As Rousse—and his task force—work on the fourth edition of flushability guidelines to change some pass/fail thresholds and develops labeling practices for non-flushable wipes, he is also working to combat bans on flushable wipes that are being considered in places like New York City, which he thinks will do more harm than good to public sewage systems.
The stakes are high when it comes to this issue, Rousse tells HPCW, as thousands of tons of capacity are set to come onstream around the world in the coming months. He sat down to speak with us about how important it is to reverse public misperceptions of flushable wipes’ role in septic problems—not only for our industry but for the public good.
HPCW: Can you provide an update on the latest round of flushability guidelines in terms of the timeline and how it will be different than the GD3?
DR: The development of the Fourth Edition of the Flushability Assessment Guidelines, known as the GD4, was expected to be completed by the end of June but now looks like it may be the end of year. We are focused on changing the pass/fail thresholds on two of the seven test methods. There is a need to do this on a scientifically justifiable basis—not just a negotiation. There is little to no research or data on this beyond what INDA members have developed so getting a thorough understanding and acceptance of key principles related to this is taking some time.
Beyond these pass/fail changes, we expect the balance of GD4 to be essentially that same as GD3. However, there is a corollary group looking at the other element of our Code of Practice, and that is the labeling mandates for wipes NOT marketed as “flushable” but could be flushed because they are used in a bathroom setting or come in contact with certain bodily fluids. This group will be addressing the “Do Not Flush” symbol and placement on packaging for these products. So both elements of the Code of Practice are in play, with end-of-year timing expected.
HPCW: Does the wastewater industry continue to participate in the development? What have these agencies brought to the table?
DR: The wastewater sector is actively participating in this development with a strong presence and voice. Representatives from NACWA, APWA, CWWA and WEF are at the table. The drafting group is overseen by a Principals Group of the association management to address any impasses. They continue to believe, as we do, that working through this process and getting a definition for flushability that both sides agree to is the most important step to enable us to move forward to a true educational outreach initiative that guides consumers on what they can and cannot flush, all through a mutually agreed Code of Practice for the proper labeling of nonwoven disposable wipe products.
HPCW: Have the FTC/Nice-Pak lawsuit and subsequent legal issues hurt or hindered your efforts?
DR: That settlement in 2015 related to products discontinued in 2014 so it is really not germane to today’s products. However, a court in New York City where several of the class action lawsuits are being tried has asked the FTC to determine a definition for “Flushable.” We do not know if the FTC is, has or will take this up. We have, nevertheless, offered to the FTC access to our full scope of science and research on this issue, and received a polite “thank you” for this offer. So the FTC potential involvement in this issue is out there, but more in the background.
HPCW: How is INDA and your member companies handling pending anti-flushability legislation (like the proposed bill banning flushable wipes in NYC)?
DR: The threat of misguided legislation is the most imminent threat we are facing on this issue. Wastewater utilities see wipes in their system, see some wipes marketed as “flushable” and draw the erroneous conclusion that all wipes are “flushable” and are causing their problems.
The facts belie their position. Only 7% of wipes are marketed as “flushable.” The other 93% are NOT advertised or marketed as “flushable.” In fact, most of these have “Do Not Flush” instructions or symbols on their packaging instructing that they be disposed of in the trash. But we need to do better on the labeling of this disposal instruction, and educate consumers to be aware of proper disposal instructions regarding all products that could be flushed.
“The Toilet is NOT a Trashcan” is a message we want to get to consumers. But our resources are required to first prevent misguided legislation that targets the wrong products. We are doing this now in New York City and Minnesota, and know that several other jurisdictions are watching these carefully.
We believe that education, not legislation, will lead to a real reduction in the burden caused by the inappropriate flushing of products never designed to be flushed, be they disinfecting wipes, baby wipes, facial wipes, hard surface cleaning wipes, paper towels or feminine hygiene products.
Flushable wipes are highly engineered products designed to break down as they pass through the wastewater collection and treatment process. They are made of primarily cellulosic fibers, not plastic. These fibers enable the wipes to sink, not float like plastic. The fibers are short, not long, so they disentangle more readily, and therefore lose strength.
Some wipes made from polypropylene or polyester are very strong and can stretch and “rope” in pumps, causing the issues blamed on the flush-friendly wipes. There is a big difference among the many types of wipes. Legislation punishing those wipes designed and engineered with properties enabling them to weaken and break up in the system will only make the situation worse, as consumers will either not pay the higher prices for these products that costly third party testing and special labeling may require, or these products will not be made available in the markets where misguided legislation is passed. But the consumer need for a supplemental personal cleaning product in the bathroom will still be there, and growing.
The consumer will be forced to meet that need with a lower cost product that is NOT engineered to be disposed of in the wastewater system, but will be because the legislation has made the correct product too expensive or not available. So the stakes are high.
We believe that a proper diagnosis of the problem is necessary for a proper solution, and thus our involvement in these legislative threats.
HPCW: Can you tell me how the advances in flushable technology have helped your efforts? How are the flushable wipes of today different from those of a few years ago?
DR: The science of having wipes be strong at point of use and then lose that strength rapidly upon being flushed has advanced considerably over the last five years, and continues to evolve. Cellulosic fibers are available now that are shorter than before. Fiber lay-down and bonding processes have been designed to optimize the strength performance requirements of wipes for this use (high strength in use/fast release when flushed). Chemical bonding products have been introduced to help this process. And developments continue. The latest generation of flushable wipes loses strength much more rapidly than before.
Thus the practicality in adjusting the pass/fail limits of some of the tests of GD3 to advance to a GD4. Legislation, on the other hand, would fix performance requirements at a point in time, and provide no incentive to continuously improve. That is why we believe our Flushability Assessment Guidelines, a living document, is the better way to address the flushability issue. And we have the evidence of better products today through innovation to back this up.
HPCW: What is the number one challenge you and your committee face?
DR: The biggest challenge we continue to face is that of defining or diagnosing the problem correctly. The problem is not flushable wipes, but wipes being flushed. It is so easy to make the assumption that since some wipes have “flushable” on the package that all wipes are marketed as “flushable.”
This is the myth that many in the wastewater sector still believe. So if everything looks like a “nail” to them, they want to hammer everything.
We have had success in our direct engagement with the wastewater association staff and GD4 participants in getting them to take a more nuanced approach to this problem. But there are 17,000 wastewater treatment plants in the U.S., and getting the operators of all of these to appreciate the nuances is rather difficult, and the associations have not taken up the challenge of providing assistance on this problem definition challenge.
Once the problem is correctly identified, the solutions become more readily apparent to everyone.
Package labeling that includes the “Do Not Flush” symbol prominently, and optimally at the point of extraction of the wipe, and an effort to increase the awareness among consumers that the toilet is not a trash can, and look for proper disposal instructions on products used in a bathroom. The symbol is highly effective because it cannot be hidden in small print, does not require anyone to read and does not require anyone to read English. So this combination will ultimately be the solution. Consumers generally want to do the right thing, as long as it is clear what that right thing is. n