Dear Mrs Irwin,

I have now consulted my colleagues at our Head Office in view of the
attachments regarding DEFRAs proposals. We can make the following response;

Under Waste Strategy 2000, the Government has strict targets to meet for the
recycling or composting of domestic waste.  By 2005, 25% of all household
waste must be recycled or composted.  Under the EU Landfill Directive, the
UK also has to meet targets for the reduction of biodegradable municipal
waste sent for landfill.  By 2020 the amount of biodegradable municipal
waste sent for landfill must be reduced to 35% of its 1995 level.
Composting and biogas digestion are seen as vital tools for achieving these
targets.

Under the Animal By-Products Order 1999 (as amended) it is an offence to
allow livestock and birds access to catering waste containing meat or
products of animal origin, or catering waste which originates from a
premises on which meat or products of animal origin are handled.

The new EU Animal By-Products Regulation (expected to come into force in
spring 2003) will permit the use of composting and biogas treatments for
catering waste and low-risk animal by-products.  Animal by-products must be
treated to the EU standard, which is 700C for 1 hour.  However, for plants
which process only catering waste (not animal by-products), the Regulation
allows Member States to specify their own standards at national level,
provided that these standards guarantee an equivalent level of pathogen
removal.

To this end DEFRA commissioned a risk assessment examining the risks to
public and animal health from the use of catering waste in composting and
biogas treatment processes.  The risk assessment (available from the DEFRA
website) makes recommendations on alternative treatment standards which are
at least as effective as the EU standard.

DEFRA are now looking to amend the Animal By-Products Order 1999 to permit
the treatment of catering waste in composting and biogas plants. We might
expect amongst other controls that strict treatment standards will be
applied to the treatment process, that treatment will only be permitted in
closed or in-vessel composting systems and restrictions put upon subsequent
use of the material. The direct landspread of untreated catering waste to
which livestock will have access will continue to be illegal.

The State Veterinary Service (SVS) and Local Authorities regulate the Order.
Accordingly any such new treatment controls will be regulated by an approval
issued by the SVS which will be in addition to any waste management
authorisation regulated by the Environment Agency

A public consultation on the new proposals is expected from DEFRA shortly.
All interested parties should make use of this opportunity to make DEFRA
aware of their views and comments. I will forward your message and my reply
to contacts in DEFRA so that they are aware of your concerns.

Yours sincerely


Geoff Bateman
Area Manager (Devon)