The stench from cooking animal parts, some of which have been sitting in slaughterhouse skips for a few days, makes rendering an unpopular neighbour. Complaints to local authority environmental health departments generally peak in the summer when the smell from animal wastes is at its worst.
Some renderers have recently invested heavily to reduce their environmental impacts. But others are continuing to cause problems. In a single day last summer, more than 100 people complained to Tameside council in Greater Manchester about Smith Brothers' controversial rendering plant in Hyde. And the complaints keep pouring in, despite a record £216,000 fine - which the company is appealing against - imposed for a series of offences last year (ENDS Report 264, pp 45-46 ).
Renderers' change of role
Until recently, the rendering industry could claim that it provided an essential service to the meat industry by paying for and removing animal waste and converting it into animal feed and other useful products. But recent events have transformed it into a waste disposal operation - and one which, according to the Ministry of Agriculture, Fisheries and Food (MAFF), will soon have to compete with landfill.
The trigger was the Government's announcement last March that the "most likely explanation" for 12 cases of a new variant of Creutzfeldt Jakob disease was consumption of meat from cattle with bovine spongiform encephalopathy (BSE).
Mammalian meat and bonemeal (MBM) - one of the renderers' key products - was immediately banned from use in feed for all farmed animals, including poultry, horses and fish. Earlier measures aimed at eradicating BSE had only banned MBM in feed for cattle and other ruminants. The Government's scientific advisers, the Spongiform Encephalopathy Advisory Committee (SEAC), blamed the use of MBM in cattle feeds for the original BSE outbreak.
A failure by some renderers and abattoirs to separate specified bovine materials (SBM) from other animal wastes in their processes is believed to have prolonged the BSE epidemic. SBM comprises animal parts - such as the spinal cord and brain - which can contain the BSE infective agent. Successive statutory Orders have broadened the SBM definition, and specified "bovine" materials now include the complete heads of cattle, sheep and goats.
A small proportion of SBM is incinerated in cremators, but most is rendered at a dozen MAFF-authorised plants. The MBM so produced can be sent to landfill, but emergency measures currently in place mean that it is being stockpiled along with the vast tonnages of MBM from the Government's Over Thirty Months Scheme (OTMS) cattle cull (see box overleaf).
In addition, up to 300,000 tonnes of MBM produced annually from "clean" offal - including waste from pigs and sheep - is being sent to landfill because it no longer has a market. MBM is now used only in pet food and domestic fertilisers. According to a report prepared for MAFF by Coopers & Lybrand, these outlets amount to 7,000 tonnes per year - just 2% of the pre-crisis market.
The renderers' other product - the fatty material, tallow - is mostly being stockpiled. The EC's export ban on British beef and beef products has cut sales of UK tallow from 210,000 tonnes in 1995 to 62,000 today. Major consumers, including the cosmetics, pharmaceuticals and soap industries, have switched to other materials or imported tallow. The principal remaining outlets are chemical companies which use tallow to make plasticisers, surfactants, coatings and humescants for cigarette filters.
Some retailers have put pressure on suppliers to switch away from UK tallow. And while the anticipated lifting of the tallow export ban will ease the renderers' predicament, Coopers does not expect markets to recover rapidly.
"We hope that ultimately the MBM market for feed will resume," says Brian Rogers of the UK Renderers Association (UKRA). "But our short-term future is very much as a waste disposal industry."
The industry has been the subject of several inquiries by the Monopolies and Mergers Commission. A 1993 report concluded that there is "generally little competition among renderers". One company, Prosper de Mulder, had a 64% market share in rendering red meat waste in England and Wales and an 80% share of poultry waste. In Scotland, William Forrest & Son was found to have a 71% market share in red meat waste. Both firms subsequently gave undertakings to publish their prices and charges on a weekly basis.
However, the BSE crisis has put competition between renderers on hold. First, MAFF stepped in to subsidise the industry for loss of MBM and tallow sales, so as to prevent a "disorderly collapse" of the slaughtering trade which would otherwise have been obliged to pay for treatment of its waste. Second, the Government agreed a plan with the UKRA in which 11 renderers were paid fixed prices per carcase for animals slaughtered under the OTMS cull. Renderers were paid roughly £55 million in the first year of the OTMS.
MAFF's subsidy to rendering companies, which comes on top of the OTMS payments, totalled £100 million in 1996/97 - a sum roughly equivalent to the industry's entire 1995 turnover. In May, MAFF was paying renderers £248 per tonne of tallow and £224 per tonne of MBM. But the subsidy is to be phased out from this summer and eliminated next March.
Competition from landfill
That decision was announced in a little-noticed consultation paper issued by MAFF in February. MAFF's proposals, which are predicated on stoking up competition between renderers and landfill businesses for the disposal of animal wastes, have potentially significant environmental consequences.
Once the renderers' subsidy is removed, the paper said, "it could prove cheaper for abattoirs and other businesses to consign most animal by-products to an appropriately licensed landfill site than to pay the increased charges which a rendering company would have to set to recover his costs."
It continued: "However, given reasonable recovery of the market for UK-produced tallow, and competitive pressure on renderers' costs, there is reason to believe that rendering should still be able to compete successfully with other disposal routes for many if not all animal by-products."
MAFF, it might be suggested, is both being unduly optimistic about the prospect of a recovery in tallow sales and understating the capacity of the landfill industry - much bigger than the rendering sector, and always creative in cutting prices - to undercut the renderers.
Some animal waste is already going to landfill. The main instrument governing the disposal of offal and other animal wastes is the Animal By-products Order 1992 which, implementing the EC animal waste Directive, stipulates that material must be disposed of by rendering, incineration or burial beyond the reach of carnivorous animals. Landfills can therefore take animal wastes unless barred by their licences.
Before the winter, when the Government was clearing the backlog of animals under the OTMS cattle cull, a shortage of rendering capacity led the industry to consign a significant tonnage of "clean" animal waste - non-OTMS material - directly to landfill. Under a contract with Shanks & McEwan, animal waste was landfilled at four of the company's sites plus additional landfills sub-contracted around the country.
Animal waste is landfilled by tipping into a trench dug into the site which is immediately covered. But if the rendering industry was to collapse under competitive pressure from the waste sector, landfilling huge tonnages of raw animal waste would pose considerable management and regulatory challenges to avoid nuisances such as vermin and odour.
If too much animal waste was tipped in one area of a landfill there could be problems with site stability. And some landfill technologists argue that the leachate generated by protein-containing wastes - which include MBM as well as untreated animal wastes - may also cause difficulties. The nitrogen content of such materials means that leachates contain high levels of ammonia which is expensive to remove.
The magnitude of the potential animal waste problem should not be underestimated. Before the BSE crisis, renderers processed 1.2 million tonnes per year of waste from abbatoirs, meat cutting plants, butchers and knackeries - a tonnage equivalent to the household waste produced by a city of 2.5 million, but far more difficult to manage.
From rendering to incineration
Landfill is not the only alternative to rendering. Another is incineration. The incinerators springing up across Britain in response to the OTMS cull will, in the long term, offer further competition in animal waste disposal once the cull is concluded and the incinerator owners look for new markets.
Determined to stay in business, the renderers have been looking at ways of making their processes more efficient. Attractive Intervention Board contracts to dispose of OTMS carcases are offering a spur to innovation. The Board has invited bids for "integrated tenders" offering a complete animal disposal service. Some of the bids, which were submitted in April, consist of slaughtering followed by direct carcase incineration. Others involve rendering followed by incineration of the resulting MBM and tallow.
Because rendering involves driving off the moisture from animal waste, heat from a sizeable combustion plant is needed. Renderers have long recognised that tallow is an excellent fuel - some are already burning stockpiled tallow in place of fuel oil. But they are now turning their attention to MBM.
Under EC law, all OTMS material must be "incinerated or rendered and destroyed" - a definition presumed not to include landfill. The Board has yet to announce its chosen contractors, but several renderers are hoping to burn the MBM and tallow they produce from OTMS animals.
One proposed "fuel" would be made by compressing MBM, with some tallow left in it, to form a cake. This would be burned at a rate of 4-6 tonnes per hour, generating 20-30MW of heat for use in the rendering plant.
Burning MBM is difficult to control, however, because of particulate emissions. As demonstrated by recent planning inquiries into carcase incinerators, there is also public concern about the ability of combustion processes to destroy the BSE infective agent. Renderers may therefore find it difficult to win over their neighbours and local authorities.
"Because of the public sensitivity, we are looking at a system to deplete [sic] particulates and acid gases," says Chris Ashworth of the Licensed Animal Slaughterers and Salvage Association. "Emission standards would be based on best available technology and they would be consistent with an incinerator burning clinical waste."
Mr Ashworth believes that burning MBM at rendering facilities may only require a revision of their existing air pollution control authorisations as "Part B" process under the Environmental Protection Act 1990. Alternatively, it may require a separate Part B authorisation as a combustion plant.
Deciding whether burning MBM in rendering plants is an incineration or combustion process will pose considerable difficulties for pollution regulators. Some are concerned that MBM combustion could be considered simply as an extension of the rendering process. By contrast, if it is classed as incineration, more rigorous emission standards would apply under integrated pollution control. In part the distinction depends on whether MBM, which until recently was a useful product, should now be defined as a waste.
Renderers hope to be burning MBM within a year and, unlike firms bidding to provide OTMS carcase incineration services, they may not require planning consent. They will argue that, since MBM simply displaces existing fuels, the development does not constitute a change of use in planning terms.
The loss of feed markets means that the industry is also keen to burn the MBM it produces from clean animal wastes, thus avoiding both landfill and fuel oil costs. If it gets the go-ahead under the OTMS scheme, MBM combustion is therefore likely to become a permanent feature of the rendering industry.
However, the sector's difficulties in meeting air pollution control conditions to date pose serious questions about its ability to operate combustion or incineration processes reliably. While some renderers have invested successfully to reduce their odour impact, others are still causing problems.
Creating a stink
A tale of apparently successful odour abatement comes from Kent, where environmental health officers once described the impact of the Thruxted Mill plant, operated by Canterbury Mills, as "horrendous". Things have now improved: "Most locals would grudgingly admit the performance is 10,000 times better," one regulator commented. "They've put their money where their mouths were."
However, at Dundas Brothers' rendering plant in Aberdeen, "alleged breaches of authorisation" are now being investigated by the Scottish Environment Protection Agency. Last September, following a summer of vocal complaints from the public, SEPA refused Dundas's application to double the plant's throughput. The company has appealed to the Scottish Office, but a spokesman for SEPA said that it did not want to authorise an increase in capacity until it is satisfied that the plant is operating to its existing authorisation.
Dundas installed a continuous cooking process last year, which should permit better control and reduce emissions. "Recently there has been a reduction in the number of complaints," SEPA acknowledged.
In February, Staffordshire Moorlands council also turned down an application by a rendering company to increase its capacity. Gilberts Animal By-Products of Cheddleton, Staffordshire, had applied to raise throughput from 2,500 to 5,100 tonnes per week.
"There was evidence that the increase in throughput would have adverse environmental effects," a council spokesman commented. "And it wasn't clear they were using the best available techniques not entailing excessive cost." The council receives a remarkable 1,000 complaints about the plant per year.
Questions over enforcement
As well as pollution control regulation, rendering plants are regulated by MAFF's State Veterinary Service (SVS). All renderers must gain SVS authorisation under the Animal By-Products Order 1992, and those wishing to process SBM have to gain additional authorisation under the Specified Bovine Material Orders.
Since last July, MAFF has published a monthly bulletin on BSE enforcement, which records just 13 "unsatisfactory" visits to rendering plants during 1996. During four of these, veterinary officers witnessed inadequate separation of SBM from other animal by-products. The other nine were simply recorded as "rendering plant not operating satisfactorily".
MAFF has proved extremely reluctant to provide further information on its regulatory activities and follow-up action. When Alan Watson of Public Interest Consultants, an environmental group, tried to obtain information on the 13 "unsatisfactory" visits, he was told he would be charged £6,488 for MAFF's time in gathering the information. MAFF was eventually persuaded to disclose the identity of the plants in question free of charge.
MAFF revealed that all of the unsatisfactory visits involved just four plants: Dundas Brothers in Aberdeen; Gilberts in Staffordshire; JG Pears in Newark; and Granox in Widnes. Since each of these facilities has dedicated processing lines for OTMS carcases, they are currently funded directly by the Intervention Board.
Clearly, it has been open to the Intervention Board to minimise the environmental consequences of the programme by imposing suitable conditions on these firms in its OTMS contracts. But the Board says that it has "laid no additional requirements on renderers beyond those already in place for their businesses." Despite evidence of unsatisfactory findings by the SVS and high levels of local complaint about odour nuisances at some plants, it told ENDS that "all rendering plants were...complying with the relevant legislation" - a remarkable assertion given that their authorisations generally require emissions to be free of offensive odour beyond the process boundary.
At the height of the OTMS cull programme last year, one local authority warned the Government that Intervention Board pressure for renderers to process as much material as possible would lead to environmental problems. "Any increase in throughput for whatever reason must inevitably result in greater emissions to air," the authority said. It called on the Government to direct funds to ensure the "most effective pollution controls".
In response, the then junior Agriculture Minister, Angela Browning, effectively washed her hands of the whole issue. She said it was for the local authority to decide what pollution control requirements to impose on rendering firms, "subject to appeal to the Secretary of State."
Given the recent history of air pollution control in the industry, Mrs Browning's reply will grate with local regulators. Five renderers have appealed against local authorities' refusal to grant initial authorisations under the Environmental Protection Act 1990 - and all of their appeals were upheld by the Environment Secretary (ENDS Report 263, pp 24-25 ).
By March 1998, up to £250 million of public money will have been pumped into the rendering industry - through direct subsidy and work relating to the OTMS cull - since the start of the BSE crisis. Renderers are likely to win further funds in the next round of OTMS contracts. "The additional tonnage from the OTMS has certainly assisted in maintaining margins," says Brian Rogers of UKRA. He added that the sector is "very ready to invest to achieve the best available standards".
Ministers now have a dual role - both in setting renderers' regulatory standards and as their principal customer. The decision inherited from the previous Government to introduce competition from the landfill industry carries the clear risk that the environmental problems caused by the BSE crisis will simply be spread around, with renderers having less cash for emission control and landfills giving rise to nuisances of their own.