Publication - Impact assessment

Environmental Protection (Single-use Plastic Products) (Scotland) Regulations 2021: equality impact assessment - final

Published: 11 Nov 2021

We published a partial equality impact assessment during the public consultation on the introduction of market restrictions on problematic single-use items in Scotland, which took place between 12/10/202 and 04/01/2021. This EQIA expands that work with additional research, data, and evidence.

Environmental Protection (Single-use Plastic Products) (Scotland) Regulations 2021: equality impact assessment - final
Stage 2: Data and evidence gathering, involvement and consultation

Stage 2: Data and evidence gathering, involvement and consultation

This section details the data and evidence collected throughout the EQIA process. Published evidence was gathered from existing large national and UK surveys for the partial EQIA, and has now been supplemented by evidence from more targeted, EQIA-specific engagement work. Many of the impacts identified relate to the restriction of straws, which are detailed in Table 1. Impacts related to the other items are included in Table 2.

Table 1. Evidence for the impact of the restriction of plastic straws.

Impact

Characteristic

Partial EQIA Evidence

Source

Final EQIA Additional evidence

Source

Young children who are also disabled may be particularly impacted by the removal of plastic straws.

Age/Disability

10% of children had a long-term limiting mental or physical health condition or disability in 2017.

Scottish Household Survey, 2017[8]

No specific evidence was identified in relation to the very young.


Older people are more likely to suffer from medical conditions and ill health and therefore may be more likely to be impacted by market restrictions on plastic straws.

Age/Disability

People aged 75 and over are projected to be the fastest growing age group in Scotland. The number of people aged 75 and over is projected to increase by 27% over the next ten years and by 79% over the next 25 years.

Projected Population of Scotland (2016-based)[9]

The engagement identified that it was challenging to separate disability and age-related impacts as older age is a contributing factor for medical conditions and ill health, and these characteristics may have a cumulative impact.

One-to-one interviews with, and survey of, users of plastic straws

Loss of independence

Disability

In 2011, the proportion of people in Scotland with a long-term activity-limiting health problem or disability was 20% (1,040,000 people), the same proportion as reported in 2001.

According to a number of consultation responses, the use of plastic straws allows many disabled people to maintain a level of independence which could be compromised by the implementation of market restrictions, with direct influence on quality of life.

Scottish Household Survey, 2017;[8] 2011 Census[10]

Department for Rural Affairs (2019), Consultation on proposals to ban the distribution and/or sale of plastic straws, plastic stemmed cotton buds and plastic drink stirrers in England[11]

The engagement indicated that reduced availability of plastic straws from hospitality venues has already impacted on the accessibility and inclusivity of these environments for some disabled people. In many cases, available alternatives do not offer the full functionality delivered by plastic straws and people therefore find it necessary to carry straws with them in order to drink and eat at such venues. This places an additional burden on individuals, particularly where accessing items from bags may be challenging or impossible.

A current trend of increasing costs associated with the purchase of plastic straws and the higher cost of reusable alternatives were also flagged and may have a disproportionate impact as a higher proportion of households with disabled occupants live in poverty (24%, compared with 17% in households without disabled occupants). Further research into this was undertaken as part of the Fairer Scotland Assessment.

One-to-one interviews with, and survey of, users of plastic straws

Inclusion Scotland Social model of disability summary[12]

Poverty and income inequality in Scotland: 2015-2018[13]

Stigmatisation and medicalisation (related to the exemption)

Disability

An exemption for medical-enabling use and other specialist uses could present an unfair burden for disabled users. Concerns were expressed about "gatekeeping", i.e. having to prove a disability. Concerns were raised about indignity related to having to use alternatives to plastic straws (e.g. 'sippy cups').

Department for Rural Affairs (2019), Consultation on proposals to ban the distribution and/or sale of plastic straws, plastic stemmed cotton buds and plastic drink stirrers in England[11]

Individuals consulted in the engagement identified concerns in relation to any requirement to 'prove' disability in order to access straws. The requirement to produce a badge or card could lead to embarrassment, stigmatisation, and loss of dignity. It would also put further pressure on the individual to ensure they had the required proof with them when needed.

Making straws available on prescription or in pharmacies was considered to unnecessarily medicalise their use, which could contribute to stigmatisation as well as being perceived as adding pressure to the healthcare system.

One-to-one interviews with, and survey of, users of plastic straws

Medical Requirement Loss of functionality

Disability

Muscular Dystrophy UK presented the results of a survey they had conducted:

1) Of the disabled people they surveyed, 43% had a requirement to use straws all the time, and 34% some of the time.

2) Nearly 77% of those surveyed were against the straw ban. Only 23% were in favour of the straw ban.

Straws are essential for a wide range of temporary (following surgery or dental work), and longer-term and impairments, including chronic conditions. Responses to the Defra consultation indicated that people with the following conditions could be impacted, although this list should not be considered exhaustive: neurological diseases, people who experience tremors or poor dexterity, dementia, gastro-intestinal issues, cerebral palsy, stroke, dysphagia, spinal injuries, paralysis, and patients recovering from surgery, chemotherapy or radiotherapy.

NHS Scotland reports that it uses 3.8 million drinking straws each year.

Department for Rural Affairs (2019), Consultation on proposals to ban the distribution and/or sale of plastic straws, plastic stemmed cotton buds and plastic drink stirrers in England[11]

People impacted by a diverse range of issues may require plastic straws in order to drink and eat.

Straws made of other materials do not currently deliver the full functionality of plastic straws.[14] The following functions/characteristics were noted as important and currently only delivered by plastic straws: flexibility, durability, hygienic, suitable for hot liquids and thicker liquids, can cut to length, limited potential to damage the mouth or cause choking, doesn't impair taste or stick to the lips, not expensive.

A number of those consulted were using a combination of reusable options but required plastic straws particularly for the flexible neck and to drink hot drinks safely.

One-to-one interviews with, and survey of, users of plastic straws

Table 2. Evidence for the impact of the restriction of other targeted single-use plastic items.

Impact

Characteristic

Partial EQIA Evidence

Source

Final EQIA Additional evidence

Source

Reduced littering (all items including straws) may have a disproportionately positive impact on younger people, as litter is a social problem that particularly affects young people's perceptions of their own neighbourhood.

Age

At least 250 million easily-visible litter items are cleared by local authorities in Scotland each year.

36% of people aged between 16 and 24 report neighbourhood littering as very common or fairly common, compared to a mean of 29% for the other five age categories (25-34, 35-44, 45-59, 60-74, 75 and over).

Scotland's Litter Problem, 2013[15]

Scottish Household Survey, 2017[8]

Discussion in the workshop suggested that participants did feel younger people may benefit more from a reduction in littering and the perception that positive action is being taken to reduce environmental impacts. High media exposure, and in particular the 'Blue Planet' and 'Greta' effects were referenced, as well as the view that younger people feel they have more to lose, and therefore care strongly about the planet and its future.

Workshop with members of the Scottish Youth Parliament

Reduced enjoyment by children of balloon sticks at parties and events.

Age

A respondent suggested that 'A ban would reduce children's pleasure since the balloon is not presented vertically as if it were floating'. However the significance of this way of enjoying a balloon opposed to activities with a stickless balloon was not presented

Resource Futures (2018), Preliminary assessment of the impacts of a potential ban on plastic cutlery, plates plastic balloon sticks[16]

No further evidence to support this impact. Discussion at the Scottish Youth Parliament session did not flag concerns (although participants were of an older cohort).

Workshop with members of the Scottish Youth Parliament

No evidence of disproportionate impacts was identified in the partial EQIA, consultation, or EQIA engagement for the other protected characteristics (gender reassignment, pregnancy and maternity, race, religion, sex, sexual orientation, and marriage and civil partnership).


Contact

Email: supd@gov.scot