SEPA pushes for tighter controls on land spreading of wastes

New controls on the spreading of organic waste on farmland, including a ban on spreading blood and gut contents, have been recommended in a report by the Scottish Environment Protection Agency (SEPA). 1 The proposed regime would cover all organic wastes, including agricultural and industrial waste and sewage sludge, and would require landowners to prepare management plans.

A series of odour and water pollution incidents caused by land spreading operations has focused attention on the issue in recent years. The latest Scottish prosecution for such pollution came in November (see p 49 ).

Interest in land spreading as an alternative outlet for industrial waste has been stimulated by the landfill tax, introduced in 1996. Since 1994, the practice has also enjoyed an exemption from waste management licensing, so that contractors need only pre-notify regulators of their plans. Up to 250 tonnes of waste per hectare may be spread each year, as long as this results in "benefit to agriculture or ecological improvement".

The Scottish Office asked SEPA to undertake a strategic review of waste spreading last year. Some of its proposals echo those in a recent report for the Environment Agency (ENDS Report 281, pp 27-29 ). But SEPA has also developed some more specific regulatory proposals which the Scottish Office is now considering how to take forward. As with the proposals being developed south of the border, amendments to secondary legislation will be required.

As well as industrial waste, SEPA's report addresses other organic wastes, including agricultural waste, sewage sludge and compost. It estimates that 367,000 wet tonnes of industrial waste and 200,000 tonnes of sewage sludge are spread in Scotland each year. These figures are dwarfed by the estimated 15 million tonnes of agricultural waste applied to land.

Data on land spreading are unreliable because there is no record-keeping requirement except for sewage sludge. According to SEPA, important industrial waste streams spread on Scottish land include 76,000 tonnes per year from the food and drink industries - mainly distilleries - and 49,000 tonnes from the paper industry, as well as 26,000 tonnes of abattoir waste.

SEPA notes that spreading organic wastes can bring benefits such as nutrient addition and soil conditioning. But some waste producers regard the practice as a form of disposal rather than recycling - and in turn farmers have little understanding of the benefits which it can bring and rarely reduce applications of conventional fertiliser.

"Nutrient addition from what is in effect a free source is generally discounted," the report says. And, in the case of industrial organic wastes, farmers are generally unable to optimise application rates to meet crop requirements because there is little evidence from field trials.

"It is SEPA's experience that the application rate of [industrial organic] wastes is seldom if ever matched to the nutrient needs of the growing crop," the report says. "As a result it is suspected that nutrient leaching occurs widely."

Other environmental impacts from land spreading of industrial wastes include oxygen depletion in watercourses, and the presence of contaminants such as fungicides and bactericides used in many industries, including the paper and textiles sectors.

On odour pollution, SEPA notes that pre-treatment of wastes can reduce odour problems in some cases, as can changes to storage and application techniques.

SEPA's paper also examines sources of pathogen contamination from organic wastes - in particular slurry, manure, sewage sludge and abattoir wastes - and possible control measures. In the case of sewage sludge, the Government has recently agreed that spreading of untreated sludge should stop by 2002.

  • Inconsistencies between regimes: SEPA would like to see a "consistent legislative framework" introduced to cover land spreading of all organic wastes. The framework would incorporate relevant codes of practice with statutory backing, and would for the first time offer clear definitions of "agricultural benefit or ecological improvement".

    Presumably, SEPA's proposed framework would cover the spreading of agricultural wastes - but it avoids spelling this out in the paper.

    In a parallel exercise, the Government is planning to consult on proposals to bring some agricultural waste under normal waste controls, in order to fulfil a long overdue EC obligation - but this has now been delayed until March 1999. It is possible, therefore, that a new regime on land spreading might include controls on agricultural wastes.

    SEPA proposes that the current pre-notification regime for land spreading of industrial wastes should be abandoned, not least because some parties wrongly feel that by pre-notifying SEPA of their plans they have gained its approval. "Rather than pre-notification, it is suggested that greater benefit would be offered by the keeping of detailed records by the waste producers/contractors and landowners and auditing of these records by SEPA," it says.

  • New framework: Essentially, SEPA's proposed framework builds on the existing regime for sewage sludge, in which water undertakers are required to maintain registers which SEPA can then audit. They must maintain detailed records of applications to farmland and test sludge and soils.

    Under SEPA's proposed regime - funded through a new charging scheme - any waste producer wishing to recycle organic waste to land would face a series of conditions:

  • Producers would have to provide adequate storage facilities, the lack of which currently places contractors under pressure to spread material at inappropriate stages in crop cycles. They would also provide analytical equipment and waste pre-treatment facilities as necessary.

  • Producers would have to spread waste on land themselves, or use an "authorised" contractor, and keep detailed records for subsequent auditing.

  • The contractor would have to demonstrate that the waste was deposited on land that has a "land management plan".

  • Land management plans: These would be compulsory. Landowners or occupiers would be responsible for preparing the plans, which would encompass the beneficial and detrimental aspects of all wastes applied to the land as well as take account of inorganic fertiliser inputs.

  • Minimum standards and prohibitions: SEPA proposes an outright ban on land spreading of septic tank sludge and blood and gut contents. Injecting wastes in land with field drains should also be prohibited, as should spreading outside daylight hours or in designated heritage sites.

    Minimum standards of pre-treatment would be stipulated - presumably in statutory guidance - though this would not apply to most agricultural wastes.

    Controls on land use following the application of farm wastes and industrial wastes similar to those which currently apply after spreading sewage sludge would be introduced. The aim would be to minimise risks from pathogens.

    SEPA also recommends that waste producers should have access to "properly qualified advice" to take account of nutrient requirements and contaminants in the waste. And it says that contractors should be subject to a competency scheme similar to the statutory certificates of technical competence required in other waste management fields.

  • Fallen stock: The report also examines the problem of fallen stock, increasing numbers of which have been disposed of by burial on farmland since the rendering industry lost its markets for processed animal by-products in 1996. It estimates that between one-third and a half of Scottish cattle, and 95% of sheep, were disposed of on farmland rather than by knackeries or renderers last year.

    "Difficulties might be expected in future years due to the cumulative effects of increased disposal," SEPA says, noting that the UK is unique in the EC in allowing widespread on-farm burials. The Government is currently consulting on proposed changes to animal by-products legislation which would further restrict burial of fallen stock (see p 37 ).

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