SEPA Recommends New Controls for Spreading Organic Wastes on Land
Issued on 3 November 1998 - Ref 39/98
The Scottish Environment Protection Agency (SEPA) has put forward a comprehensive set of recommendations for controlling the spreading of organic wastes, such as sewage sludge and blood & gut contents from abattoirs, on agricultural land.
The overall conclusion of a report produced by SEPA for The Scottish Office is that the current regulation and management of organic waste spread on land is inadequate and inconsistent, leading to practices which pose a risk to the environment and, potentially, to public, animal and plant health.
The Report’s recommendations include:
The report also recommends prohibition of :
SEPA’s Director of Environmental Strategy, Tricia Henton, who headed the Project for SEPA, said:
"The spreading of organic wastes, especially untreated sewage sludge and abattoir wastes, has understandably caused public concern. I was pleased to be asked to take forward this important project, and I believe our recommendations provide an achievable framework for improvements to the current system. If adopted, they will ensure that the maximum environmental benefits can be achieved with minimal risk to human and animal health."
The Scottish Office is now considering the Report and how its recommendations can be taken forward.
A copy of the Executive Summary is attached.
ENDS
NOTES
In light of public concern about the spreading of organic wastes on land, The Scottish Office asked SEPA to undertake a strategic review of the situation and to recommend a way forward.
The project, which was overseen by a small group of staff from SEPA, The Scottish Office and the Convention of Scottish Local Authorities, began in May 1998.
The Project was asked to consider:
The Project Report "Strategic Review of Organic Waste Spread on Land " was submitted to The Scottish Office at the end of October 1998.
Copies of the Report are available on the Scottish Office Website www.scotland.gov.uk.
SEPA is happy to answer questions about the project and its recommendations. Questions about the next steps should be addressed to The Scottish Office Information Directorate 0131 244 8039.
Strategic Review of Organic Waste Spread on Land
Executive Summary
Introduction
1. The Scottish Office has requested SEPA to undertake a strategic review of organic waste spread on land. The review covers sewage sludge, waste disposal activities exempt from waste management licensing ('exempt' wastes), agricultural wastes, fallen stock and composted municipal waste.
Background
2. Current estimates of the tonnage of waste applied to land in Scotland are:
3. If organic wastes are applied correctly to land they can have positive beneficial fertilising effects. Other beneficial environmental effects include reduced resource demand, soil conditioning and, indirectly, habitat conservation. There are potential cost savings to farmers due to reduced inorganic fertiliser requirements when organic wastes are used.
4. Sewage sludge, which comprises 1% of the waste spread on land, is generally applied under controlled and regulated conditions. There is considerable public pressure to increase the level of treatment of sewage sludge, in particular to phase out the practice of spreading untreated sewage sludge on land. The UK Government has recently announced its intention to phase our the latter practice. A good body of scientific literature exists in respect of potentially toxic elements (PTEs) and many pathogens in sewage sludge.
5. Wastes applied to land as an exempt activity include blood and gut content from abattoirs, distillery wastes, paper waste and septic tank sludges. The current system for recording volumes of these wastes is not sufficiently accurate to understand the extent of this outlet for such wastes or to predict future trends. The current pre-notification period to SEPA is not useful in managing the activity.
6. Most exempt wastes are not pre-treated or stored at the point of origin, leading to odour problems and typically are not stored at the point of origin resulting in the possibility that wastes are not being spread at the time most beneficial to the crop or the land. Neither 'agricultural benefit' nor 'ecological improvement', the key justifications for the activity, are defined in regulations.
7. There is a paucity of data relating to the fate and impacts of nutrients, PTEs and pathogens in exempt wastes. Little is known of the effects of organic chemicals on soil and of the effects wastes have on soil processes. Pathogen related risks associated with exempt wastes and the agricultural wastes are not quantified or fully understood.
8. Owners/occupiers of the land on which waste is spread are not always fully aware of the nature and content of what is being spread there. Multiple wastes can be applied in addition to inorganic fertiliser without any need for the owner/occupier to take account of synergistic effects, total nutrient content or total heavy metal loadings.
9. The potential for point source or diffuse pollution of watercourses from waste spread on land is high if incorrectly spread or over-applied or if inorganic fertiliser is not reduced in proportion to the organic wastes applied. There is no necessity for waste contractors to employ operators with a certificate of competency in the activity, which may result in bad practice and increased potential for water pollution.
10. Fallen stock does not yet pose a problem but difficulties may be expected in future years due to cumulative effects of increased disposal.
11. There is much useful guidance available such as the Prevention of Environmental Pollution from Agricultural Activity (PEPFAA) Code of Practice which includes guidance and refers to statutory requirements, and the Code of Practice for the Agricultural Use of Sewage Sludge which includes all the statutory requirements of the Sludge Regulations.
However, the Codes themselves are not statutory which causes confusion. The Codes are not necessarily known or followed extensively within the agricultural community.
Conclusions
12. There is a lack of public confidence in the practice of spreading organic waste on land which threatens an activity which can have environmental benefits.
13. The current approach to the regulation and management of organic waste spread on land is inadequate and inconsistent, leading to practices which pose a risk to the environment and pose potential public, animal and plant health risks.
Principal recommendations
14. A consistent legislative framework for all organic wastes spread on land should be developed, incorporating the relevant Codes of Practice as necessary.
15. Regulations should cover mixed waste streams and set minimum standards for safe acceptance loadings for different wastes on different soil types. Minimum standards of treatment for wastes spread on land should be stipulated along with minimum storage at the producer's site.
16. The concept of land management plans should be adopted which would encompass the beneficial and detrimental aspects of all wastes applied to farmland as well as incorporating inorganic fertiliser inputs.
17. A competency scheme for contractors should be introduced, similar to the WAMITAB qualification for waste management licence operators.
18. Blood and gut contents and septic tank sludges should be prohibited from being spread on land.
19. Injecting waste in land with field drains, spreading outwith daylight hours and spreading in designated heritage sites should be prohibited.
20. A proposed mechanism for regulating the spreading of organic wastes onto land is set out in the report, with the objective of ensuring that the responsibility for specific actions rests with the appropriate person. The scheme would be amenable to an accompanying charging scheme.
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