Tobacco Industry Responsibility for Butts: A Model Tobacco WasteCare Act

Abstract

Cigarette butts and other postconsumer products from tobacco use are the most common waste elements picked up worldwide each year during environmental cleanups. Under the environmental principle of Extended Producer Responsibility, tobacco product manufacturers may be held responsible for collection, transport, processing and safe disposal of tobacco product waste (TPW). Legislation has been applied to other toxic and hazardous postconsumer waste products such as paints, pesticide containers and unused pharmaceuticals, to reduce, prevent and mitigate their environmental impacts. Additional product stewardship (PS) requirements may be necessary for other stakeholders and beneficiaries of tobacco product sales and use, especially suppliers, retailers and consumers, in order to ensure effective TPW reduction. This report describes how a Model Tobacco Waste Act may be adopted by national and subnational jurisdictions to address the environmental impacts of TPW. Such a law will also reduce tobacco use and its health consequences by raising attention to the environmental hazards of TPW, increasing the price of tobacco products, and reducing the number of tobacco product retailers.

Full text

Tobacco industry responsibility for butts: a Model
Tobacco Waste Act
Clifton Curtis,
1
Thomas E Novotny,
2
Kelley Lee,
3
Mike Freiberg,
4
Ian McLaughlin
5
▸Additional material is
published online only. To view
please visit the journal online
(http://dx.doi.org/10.1136/
tobaccocontrol-2015-052737).
1
Cigarette Butt Pollution
Project, Washington, USA
2
Graduate School of Public
Health, San Diego State
University, , San Diego,
California, USA
3
Faculty of Health Sciences,
Simon Fraser University,
Burnaby, British Columbia,
Canada
4
Public Health Law Center,
William Mitchell College of
Law, St. Paul, Minnesota, USA
5
ChangeLab Solutions,
Oakland, California, USA
Correspondence to
Clifton Curtis, JD, Policy
Director, Cigarette Butt
Pollution Project, 3409 Quebec
St NW, Washington, DC
20016; ccurtis@cigwaste.org
Received 4 October 2015
Accepted 9 January 2016
To cite: Curtis C,
Novotny TE, Lee K, et al.
Tob Control Published
Online First: [please include
Day Month Year]
doi:10.1136/tobaccocontrol-
2015-052737
ABSTRACT
Cigarette butts and other postconsumer products from
tobacco use are the most common waste elements
picked up worldwide each year during environmental
cleanups. Under the environmental principle of Extended
Producer Responsibility, tobacco product manufacturers
may be held responsible for collection, transport,
processing and safe disposal of tobacco product waste
(TPW). Legislation has been applied to other toxic and
hazardous postconsumer waste products such as paints,
pesticide containers and unused pharmaceuticals, to
reduce, prevent and mitigate their environmental
impacts. Additional product stewardship (PS)
requirements may be necessary for other stakeholders
and beneficiaries of tobacco product sales and use,
especially suppliers, retailers and consumers, in order to
ensure effective TPW reduction. This report describes
how a Model Tobacco Waste Act may be adopted by
national and subnational jurisdictions to address the
environmental impacts of TPW. Such a law will also
reduce tobacco use and its health consequences by
raising attention to the environmental hazards of TPW,
increasing the price of tobacco products, and reducing
the number of tobacco product retailers.
INTRODUCTION
While the environmental impacts of tobacco
product waste (TPW) are less known than the
health effects of tobacco use, the former are cause
for public concern and possible regulation through
legislative action. Cigarette butts are the most com-
monly discarded waste product in the world, and
almost 6.3 trillion cigarettes were consumed glo-
bally in 2012. Observational studies and self-
reports by smokers suggest that from one to
two-thirds of the butts from smoked cigarettes are
tossed by smokers into the surrounding environ-
ment, buried in landfills, or dumped into storm
drains.
1
These may now be considered a non-point
source of toxic, hazardous waste and thus subject
to regulatory control.
2
There are numerous environmental concerns
regarding the production and use of tobacco pro-
ducts throughout their lifecycle. Tobacco leaf
growing and processing involves heavy pesticide
and petroleum-based fertiliser use, land degrad-
ation and deforestation.
3
Additional waste concerns
arise from tobacco manufacturing, packaging, dis-
tribution and combustion. These concerns include
the production of greenhouse gases (CO
2
and
methane) released by manufacturing, transport and
smoking of tobacco products; environmental toxins
found in secondhand smoke; and newly described
toxic residuals known as thirdhand smoke that are
found in homes and other enclosed environments
where smoking has occurred.
4
ATobacco Control Supplement published in
2011 summarised multiple concerns regarding the
environmental impact of TPW, and presented
policy options to prevent, reduce and mitigate
these impacts. As a brief review of this special sup-
plement, there are 7000 chemicals contained in
cigarettes, and many of them, such as ethyl phenol,
heavy metals and nicotine, are themselves toxic. At
least 50 are known human carcinogens; others have
been found to be toxic to marine and freshwater
organisms
5
and poisonous to humans and animals.
6
Aquatic systems, such as shorelines and waterways,
may be the most vulnerable environments, as the
majority of land-based litter ultimately is deposited
into them. In addition, there are externalised costs
borne by communities and local/state governments
due to cleanup of TPW.
7
The vast majority of man-
ufactured cigarettes sold today include filters that
are usually made of cellulose acetate, a non-
biodegradable plastic. While ultraviolet rays may
eventually break filters into smaller pieces, the
source material never disappears.
1
Persisting for up
to 10 years, they are the major environmental
concern regarding TPW because they are a visible
community nuisance and they leach out toxic che-
micals. According to the ‘broken windows’theory
around public nuisances, researchers have found
that if people see one norm or rule being violated
(such as graffiti or illegal parking), they are more
likely to violate others—such as butt littering.
8
Although filtered cigarettes have been marketed
by the tobacco industry for decades with the impli-
cation that they are ‘safer’, their main effects have
been to reduce the machine-measured yields of tar
and nicotine, to discourage smokers from quitting,
and to make it easier for young people to become
addicted. However, the 2014 US Surgeon General’s
Report on the Health Consequences of Smoking
found that there is no benefit from product
designs, such as the cellulose acetate filter, in redu-
cing the individual or population risks of smoking.
9
In fact, risks for the more aggressive type of lung
cancer (adenocarcinoma) have increased since
introduction of filtered cigarettes. Regardless of
their health risk to smokers, filters pose a serious
litter and toxic waste disposal challenge. The mar-
keting of filtered cigarettes as ‘safer’as well as the
lack of recognition by smokers of the environmen-
tal impact of discarded filters represent ‘informa-
tion asymmetry’between the consumers and
producers of tobacco products.
10
Correcting this
asymmetry through regulation will likely lead to
both reduced tobacco consumption and less envir-
onmental contamination by TPW. Although a
Curtis C, et al.Tob Control 2016;0:1–5. doi:10.1136/tobaccocontrol-2015-052737 1
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proprietary effort to establish a cigarette butt recycling pro-
gramme (supported by the tobacco industry) has been made,
11
that effort and other cleanup campaigns address a miniscule
quantity of TPW. For example, the Ocean Conservancy reports
that approximately 52 million cigarettes have been picked up
globally in 27 years of cleanups.
12
With trillions dumped each
year, these downstream solutions will never be measurably
effective in reducing TPW in the environment. It is also unlikely
that there are safe options for reusing or recycling the toxic,
hazardous components of TPW. Instead, the focus of managing
postconsumer TPW should be directed towards reducing pro-
duction, changing the product design, preventing littering, con-
ducting cleanups as monitoring rather than abatement
programmes, and developing safe disposal technologies for
TPW.
On the basis of experience involving the pesticide, paint and
pharmaceutical industries, it can be argued that the tobacco
industry is responsible for numerous environmental problems
throughout the tobacco product life cycle.
4
However, the indus-
try has firmly held that ‘the responsibility of cigarette waste
belongs to the smoker’,
13
although, as described elsewhere,
industry efforts to persuade smokers to take on that responsibil-
ity have not been successful.
14
It has also been found that
smokers were defensive about discarding their tobacco butts and
thus not very receptive to antilittering efforts.
11
In fact, littering
behaviour studies have found a littering rate of 17% overall, but
for cigarette butt littering, this was 65%.
15
With a goal of shifting responsibility for TPW to the smoker,
the industry’s response to the butt waste problem has been to
encourage cleanup efforts through corporate social responsibil-
ity partnerships with environmental groups, the use of hand-
held ashtrays for smokers, and the placement of butt waste
disposal receptacles in public places. Although tobacco industry-
sponsored environmental groups claim correlation between
reduced butt waste and placement of receptacles,
16
careful
evaluation of these efforts has not been done. Moreover, these
approaches should be recognised as downstream solutions to an
upstream waste problem; they put the blame for TPW onto end
users rather than to the manufacturers of a product that gener-
ates toxic waste once used. This is a ‘blame the victim’response,
not a source-based approach to waste reduction and prevention.
The industry’s long-standing efforts to avoid responsibility have
also included attempts to develop biodegradable filters.
However, it was concluded that biodegradable filters would
likely encourage even more littering and, in fact, would not be
marketable.
17
From a tobacco control perspective, a variety of initiatives can
help prevent, reduce and mitigate the environmental impacts of
TPW. These measures include banning smoking in outdoor,
indoor and workplace areas; applying additional litter fees on
tobacco products to pay for cleanup and anti-TPW programmes;
and levying fines for littering that specifically include TPW.
While not yet operational, other potential initiatives include
banning the sale of single-use, disposable filters; litigation for
damages associated with TPW environmental impacts; product
labelling regarding TPW disposal as hazardous waste; and enact-
ment of laws that make tobacco producers and sellers respon-
sible for cleaning up and safely disposing of TPW.
1
This Special Communication explores that last policy
approach, which is based on the environmental principle of
Extended Producer Responsibility (EPR). We have developed a
Model Tobacco Waste Act which may be adapted at the national
or subnational level to implement such an approach.First we
discuss EPR and product stewardship (PS) principles that are the
foundation for such an Act. Next, we present the core provi-
sions in the Model Act and discuss relevant potential barriers to
implementation, limitations on efficacy and implications for
tobacco control outcomes. The Model Tobacco Waste Act is pre-
sented in the online supplementary file to this paper.
ENVIRONMENTAL PRINCIPLES UNDERLYING THE MODEL
TOBACCO WASTE ACT
EPR is a policy principle that promotes environmental protec-
tion by extending the responsibilities of the producer across the
product’s entire life cycle.
18
As set out by Lindhqvist,
19
EPR
addresses three core tenets:
1. Internalise the environmental cost of products into their
retail price.
2. Shift the economic burden of managing toxicity and other
environmental harm associated with postconsumer waste
from local governments and taxpayers, to producers.
3. Provide incentives to producers to incorporate environmen-
tal considerations into the design of their products.
For the effective application of those tenets, Lindhqvist includes
four specific categories of producer responsibility:
1. Liability: The responsibility for proved environmental
damages caused by the product in question; the extent of
liability is determined by legislation and may embrace differ-
ent parts of the product life cycle, including usage and final
disposal.
2. Economic: The producer covers part or all of the expenses
for the collection, recycling, or final disposal of the products
manufactured; these expenses could be paid for directly by
the producer or through a special fee collected by sellers.
3. Physical: Manufacturer is involved in the physical manage-
ment of the product and its environmental impacts through-
out its life cycle.
4. Informative: Producer must supply information on the envir-
onmental risks of the products manufactured.
Complementing EPR-based interventions, the PS principle
requires that, throughout the product lifecycle, all stakeholders
who participate in growing, designing, producing, distributing,
selling and using products share various responsibilities to
reduce the negative environmental impacts at the end of
product life.
16
Among these responsibilities, government agen-
cies, citizen groups, ‘green’business enterprises, or academic
researchers might conduct informational activities, publish
op-eds, conduct scientific research, or advocate about a given
product’s environmental hazards. Postconsumer waste may
involve hazardous materials, and therefore, sellers of these pro-
ducts must inform consumers about proper disposal. PS also
underlies voluntary cleanup efforts for postconsumer waste
products.
Over the past two to three decades there has been some con-
fusion regarding the roles of EPR and PS. As presented above,
EPR focuses on the tobacco producer as the party mainly
responsible for prevention and mitigation of TPW. PS provides
for complementary responsibilities among all stakeholders,
while holding the producer mainly responsible for the four cat-
egories of producer responsibility described above. Thus, the
two principles may work in consort to address the environmen-
tal impacts of TPW.
Regarding TPW, EPR and PS focus on product design as well
as take-back, recycling and final disposal of postconsumer waste.
TPW-related EPR and PS interventions could include:
1. Mandating corporate take-back programmes for TPW, both
as individual and collective activities of tobacco companies;
2 Curtis C, et al.Tob Control 2016;0:1–5. doi:10.1136/tobaccocontrol-2015-052737
Special communication
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2. Shifting product disposal management responsibilities away
from local communities and taxpayers to producers, distribu-
tors and consumers of tobacco products;
3. Enabling cost recovery schemes to fund EPR programme
management, implementation and compliance through
enforcement;
4. Collecting TPW from beaches, parks, campuses or neigh-
bourhoods as a way of raising awareness about tobacco use
and the impact of TPW;
5. Changing the product such that it creates less waste at the
end of life. This could include eliminating sales of the cellu-
lose acetate filter.
1
With regard to tobacco control, the application of EPR/PS
principles to TPW legislation may also create important public
health outcomes by: (1) further denormalising tobacco use and
increasing anti-industry sentiments; (2) increasing the cost of
tobacco products; (3) enacting new tobacco product regulations
to make the product less marketable; (4) strengthening existing
anti-litter and outdoor smoking prohibitions and (5) forging
new alliances with environmental advocacy, tobacco control and
regulatory groups. With these issues in mind, it is highly likely
that a substantial reduction in tobacco use will result from the
implementation of EPR/PS-based legislation on TPW. It is also
likely that tobacco product retailers might consider the difficul-
ties in participating in a take-back programme for TPW unten-
able for their continued tobacco business model. Finally,
increasing public attention to TPW and how the tobacco indus-
try is responsible for this waste may have beneficial impacts
among smokers. This is essentially an anti-industry strategy that
may serve to reinforce intentions to quit as part of social norma-
tive changes based on environmental concerns.
20
CORE PROVISIONS OF THE MODEL TOBACCO WASTE ACT
AND BARRIERS TO IMPLEMENTATION
The Product Stewardship Institute (PSI) is a US-based non-profit
organisation (http://www.productstewardship.us/) that works
with a variety of governmental, private sector and non-profit
partners to implement some of the 89 EPR/PS-based state laws
currently operative in 33 states. These laws address 12 different
waste products including: appliances with refrigerants, switches,
batteries, carpets, cell phones, electronics, florescent lighting,
mattresses, mercury thermostats, paint, pesticide containers and
pharmaceuticals. The Model Tobacco Waste Act (see online
supplementary file) is based on the well-established principles
underlying such laws in the USA and Europe. For example, the
‘Framework Principles for (PS) Policy’was developed in 2008–
2009 by five US state stewardship councils and British
Columbia.
21
In 2012, the ‘PS and EPR Definitions and
Principles’were adopted by the Product Policy Institute, the PSI
and the California Product Stewardship Council. They were
then endorsed in 2013 by a diverse mix of businesses, steward-
ship organisations, academia, governments, government coun-
cils, non-profit organisations and consulting groups.
22
The Model Tobacco Waste Act’s core provisions draw heavily
from the 2009/2013 Oregon PaintCare law, which established
the first US paint stewardship programme in 2010.
23
It requires
paint manufacturers to finance and operate a system for retriev-
ing, transporting and processing leftover paint, which, like TPW,
contains toxic substances. All programme activities are funded
by the paint industry, and the responsible entity (PaintCare
Incorporated) is managed directly by the industry. Additional
features involve accountability to government for: plan
approvals and amendments, goals and performance standards,
education and outreach programmes, annual reports, annual
stakeholder meetings, and privacy considerations. While these
and other features may be readily transferable to a TPW EPR/PS
programme, the major difference between the two products is
that leftover paint is significantly less toxic and far more amen-
able to recycling than cigarette butts. In 2012, for example,
over 70% of all leftover latex paint collected by PaintCare
Incorporated was used to make recycled-content paint.
24
Enforcement of an EPR/PS-based TPW regime may be chal-
lenging, given what is known about the smokers’lack of adher-
ence to existing litter laws. To address enforcement (section 14
‘Enforcement and Penalties’, see online supplementary file), we
reviewed section 7 of the model Cigarette Fire Safety Standard
and Firefighter Protection Act.
25
The Coalition for Fire-Safe
Cigarettes drafted this model law based on fire prevention regu-
lations developed by the New York State Office of Fire
Prevention and Control. After 3 years of deliberation and with
input from the public and affected parties, the State of
New York State passed the first ‘fire-safe cigarette’law in the
USA in 2004. Today, all US states and Canadian provinces have
adopted laws requiring that cigarettes sold in these jurisdictions
have reduced combustibility. The first five types of enforcement
approaches in that Act have been adapted for inclusion in the
Model Tobacco Waste Act, and they are applicable to tobacco
producers (broadly defined), retailers and consumers. They
provide for court actions for injunctive relief or to recover any
costs or damages suffered by the (State) because of a violation
of the Act, including enforcement costs related to the specific
violation and for attorney’s fees.
A potential barrier to passing EPR/PS-based TPW legislation
is the fear of pre-emption of subnational actions by national
governments. This fear has not been realised in practice to date.
In 2009, the US Congress enacted the Family Smoking
Prevention and Tobacco Control Act (TCA), which provided the
US Food and Drug Administration (FDA) with the authority to
regulate tobacco products for the benefit of public health.
Tobacco product standards, including new product marketing,
additives, labelling, and manufacturing standards are solely the
FDA’s responsibility. However, state and local authorities were
expressly allowed to adopt tobacco control laws that deal with
distribution, possession, sale, advertising, promotion and fire
safety. In an analysis of possible national pre-emption of local
TPW regulation, Freiberg
26
found that a state or local law
making tobacco producers responsible for cleaning up and prop-
erly disposing of TPW would not be pre-empted by FDA regula-
tory jurisdiction. Nonetheless, specific antipre-emption language
may be included in state or local laws.
Finally, with the dramatic increase in the use of e-cigarettes,
specific language may be needed to cover the chemicals, batter-
ies and detritus produced as waste by this new but largely
unregulated consumer product. The small size of disposable e-
cigarettes facilitate their becoming e-waste, and this waste has
been shown to contain lead as well as nicotine (if not fully con-
sumed).
27
Additional research is needed to identify potential
toxicants, fire risks and difficult-to-recycle materials used in
making the product.
28
FINAL COMMENTS
Given the numerous toxic chemicals found in tobacco products
and TPW and the ubiquity of TPW in the environment, a strong
case can be made that product alterations as well as effective
prevention, clean up and safe disposal efforts are badly needed
to address the TPW problem. In this context, there is much to
learn from environmental policies for other toxic waste pro-
ducts, such as obsolete pesticides and their containers, medical
Curtis C, et al.Tob Control 2016;0:1–5. doi:10.1136/tobaccocontrol-2015-052737 3
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waste, and unused paints. Disposal of such substances into
municipal landfills or incineration is generally recognised as
unsafe. Applying these models to TPW, safely managed take-
back programmes, including collection services, transportation
and closed, monitored regional TPW disposal sites are needed.
These and other related services should be paid for by tobacco
producers according to EPR and PS principles.
While EPR is put forward as a legislative approach, it asserts
that the manufacturer would be strictly liable for TPW. Several
legal theories pertaining to liability are addressed in detail in a
Tulane Environmental Law Journal article that explores several
potential litigation-related causes of actions that could be applic-
able to TPW.
29
Public nuisance may be the strongest approach,
although product liability and state hazardous waste laws could
also successfully hold cigarette manufacturers liable for TPW.
Raising awareness about the environmental consequences of
tobacco use and the responsibility of the tobacco industry for
these consequences will require media messaging and actions by
governments in order to succeed. These actions may reinforce
global approaches to environmental protection, including inter-
ventions to slow climate change, and they may mobilise new part-
nerships between tobacco control and environmental advocates.
The Model Tobacco Waste Act presented in the online
supplementary file to this report is a starting point from which
national, subnational and local governments can begin to
address the substantial and growing environmental concerns
regarding tobacco products worldwide. These programmes will
raise the cost of tobacco use, make it more difficult for retailers
to participate in the tobacco product market, denormalise and
formally recognise that tobacco use is not only deadly to
humans, but hazardous to the environment as well.
What this paper adds
This Special Communications provides a novel approach to
tobacco control through the environmental principle of Extended
Producer Responsibility. It describes a Tobacco Waste Act to
prevent, reduce and mitigate tobacco product waste. This Act
will internalise the burden of tobacco waste management to the
producer and consumer, thereby increasing costs of smoking,
further denormalising tobacco use as offensive to the
environment, and possibly reducing retail accessibility of
tobacco products.
Acknowledgements The authors wish to thank Heather Lewis of ChangeLab
Solutions, Oakland, California, for her review of drafts of the Model Tobacco Waste
Act. The authors wish to think the Truth Initiative (Washington, DC), for their kind
assistance in producing the video abstract for this article.
Contributors CC and TEN conceived of this article and the Model Tobacco Waste
Act (see online supplementary file); CC composed first draft of the submitted article
and the initial draft of Model Tobacco Waste Act, and TEN substantially edited the
initial article draft and finalised the submitted article. KL provided substantial editing
to the draft manuscript and Model Tobacco Waste Act. IMcL and MF contributed to
development of the Model Tobacco Waste Act and to editing of the final article
submission.
Funding This work was supported by the US National Cancer Institute of the US
National Institutes of Health under award No. 2R01CA091021-10A1 and by the
University of California Office of the President’s Tobacco-related Disease Research
Program under award No. 21XT-0030.
Competing interests None declared.
Provenance and peer review Not commissioned; externally peer reviewed.
Data sharing statement We would like to include our Model Legislation as a
online supplementary file.
Open Access This is an Open Access article distributed in accordance with the
Creative Commons Attribution Non Commercial (CC BY-NC 4.0) license, which
permits others to distribute, remix, adapt, build upon this work non-commercially,
and license their derivative works on different terms, provided the original work is
properly cited and the use is non-commercial. See: http://creativecommons.org/
licenses/by-nc/4.0/
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Curtis C, et al.Tob Control 2016;0:1–5. doi:10.1136/tobaccocontrol-2015-052737 5
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