In a response to the Department for the Environment, Food and Rural Affairs' consultation on the proposed Amendment to the Animal By-Products Order 1999, Cory warned that the proposals could hinder the UK's ability to meet Landfill Directive targets.
Delay
The UK's ability to meet the requirements of the Landfill Directive could be hindered by the high capital and operational costs proposed for catering waste, Cory's report said. “Local authorities may delay the introduction of collection schemes and facilities for catering waste until increasing landfill tax makes processing of catering waste a viable proposition, or until the requirement to meet recycling and composting targets makes processing of catering waste a necessity,” the response explained.
And because the EU had not yet confirmed DEFRA's proposals would comply with the EU Animal By-Products Regulations, investment in catering waste composting could be further held up, it added.
Pointing out that the BSI PAS 100 standard for compost, launched in November 2002, was intended to boost confidence in certified compost products, Cory warned: “Compost product from the composting of catering waste is likely to achieve even less acceptability in the market than product resulting from composting of garden waste due to its perceived contamination.” This meant local authorities could not rely on an income stream from catering waste compost.
In addition, the fact that animals would be banned from grazing land for two months after catering waste compost had been spread on it would add to the perceived risk of using the material, the report said.
Clarity
Cory also echoed calls by the Composting Association to clarify the requirements contained in the Order (see letsrecycle.com story). It should be careful not to encourage local authorities to mix collections of garden and catering waste from households, the company said. “Defining material from garden waste kerbside collections as catering waste would have significant impact on a number of existing and proposed garden waste collection schemes. Cory would like DEFRA to clarify that source separated garden waste will not be classed as catering waste.”
With regards to a requirement in the draft Order for each batch of catering waste compost to be sampled and tested for pathogens, the report called on DEFRA to clarify what size of batch was required, noting that testing each lorry load would create significant time and monetary costs. It also asked whether a housed windrow would qualify as a “closed composting reactor” for the purposes of the Order.
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