Animal By-Products presentation

1. Animal By-Products presentation Conor McGovern Celtic Waste/greenstar 20 March 2003

2. Presentation Proposed Regulation governingHealth Rules concerning Animal By-products not intended for Human Consumption

3. About the Legislation Reaction to disease outbreaks - from animal health POV Complicated – 38 Articles, 11 annexes and 95 pages Adopted 3 October 2002, to be transposed by 1 May 2003 Derogations may delay implementation

4. Signficant parts of Regulation • Articles 4-6 define waste categories and disposal options • Article 10 defines approval of composting plants • Article 26 defines official controls and requires HACCP • Annex V specifies general requiremants for approval of plants • Annex VI specifies requirements for approval of composting plants

5. Category 1 • TSE infected Animals confirmed /suspected • Specified Risk Material -SRM (including whole ruminants) • animal material collected when treating cat.1 waste water and premises where SRM are removed • pet animals, zoo and circus animals • experimental animals or animals administrated prohibited substances or environmental contaminants • catering waste from international means of transport

6. Incineration Dir.2000/76 Category 1 material Category 1 processing plant Co-incineration Dir.2000/76 133° No TSE animals Derogation for burial/burning in remote areas/ emergency circumstances/ pet animals Landfill Dir.1999/31

7. Category 2 Material • Category 2 materials are; • Animal material collected from waste water plants • Products containing residues of veterinary drugs and contaminants • Animal by-products other than Category 1 or Category 3 • Farmed animals not slaughtered for consumption • Fish with clinical signs of communicable diseases • Manure and digestive tract content from mammals

8. Incineration Dir.2000/76 Co-incineration Dir.2000/76 Category 2 material Category 2 processing plant Fishensilage 133° Oleo-chemical 133° 133° manure Landfill Dir.1999/31 Bio-gas composting Fertilisers Spread on land

9. Category 3 Material Category 3 Materials are • All parts of animals passed fit for human consumption • blood, hides and skins, hooves and horns, pig bristles and feathers from passed non ruminants • egg, hatchery by-products from animals without communicable disease • Raw milk from healthy animals • Foodstuff destined to animal consumption due to defects without health risks or for commercial reason • Fish caught on open sea and fish offal • catering waste, including used cooking oils

10. Non-ABP composting Incineration Dir.2000/76 Technical plant Technical products Catering waste Category 3 material Cat 3 Processing plant Feed material Petfood plant Bio-gas composting petfood Processing plant Co-incineration Dir.2000/76 Landfill Dir.1999/31

11. Catering Waste • catering waste’ means all waste food from restaurants or household kitchens preparing food for direct consumption • but NOT from Premises Butcher shops or supermarkets or food factories producing product for retail sale • catering waste is not controlled IF it goes to composting. Otherwise it IS controlled e.g. for petfood manufacture. • Catering wastes are subject to the existing national standard and NOT this legislation (Ref UK) • For a composting plant to be excluded, it must treat only catering waste and not ANY other type of controlled material

12. Composting plant approval Approved composting plants must • Be approved by and be under the surveillance of competent authority ie Department of Ag. and Food • Treat only Categories 2 and 3 materials • Establish and implement an HACCP system • Heat treat to at least 70°C X 60 min. Equivalent treatments may be approved nationally • Meet “specific requirements for approval” • Premises • Hygiene • Processing • Microbiological

13. Specifics - Premises Specific requirements for Composting plants include: • Closed nonbypassable compost reactor with • Temperature v time monitoring; • Devices to record these results continuously; • A system to prevent insufficient heating • Facilities and a designated area for cleaning and disinfecting vehicles and containers transporting untreated animal by-products. This must be situated or designed to prevent contamination of treated products. • Its own laboratory or make use of an external laboratory.

14. Specifics - Hygiene • Only manure and digestive tract content and Category 3 materials may be composted • Animal by-products must be stored properly and transformed as soon as possible. • Preventive anti-vermin measures including a systematic documented control programme required • Cleaning procedures must be established and documented. Suitable equipment and cleaning agents must be provided.

15. Specifics - Hygiene • Hygiene control must include regular inspections of the environment and equipment. Inspection schedules and results must be documented. • Installations and equipment must be kept in good repair and measuring equipment must be calibrated regularly. • Digestion residues must be handled and stored at the plant in such a way as to preclude recontamination. • The processing plant must have a clean and unclean sector, adequately separated.

16. Specifics - standards Category 3 material used as raw material in a composting plant must be submitted to the following minimum requirements: • 12 mm maximum particle size • minimum temperature in all material : 70 °C; • 60 minutes minimum time in the reactor at 70 °C : The use of processing standards other than those laid down, when catering waste is the only animal by-product used as raw material in a composting plant may be authorised, if they guarantee an equivalent pathogens reduction effect

17. Specifics - Microbiological Samples of the compost taken during storage at the composting plant must comply with the following standards: • Salmonella: absent in 25 g: • Enterobacteriaceae: 5 in 1 g

18. Product - Use restrictions Application to pasture land of organic fertilizers and soil improvers (materials of animal origin used to maintain or improve plant nutrition) other than manure is prohibited. Restriction period may be set at two months

19. Product - Marketing manures Processed manure and processed manure on market must be • from an approved composting plant • Exposed to 70°C for 60 minutes or equivalent. • stored so that contamination or secondary infection and dampness is impossible. • Stored in well-sealed insulated silos or sealed plastic bags • Free from salmonella (in 25 g treated product). • Free from enterobacteriaceae (<1000 cfu /g) • Subject to reduction in spore-forming bacteria and toxin formation.

20. Over to us These are the measures required of the Irish legislation by the EU. Ireland must develop a response.

21. Issues 1 • Over-regulation of the industry and application of standards form the food industry • Clean v dirty sections of a building • Washing bins/vehicles after each use is costly • That sampling requirements are onerous especially for smaller operations (€80 - €160 per sample per batch) • That the composting industry be consulted before development of national legislation • That Ireland develop its own alternative standard for composting of catering waste

22. Issues 2 • That Ireland learn from the UK where a ‘misinterpretation’ of the Regulation led the UK to apply the legislation also to catering waste rather than just Animal By-Products • It is unclear whether enclosed windrows will be permitted (as used extensively on Continental Europe) • Small-scale facilities (schools, country clubs) may be adversely affected, leading to continued landfill with its increased environmental and animal health risks

23. Summary • The Regulation will set standards that will govern the composting industry • Ireland may develop a local interpretation that provides equivalent disease protection • This interpretation should allow the industry to progress • Cré the Composting Association of Ireland wishes to be integrally involved in the development of this legislation • Ireland is in a strong position to learn from experiences elsewhere

24. That’s it!Thank you!