Royal Commission on Environmental Pollution

The Royal Commission on Environmental Pollution has produced a statement summarising its views on potential hazards from pathogens in wastes, in the light of current controversies about BSE. The Royal Commission has long had a general concern to ensure that pathogens in wastes do not reach human and animal targets. The full text of the statement is below.

Statement by the Royal Commission on Environmental Pollution

In the current debate about bovine spongiform encephalopathy (BSE) references have been made to views expressed in the past by the Royal Commission on Environmental Pollution and waste management issues have been raised which are the subject of recommendations in recent Royal Commission reports. This statement has been produced to provide a clear and concise summary of the Royal Commission's views on relevant issues.

Recycling wastes for beneficial purposes is an important contribution to sustainable development. However recycling of the materials in wastes will not always represent the best practicable environmental option. A case by case assessment is necessary to ensure that the recycling process does not consume more resources than it saves, and that recycled material will not contain harmful contaminants. Where recycling is undertaken, it must be adequately regulated.

While the Royal Commission recognises the value of the various nutrients contained in animal and human wastes, including farm wastes and sewage sludge, it has long been concerned at the potential hazards from pathogens in such wastes. This issue was raised in its report on Agriculture and Pollution in 1979, because of the possibility that using poultry faeces as a source of protein might transmit disease to ruminant animals, and thence through the food chain to humans. At that time BSE had not been identified as a condition in cattle and the Royal Commission did not give specific consideration to hazards from using carcasses as a source of protein.

The Royal Commission remains concerned that the potential hazards represented by pathogens in wastes have received too little attention. Its recent report on Sustainable Use of Soil discusses in particular the parasite Cryptosporidium, sewage sludge, and other types of waste which can be spread on land without a waste management licence. One recommendation was that all sewage sludge applied to agricultural land should be treated. Another was that the Environment and Agriculture Departments review immediately the present legislation governing the spreading of wastes on land, with the aim of improving control and making regulation of the application of all wastes to land more consistent.

Of wastes at present exempt from waste management licensing, attention has recently focused on the spreading on land of blood and gut contents from abattoirs in view of the risk that these might contain remnants of offal or neural tissue. Bearing in mind its general concern about pathogens in wastes, the Royal Commission welcomes the considerable reduction in the amounts of abattoir wastes disposed of in that way which has taken place on a voluntary basis, but emphasises its previous recommendation that the law governing spreading wastes on land should be immediately and comprehensively reviewed.

Culling of cattle as a result of new government measures to deal with the BSE issue will create considerable quantities of solid wastes for disposal. In its report on Incineration of Waste, the Royal Commission drew attention to a shortage of appropriate disposal facilities for animal carcasses and offal and recommended that Agriculture Departments take the initiative in ensuring that suitable incineration facilities would be available. This recommendation was rejected by the government on the ground that 'there already exists a range of options for the disposal of fallen stock generally'.

The eventual size and nature of the waste disposal problem arising from the present situation is not yet clear. Discussions are taking place between the Environment Agency, the Ministry of Agriculture Fisheries and Food, the Department of the Environment and the waste disposal industry in order to assess various options. The Royal Commission wishes to emphasise the desirability of seeking the best practicable environmental option for disposal, and the importance of ensuring that disposal of carcasses does not in itself carry risks of harmful effects, either through transmission of infection or through other forms of environmental damage.

Additional Information

In its 1979 report on Agriculture and Pollution (HMSO, Cmnd 7644) the Royal Commission said (5.63):

In addition to its use as a fertiliser, some animal wastes may also be recycled as an animal feedstuff. The use of poultry manure as a feedstuff component is well recognised although there are obstacles to its full development ... . The major problem encountered in this recycling process is the risk of transmitting disease-bearing pathogens to stock and thence to humans.

Its report on Sustainable Use of Soil was published on 29 February (Cm 3165). Its report on Incineration of Waste was published in May 1993 (Cm 2181) and the government's response was issued by the Department of the Environment as an unpriced publication in July 1994.

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