. When discarded they tend to break into their constituent parts, except in the aquatic environment where they tend to remain intact at a microscopic level.

    Microplastics are now accumulating in the marine environment, and due to their small size are more readily eaten or absorbed by marine creatures. Many studies show that shellfish and corals are digesting them (EU study on Shellfish plastic contamination/ARC study of GBR Corals 2014).

    Plastic products and materials are made using fossil fuels. Reducing plastic use reduces our toxic load and reduces greenhouse gas emissions.

    Making a Difference

    As outlined in the Discussion Paper, The Queensland Government decision to ban lightweight, single use plastic bags will make a difference by dramatically reducing the number of plastic bags in circulation. It will also encourage new habits and build community awareness about a range of other problematic plastics. We welcome the introduction of this ban, including ‘degradable and biodegradable’ bags, as soon as practical.

    Other problem plastic items as identified above should be included.

    Importantly, this ban should be seen as a first step, with a Continuous Improvement Strategy adopted that will effectively, and as quickly as possible, reduce Queensland’s litter and plastic pollution problems and build a more resilient and healthy state for the future.


    I support Wildlife Queensland’s submission and want to add my voice to the campaign now!

      To place your support, please provide your contact details:

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      Written by Wildlifeqld