Animal By-Products
presentation
Conor McGovern
Celtic Waste/greenstar
20 March 2003
1
Presentation
Proposed Regulation governing
Health Rules concerning
Animal By-products not intended for
Human Consumption
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
31
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
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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
5
Incineration
Dir.2000/76
Category 1
material
Derogation for
burial/burning
in remote areas/
emergency circumstances/
pet animals
Category 1
processing plant
No TSE
animals
Co-incineration
Dir.2000/76
133°
Landfill
Dir.1999/31
6
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
71
Incineration
Dir.2000/76
Co-incineration
Dir.2000/76
Category 2
material
manure
Category 2
processing plant
133° 133° 133°
Oleo-chemical
Landfill
Dir.1999/31
Bio-gas
composting
Spread on
land
Fish
ensilage
Fertilisers
8
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
91
Non-ABP
composting
Incineration
Dir.2000/76
Technical
plant
Catering
waste
Bio-gas
composting
Category 3
material
Processing
plant
Co-incineration
Dir.2000/76
Cat 3
Processing
plant
Petfood
plant
Landfill
Dir.1999/31
Technical
products
Feed
material
petfood
10
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
111
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
121
Specifics - Premises
Specific requirements for Composting plants include:
1.
Closed nonbypassable compost reactor with
• Temperature v time monitoring;
• Devices to record these results continuously;
• A system to prevent insufficient heating
2. 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.
3. Its own laboratory or make use of an external laboratory.
131
Specifics - Hygiene
1.Only manure and digestive tract content and
Category 3 materials may be composted
2.Animal by-products must be stored properly and
transformed as soon as possible.
3.Preventive anti-vermin measures including a
systematic documented control programme required
4.Cleaning procedures must be established and
documented. Suitable equipment and cleaning agents
must be provided.
141
Specifics - Hygiene
1.
2.
3.
4.
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.
151
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
161
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
171
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
181
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.
191
Over to us
These are the measures required of the Irish legislation by
the EU. Ireland must develop a response.
201
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
211
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
221
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
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That’s it!
Thank you!
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