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SEPA food waste treatment operators workshop

ORG attended a very constructive SEPA workshop for compost and AD site operators on 21st September 2016. This workshop was to discuss the outcomes of SEPA's food waste management consultation (consultation and ORG response here). The meeting was well attended by compost and AD operators and trade associations and it was very welcome to see that SEPA had listened to comments made during the consultation and that they were willing to engage with the industry to and take on board comments made on the day. There was plenty of time for discussion and everyone present had an opportunity to comment. 

Proposals from the consultation:
The consultation focused on three documents: guidance on food waste management; revised regulatory position statement (i.e. end of waste criteria) for outputs from anaerobic digestion; and a revised regulatory position statement for compost. SEPA's overall objective is to improve the quality of food waste derived compost and digestate and protect agricultural soil. They are particularly concerned about plastic.

Food Waste Management guidance
The Food Waste Management Guidance sets out obligations across the chain of food waste management to achieve high quality recycling, i.e. sets out what food waste producers must do, what food waste collectors need to do, what food waste treatment facilities need to do and what users of compost and digestate should do. Only food waste collected in line with the guidance will fulfil the duty of care and the requirements for high quality recycling. 

SEPA have incorporated many of the comments raised during the consultation and circulated a revised version for discussion at the meeting. There was mostly agreement with all the measures set out across the different sectors. There were some comments made around the bags used for food waste collection.

SEPA also set out some standard permit conditions that they are proposing to add to compost and AD operators permits. These were to do with a requirement for pre-acceptance assessment on waste streams, developing critical limits and refusing non-conforming loads and reporting them to SEPA. Most sites seem to either already have these conditions in their permit or do them as a PAS100 / PAS110 requirement, so there were no objections raised.

Waste management exemption proposals
In the consultation SEPA had proposed a ban on materials not meeting the regulatory position statements for compost and digestate being able to be applied to agricultural land under a paragraph 7 exemption. This was not well supported by industry. SEPA's concerns are about plastic being applied to agricultural land so it was suggested that material not meeting the revised regulatory position statements (below) may still be appropriate for applying to land under a paragraph 7 exemption if the spreading rate is reduced to meet the equivalent loading rate for physical contaminants as set out in the position statements. All parties seemed to think this would be a workable solution. The application process is technical and requires applicants to demonstrate that the material will benefit agriculture and this is assessed by technical staff within SEPA.

Regulatory position statement on digestate
SEPA are proposing to reduce the limit for physical contaminants in digestate to 50% of the PAS110 level by 1st Dec 2017, 25% of PAS110 level by 1st Dec 2018 and to 8% of PAS110 level by 1st Dec 2019. These are in line with the requirements of the Quality Meat Scotland (QMS) standard. The operators in the room agreed that this would be technically feasible. Many are already supplying digestate to QMS farms. There were some discussions about further work to be done to look at the physical contaminants test carried out by the laboratories and the need for a Scottish based lab.

Regulatory position statement on compost
SEPA were proposing to reduce the limit for physical contaminants in compost to 66% of the PAS100 level by 1st Dec 2017 and 50% of PAS100 level by 1st Dec 2019. There was concern expressed by many operators about the ability to reliably and consistently meet these levels and the ability to remove physical contaminants from compost is not so straight forward. Not introducing them into sites in the first place is the best solution so in order to allow some of the work with the waste producers to take effect, it was suggested that the first target of 66% of the PAS100 level is delayed until 1st Dec 2018 with the potential for 50% in 2019. Further data will be gathered in the meantime on the levels of physical contaminants in feedstock material to assess what else is needed to improve the compost outputs. Support for local authorities to improve the quality of their collections was also suggested.

Where now?
The documents will be revised by SEPA following the feedback from the workshop. These will need to be signed off internally and by Scottish Government and hope to be published and implemented by December 2016 or early 2017. There will be further thought to the communication and dissemination of the guidance. 

If you would like any further info, or to discuss please contact Jenny Grant

Published: 22/9/16
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