This was the conclusion made by industry, local authorities and consultants during a series of debates on the draft Order betwen January 15 and 17, the Association has revealed. The views will be used in the Association's response to DEFRA's consultation on the Order.
Clarity
Composting Association technical officer Mary Messer said: “It was interesting to see the same points coming up from the three different groups of people.” One of the main concerns was over the clarity of definitions in the Order. “They have used terms indiscriminately, they have not been at all precise in their wording,” Ms Messer said.
But while some parts of the document were vague, stakeholders thought that other parts seemed too precise and inflexible. For example, there was much debate on the fact that DEFRA had specified exactly what particle size, temperature and time the composting process should take place at, rather than allowing for equivalent systems.
Most people felt that the important thing was to make sure the systems used met the risk reduction recommended by the catering waste risk assessment on which the draft amendment was based, Ms Messer said. “Some parts are prescriptive and other parts are very woolly. We don't want to stifle innovation. If things are put down too rigidly, it's very difficult to improve the process.”
In-hall windrows
Another area the Association is expected to recommend flexibility in is the definition of “enclosed” composting which was originally suggested in the risk assessment. This could apply to either in-vessel plants or in-hall windrows, the Association believes. Ms Messer explained: “We would say, leave the option open. Providing that an equivalent performance can be achieved, does it matter how we got there?”
However, there is some industry pessimism that DEFRA will not want to amend the draft Order significantly. The fact that the government is already inviting plant applications has been taken by some to indicate that there will be little change.
The Association must make its contribution to DEFRA's consultation by February 12, 2003. The Animal By-Products (Amendment) Order is due to be amended by the end of March 2003.
Subscribe for free