International Review of Waste Management Policy - Department of ...

37.6.1 Environmental Benefits - Prevention
Waste prevention falls under the definition of minimising the quantity and
hazardousness of waste generated. The ABP Regulations ultimately prevent the risk
of disease caused by contaminated ABP and catering waste by introducing controls
for the safe use and disposal of animal by-products hence avoiding contamination of
the food chain.
37.6.2 Environmental Benefits Associated with Recycling
The manner of implementation of the ABP Regulations, although not completely a
‘recycling policy’, will determine the costs of meeting, and the ease of meeting,
specific targets for ensuring biodegradable waste is not landfilled. It has been
commented elsewhere in the UK for example) that it is anomalous that the Directive
does not address the issue of potential transmission of livestock diseases at landfills.
Consequently, few rules apply to landfilling ABP, but rules apply to composting and
biogas plants.
Studies elsewhere suggest that, in particular where biogas plants are used, the
environmental benefits of recycling biodegradable waste are positive relative to
residual waste treatment / disposal. Hence, a rational and proportionate
implementation of the ABPR has the potential to a) enhance the sustainability of
management of biodegradable wastes whilst b) giving confidence to end-users of
compost that the end product is adequately hygienised. On the other hand, an
onerous and disproportionate approach would risk undermining the potential benefits
to be derived (not least in agriculture itself).
37.7 Implementation Costs
The Department of Agriculture, Food and Fisheries incurred a number of costs in
relation to the administering of the policy. DAFF were contacted in relation to
implementation costs and were unable to provide information on this. Facility
operators do not pay fees in relation to the regulations. They do, however, have to
ensure their facility is operated in line with DAFF requirements (see below).
37.8 Response from Public and Industry
The outbreak of foot-and-mouth disease in the country in 2001 led to the introduction
of rigorous legislation in Ireland, which greatly restricted the siting, reception, and
processing of animal by-products and the beneficial uses permissible for the treated
products. To provide clarity on the veterinary requirements, the Department of
Agriculture and Food issued draft information notes Conditions for Approval and
Operation of Composting Plants Treating Animal By-Products in Ireland and Guidance
for Applicants Wishing to Treat Animal By-Products in Composting and Biogas Plants
in Ireland.
A number of submissions were received from industry, citing concern in relation to the
legislation. Issues in relation to the requirements of double fencing, compost end-use
labelling, compost end-use recording to horticulture, hygiene and validation were
highlighted in the submissions. The latest draft of the conditions has taken these
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International Review of Waste Policy: Annexes