OrganicWasteSpreadOnLand PDF

STRATEGIC REVIEW OF ORGANIC
WASTE SPREAD ON LAND

Contents
Page No.
1.
Executive summary
2.
Introduction
3.
Current practice
4.
Underpinning science
18
5.
Current legislation/regulation, guidance and control mechanisms
33
6.
Discussion
43
7.
Conclusions and recommendations
53
8.
References
57
9.
Annexes
65
10.
Plates

Annexes
Annex 1
Brief agreed with Scottish Office
Annex 2
Questionnaire
Annex 3
List of persons contacted
Annex 4
Description of sewage sludge types
Annex 5
Sludge use in Agriculture Regulations - monitoring requirements for PTEs
Annex 6
British Retail Consortium Matrix
Annex 7
Exemptions to Waste Licensing
Annex 8
Agricultural wastes statistics & treatment
Annex 9
Particular interests in organic wastes applied to land
Annex 9a
Summary of Blairingone Action Group concerns
Annex 10
Nutrients in sewage sludge as spread
Annex 11
PTEs in Scottish soils and sludges
Annex 12
Comparative risks from pathogens associated with land application
Annex 13
Sludge treatment to reduce pathogens
Annex 14
Benefits and disbenefits of the various wastes
Annex 15
Risk assessment matrix
Annex 16
Control options matrix
Annex 17
Risks - exempt wastes
Plate 1
Injection of sewage sludge
Plate 2
Experimental trial using digested sewage sludge
Plate 3
Application of slurry
Plate 4
Application of slurry
Plate 5
Application of farmyard manure
Plate 6
Application of distillery waste
Plate 7
Papermill sludge post application
Plate 8
Composting process

Executive summary
Introduction
1.
The Scottish Office has requested SEPA to undertake a strategic review of organic waste
spread on land. The review covers sewage sludge, waste disposal activities exempt from
waste management licensing (exempt wastes), agricultural wastes, fallen stock and
composted municipal waste.
Background
2.
Current estimates of the tonnage of waste applied to land in Scotland are:

agricultural waste
15,000,000 tonnes
exempt industrial waste
367,000 tonnes
sewage sludge
200,000 tonnes
composted waste
?
96%
3%
1%
< 1%
3.
If organic wastes are applied correctly to land they can have positive beneficial fertilising
effects. Other beneficial environmental effects include reduced resource demand, soil
conditioning and, indirectly, habitat conservation. There are potential cost savings to farmers
due to reduced inorganic fertiliser requirements when organic wastes are used.
4.
Sewage sludge, which comprises 1% of the waste spread on land, is generally applied under
controlled and regulated conditions. There is considerable public pressure to increase the
level of treatment of sewage sludge, in particular to phase out the practice of spreading
untreated sewage sludge on land. The UK Government has recently announced its intention
to phase our the latter practice. A good body of scientific literature exists in respect of
potentially toxic elements (PTEs) and many pathogens in sewage sludge.
5.
Wastes applied to land as an exempt activity include blood and gut content from abattoirs,
distillery wastes, paper waste and septic tank sludges. The current system for recording
volumes of these wastes is not sufficiently accurate to understand the extent of this outlet for
such wastes or to predict future trends. The current pre-notification period to SEPA is not
useful in managing the activity.
6.
Most exempt wastes are not pre-treated or stored at the point of origin, leading to odour
problems and typically are not stored at the point of origin resulting in the possibility that
wastes are not being spread at the time most beneficial to the crop or the land. Neither
agricultural benefit nor ecological improvement, the key justifications for the activity, are
defined in regulations.
7.
There is a paucity of data relating to the fate and impacts of nutrients, PTEs and pathogens
in exempt wastes. Little is known of the effects of organic chemicals on soil and of the
effects wastes have on soil processes. Pathogen related risks associated with exempt
wastes and the agricultural wastes are not quantified or fully understood.
8.
Owners/occupiers of the land on which waste is spread are not always fully aware of the
nature and content of what is being spread there. Multiple wastes can be applied in addition
to inorganic fertiliser without any need for the owner/occupier to take account of synergistic
effects, total nutrient content or total heavy metal loadings.
The potential for point source or diffuse pollution of watercourses from waste spread on land
is high if incorrectly spread or over-applied or if inorganic fertiliser is not reduced in
9.

proportion to the organic wastes applied. There is no necessity for waste contractors to
employ operators with a certificate of competency in the activity, which may result in bad
practice and increased potential for water pollution.
10.
Fallen stock does not yet pose a problem but difficulties may be expected in future years due
to cumulative effects of increased disposal.
11.
There is much useful guidance available such as the Prevention of Environmental Pollution
from Agricultural Activity (PEPFAA) Code of Practice which includes guidance and refers to
statutory requirements, and the Code of Practice for the Agricultural Use of Sewage Sludge
which includes all the statutory requirements of the Sludge Regulations. However, the Codes
themselves are not statutory which causes confusion. The Codes are not necessarily known
or followed extensively within the agricultural community.
Conclusions
12.
There is a lack of public confidence in the practice of spreading organic waste on land which
threatens an activity which can have environmental benefits.
13.
The current approach to the regulation and management of organic waste spread on land is
inadequate and inconsistent, leading to practices which pose a risk to the environment and
pose potential public, animal and plant health risks.
Principal recommendations
14.
A consistent legislative framework for all organic wastes spread on land should be
developed, incorporating the relevant Codes of Practice as necessary.
15.
Regulations should cover mixed waste streams and set minimum standards for safe
acceptance loadings for different wastes on different soil types. Minimum standards of
treatment for wastes spread on land should be stipulated along with minimum storage at the
producers site.
16.
The concept of land management plans should be adopted which would encompass the
beneficial and detrimental aspects of all wastes applied to farmland as well as incorporating
inorganic fertiliser inputs.
17.
A competency scheme for contractors should be introduced, similar to the WAMITAB

qualification for waste management licence operators.
18.
Blood and gut contents and septic tank sludges should be prohibited from being spread on
land.
19.
Injecting waste in land with field drains, spreading outwith daylight hours and spreading in
designated heritage sites should be prohibited.
20.
A proposed mechanism for regulating the spreading of organic wastes onto land is set out in
the report, with the objective of ensuring that the responsibility for specific actions rests with
the appropriate person. The scheme would be amenable to an accompanying charging
scheme.

1.
Introduction
1.1
During the course of late 1997 and early 1998 there has been public disquiet in relation to the
practice of spreading organic wastes on land. This has been expressed through media
interest, complaints to SEPA and internal SEPA Board discussion at both national and
regional level. The Scottish Office had also recognised the concerns and subsequently The
Scottish Office requested SEPA to undertake a strategic review of organic waste spread on
land. A copy of the brief is given in annex 1.
1.2
The work has been directed and carried out by SEPA staff as a consultancy project reporting
to a small steering group drawn from The Scottish Office, the Convention of Scottish Local
Authorities and SEPA. The study has been wide ranging and it was considered necessary to
involve all relevant stakeholders who have an interest in the practice. A questionnaire
approach was used as the initial data gathering exercise, augmented by personal or
telephone interviews (annex 2).
1.3
SEPA wishes to acknowledge with thanks the individuals and organisations who have
assisted in the provision of information. A list of those concerned is given in annex 3.

2.
Current practice
Introduction
2.1
In this chapter the origin and current practice for disposal of organic wastes are described
briefly, along with information on the tonnages and outlets. Supplementary detail is given in
annexes where information relating to fallen stock is also discussed. It is important to place
each waste in context against the others and against the total tonnage of organic wastes
spread on land. Current estimates of the main waste types applied to land in Scotland are:
Agricultural waste
Exempt industrial wastes
Sewage sludge
Composted waste
15,000,000 tonnes
367,000 wet tonnes
200,000 wet tonnes
?
96%
3%
1%
< 1%
Information relating to fallen stock is also discussed
Sewage sludge
Origin and disposal methods
2.2
Sewage sludge is a by-product of the sewage treatment process. The nature of the
treatment process will affect dry solids content, nutrient availability and pathogen content.
This in turn influences its suitability for recycling to land. Sludge may be stabilised through a
digestion process, the addition of lime, thermal treatment or it may remain unstabilised.
Types of sludge and typical dry solids content are summarised in annex 4.
2.3
Responsibility for sewage treatment and hence sludge production, treatment and disposal
lies with the three water authorities. Only about 20% of sludge applied to agricultural land in
Scotland is stabilised by digestion before application. This situation is set to change in
response to various external pressures and it is likely that in the near future a large
percentage of sludges will be pasteurised and stabilised/ thermally dried.
2.4
Sludge is currently applied to agricultural land either by surface spreading of liquid sludge
from a tanker or by injection to plough depth. A much smaller amount (8% of area) is applied
from solid manure spreaders. However, future application methodology will change in step
with changes in the nature of the sludge product. At present, sewage sludge is applied to
land either by the water authorities or, more commonly, by sludge contractors. It is known
that certain sludge contractors apply sewage sludges mixed with other wastes for example,
farm slurries or exempt industrial wastes such as paper crumble as this product is easier to
handle. The extent to which waste streams are mixed at time of application is not known.
2.5
The water authorities are responsible for monitoring sewage sludge and soils to which sludge
is applied for a range of metals and nutrients as defined in the Sludge Use in Agriculture
Regulations (annex 5). However, landowners have to assume some responsibility for
ensuring that such sampling has taken place before sludge application.

Quantities
2.6
At present some 100,000 tonnes dry solids (tds) of sewage sludge are produced each year,
arising as follows:
East of Scotland Water (ESWA)
- 34,000 tds
North of Scotland Water (NoSWA)
- 10,000 tds
West of Scotland Water (WoSWA)
- 55,500 tds
Sludge production is set to rise to 177,500 tds by the year 2006 due to additional treatment
requirements imposed by the Urban Waste Water Treatment Directive (91/291/EEC) which
takes effect progressively from 31 December 1998.
Outlets
2.7
Each water authority has developed a different approach to dealing with the sludge
produced, largely inherited from the former Regional Council water and sewerage
departments, and affected by land availability. At present 89,000 tds pa are disposed of at
sea and only 24,000 tds (19% of total produced) is recycled to land, equating to
approximately 200,000 wet tonnes, assuming a typical dry solids content for Scottish sludges
applied to land of 11.2% ds. The current estimate of sludge which will be recycled to land by
the year 2005/6 is 120,000 tds with the majority likely to be applied to agricultural land and
only a small amount recycled to other land-based outlets such as land reclamation and
forestry. (Gendebien et al, 1998).
2.8
The total area of agricultural land currently used for sludge recycling is just over 4,000ha, at
a total of 597 sites. The majority of sludge is recycled to arable farmland (378 sites, 2,815ha)
and a smaller amount to pasture (219 sites, 1389 ha) (Gendebien et al, 1998). The practice
of recycling to land varies geographically with NoSWA currently recycling 66% to land,
ESWA recycling 38% to land and WoSWA applying 6% to land. The suitability of land for
receiving sludge varies across Scotland, depending upon the soil type, topography, the metal
content and pH of the soil. Estimates (Towers, 1995) have indicated that the potentially
2
2
2
available areas are as follows: NoSWA 7597 km , ESWA 4176 km , and WoSWA 4550 km .
Impending changes
2.9
Recently considerable public pressure has been exerted on the UK water industry to cease
applying raw sludge to land. There are a number of drivers, mainly relating to pathogen risks
associated with application of untreated sludges to land.
2.10
The nineteenth report of the Royal Commission on Environmental Pollution on Sustainable

Use of Soil (RCEP, 1996) found there to be no reported instances in the UK in which a link
has been established between controlled application of sewage sludge and occurrence of
disease in the general population through food or water contamination. However, it was
observed that untreated sludge will contain a variety of pathogens and recycling to
agricultural land therefore presents a theoretical pathway by which infections could return to
the general population. The committee recommended that the use of untreated sludge to
agricultural land be phased out on precautionary grounds. The committee also advised that a
review of scientific evidence relating to the Code of Practice for the Agricultural Use of
Sewage Sludge be undertaken. This was subsequently commissioned by the Department of
Environment, Transport and the Regions, and reported in July 1998 (Carrington et al, 1998).
2.11
The House of Commons Environment, Transport and Regional Affairs Committees report on
Sewage Treatment and Disposal (HoC, 1998) also highlighted the requirement for increased
understanding of the scientific basis for the Code of Practice and recommended that by the

year 2002 all sludge that is to be recycled to land should be subjected to stabilisation and
pasteurisation, subject to confirmation that these processes also remove the pathogens of
new interest and would effectively remove any microbiological hazard from sewage sludge
recycling to agricultural land. Recommendations were also made for a new Code of Practice
for consumers written in non-technical language and circulated to farmers and users.
2.12
The Select Committee on the Environment, Transport and the Regions - Sewage Treatment
and Disposal - Government Response (July, 1998) considered that the case has not been
made for requiring stabilisation and pasteurisation on public health grounds but recognised
the potential risk of transfer of pathogens to food by spreading of sewage sludge to
agricultural land and proposed that a structured programme of research and risk assessment
be carried out into the use of all organic wastes on land. It was agreed that spreading
untreated sludge on land will be phased out by 2002 and further precautionary changes to
existing controls were recognised.
2.13
Both the public and food retailers as represented by the British Retail Consortium (BRC)
have raised concerns regarding the risk of disease through application of sludge to
agricultural land and the effects on the whole food chain. Food retailers have voiced the
need for scientific evidence relating to the safety and security of the practice. This is to
include processes and systems that deliver assurances from the point of treatment to field
application with an audit system which monitors the whole process. An agreement has been
reached by the Water industry and retailers which lays out a framework for use of sludge in
agriculture. Details of this are given in annex 6.
2.14
The view of the farming community as voiced by the National Farmers Union of Scotland is
that where Scottish farmers cannot compete with foreign imports in terms of price they have
to compete on quality. Consequently, farmers would note be prepared to take risks by using
untreated sewage sludge if public perception is such that this is not acceptable (NFU, pers
comm, 1998). There is a consensus that farmers do not wish to use raw sewage sludge, thus
easing adoption of this agreement by the farming community.
2.15
In addition, land owners are concerned about potential liabilities arising from sewage sludge
being applied to their land. In England and Wales the Country Landowners Association
(CLA) has suggested that owners should enter into agreements with water undertakers to
ensure that the best methods of treatment are used and to ensure that owners have an
indemnity in respect of any problems which may arise as a result of their land being used for
sludge disposal. A Model Agreement has been drawn up. This approach is not followed by
the Scottish Landowners Federation (SLF) (pers comm, Maurice Hankey, 1998). Instead, the
SLF is encouraging its members to follow the guidance given in the Prevention of Pollution
From Agricultural Activities Code of Practice (the PEPFAA Code) and to consider carefully
the long term impact on their land.
2.16
The consequence of such drivers is that the Scottish water authorities are revisiting their
sludge strategies to ensure that the demand for higher level treatment is satisfied. Details
are given below, from information provided by ESWA, NoSWA and WoSWA.
East of Scotland Water Authority

2.17
ESWAs future policy is to ensure beneficial re-use of sludge, recognising that there is a need
to secure more than one outlet. A number of outlets have been considered including
agriculture, forestry, horticulture, energy recovery, and incineration in a cement
manufacturing process. ESWA has responded rapidly to the BRC, who in their view are
driving the issue. Consequently it is intended that sludge be treated by the year 2000 (with
treatment including digestion, lime stabilisation or thermal treatment). The application of

liquid digested sludge will be phased out by 2005. The long-term strategy is to pasteurise all
sludge and it is intended that all new sludge treatment centres will be capable of
pasteurisation to provide effective barriers to pathogen transmission. Thermal drying of
sludge is being considered as market research has shown farmers have a preference for
thermally dried sludge pellets. As an interim solution ESWA will use a licensed landfill.
North of Scotland Water Authority

2.18
NoSWA has a good landbank for spreading and the availability of this outlet is being
encouraged. NoSWA has promoted the use of farm waste management plans with a strong
emphasis on Quality Assurance. NoSWAs future strategy takes a flexible balanced
approach, continuing with beneficial recycling to land whilst securing incineration as a
possible future option. Local solutions will be adopted in certain areas, taking into account
geographical and operational limitations and transport costs. Approximately 90% of sludge
produced will be from treatment works progressed under three PFI schemes. NoSWA also
intend to form major centres and undertake lime stabilisation, dewatering and application of
cake sludge to land. Lime stabilisation as a long term solution is still subject to evaluation.
West of Scotland Water Authority

2.19
It is intended that 90% of the sludge generated within WoSWA will be used for energy
recovery using sludge cake as a secondary fuel source with an annual throughput of 65,000
tds. The plant is to be completed by mid 2000 and in the interim period untreated sludge will
be dewatered at major wastewater treatment works and landfilled. Options are still being
considered for Ayrshire, Argyll and Dumfries and Galloway where it is likely that the strategy
will be for enhanced treatment and recycling to land.
Industrial wastes which are exempt from licensing - exempt wastes

2.20
Since the introduction of the Waste Management Licensing Regulations 1994 a variety of
non-agriculturally derived wastes, often referred to as industrial wastes, have been applied to
land, under legal exemptions from licensing. These wastes, which are commonly referred to
as exempt wastes are listed in annex 7. The most common wastes in Scotland include
distillery waste, paper waste and blood and gut contents from abattoirs. The terminology
exempt waste will be used throughout this report to describe these wastes which are
recovered through recycling to land and are exempt from licensing. It is the process of
application, not the waste itself, which is exempt.
2.21
These wastes are not usually treated although technologies which can be used include lime
stabilisation, dewatering, digestion, composting and heat treatment. Treatment of many of
these wastes would produce a much more stable product making such wastes more suited
for storing for longer periods of time without leaching or causing odour nuisance and would
also improve the consistency of the product, reducing transport costs and improving
agronomic value. The extent to which such wastes arising in Scotland are treated is not
known but is considered to be small.
2.22
Most landspreading of exempt wastes in Scotland is carried out by two contractors. In order
to satisfy the criteria that these wastes are exempt from licensing it is essential that their
application provides agricultural benefit or ecological improvement, terms which are not
defined. The wastes are analysed to determine nutrient content, pH and any chemical or
physical properties which would allow the waste to act as a soil conditioner. Typically,
analysis is undertaken at the start of a particular waste stream being used, and are not

necessarily re-analysed at intervals over the following weeks or months during which the
waste is applied. Some wastes are inconsistent in nature, resulting in wide variation in
composition from batch to batch over time. Generally microbiological analysis is not
undertaken.
2.23
The most common practice is for waste to be collected from the site of production by
contractors. Solid wastes are usually transported in dumper trucks or skips whilst liquid
wastes are transported in tankers. Very few waste producers have the ability to store wastes
on their premises, resulting in the need for storage at the site of application. Storage-related
problems at the site can arise such as escape of waste, leaching of potentially polluting
effluents and odour nuisance, as well as transport related issues.
2.24
Liquid wastes are stored mainly in field storage tanks; sludges are stored in lagoons or
heaped in fields if the solids content is high enough; cakes and crumbles are stored in
heaps. There are no specific minimum standards for the storage of these wastes in terms of
bunding and drainage, in contrast to the regulations applying to agricultural slurries.
2.25
The method of application to land is dependent upon the waste involved, the soil type and
the nature of the crop being cultivated. Liquid wastes are either injected using an umbilical
injection system or surface spread using dribble bars. Solid wastes (taken to be > 12% dry
solids) can be spread by muckspreaders or specialist solids spreaders. The method chosen is
determined by the potential of the waste to cause nuisance, and the risk of sward
contamination by pathogens, chemical residues or litter.
2.26
Wastes are currently applied to land 52 weeks a year, due to lack of storage facilities.
Consequently wastes are applied to land during inappropriate weather conditions, for
example during periods of heavy rainfall when soils are at field moisture capacity and the
waste is likely to be washed away on application. Wastes are also applied at times of the
year when low temperatures result in limited plant growth and hence limited nutrient uptake.
As a result, nutrients are likely to be leached from the soil particularly if available in a soluble
form.
2.27
Exempt wastes are occasionally spread at night, a practice which is unacceptable to persons
living in the vicinity who are suspicious of the legitimacy of the activity (BAG, pers comm,
1998). Concern has also been expressed that contractors are purchasing land to use as
dedicated disposal sites, although there is no evidence to support this view.
Quantities
2.28
The actual amounts of exempt wastes spread to land in Scotland are not known accurately.
This is due to the recording system currently used whereby the sludge contractor is required
only to give pre-notification of maximum amounts intended to be spread in a six-month
period. The information is provided as maximum area to which the waste is to be applied
and maximum application rate. Figures were collated from SEPA records (SEPA, 1998) and
table 1 shows the total amounts for which notifications were received from the contractors in
1997. All figures are given as wet tonnes, the dry solids content of most of the wastes not
being known.
10

Table 1 - Exempt waste spread on land in Scotland
Waste
Waste wood, bark or other plant matter to agricultural land
Molasses
Dredging from inland waters
Septic tank sludges
Press sludge
Waste soil or compost to agricultural land
Waste lime
Waste soil or compost to non agricultural land
Blood and gut contents from abattoirs
Paper waste (of which paper crumble is 46,000)
Sludges from biological treatment plant
Waste food, drink etc. (of which distillery waste is 63,000)
Mixture of wastes
Estimated total
Amount recycled to land 1997

(max. figure) wet tonnes
1,000
6,000
5,000
9,000
16,000
11,000
12,000
21,000
26,000
49,000
52,000
76,000
84,000
368,000
Outlets
2.29
The potential maximum amount applied to land shows a wide geographical variation. Almost
290,000 was applied in SEPA East Region, 60,000 tonnes in SEPA West Region and 14,000
tonnes in SEPA North Region. Records are not available for the total areas of land to which
these exempt wastes are currently applied and it should be recognised that the maximum
figures do not necessarily represent the actual figures.
Agricultural waste
2.30
There are a number of different types of agricultural waste which are collected, stored or
processed and then applied to farmland in Scotland as part of a controlled disposal
operation. For the purposes of this study, agricultural wastes are taken to be manures,
livestock slurries and silage effluent. The management of these wastes is a basic and
integral part of any farm business which has livestock. It has been part of farming practice
for as long as settled livestock husbandry has been practised and, as such, is viewed as a
natural process. It is only with the advent of intensive agriculture that controls have been
introduced over some of the practices, especially storage, otherwise it is unrecorded and not
controlled.
2.31
Livestock wastes are generally classified by the type of stock and the physical form of the
waste. Most livestock wastes collected in Scotland originate from the dairy, beef, pig and
poultry sectors. Livestock wastes may either be solid, semi-solid or liquid. Solid wastes are
generally termed manures, and form a stable mass. Semi-solid and liquid wastes are
referred to as slurries. Detailed information is given in annex 8. The options available for
the storage, transport and land application of livestock waste, as well as the environmental
and health risks associated with these stages in the handling process are directly dependent
on its physical characteristics.
11

Quantities
2.32
It has been estimated (SAC, 1998) that 15,000,000 tonnes of agricultural waste, mainly in
liquid form, are recycled to land each year. These figures are based on numbers of
livestock and estimated volumes produced per head and whilst not exact figures, are
considered to be of the correct order of magnitude. Thus, the quantity of agricultural waste
which is stored, processed and applied to land is considerably greater than other types of
waste. However, additional amounts of agricultural wastes are deposited directly via
defecation from grazing animals and it is estimated that a further 10,000,000 tonnes are
excreted directly on to land in Scotland by grazing animals. Similar percentages have also
been quoted by (Mawdsley et al, 1993).
Composted waste
2.33
Composting is used to describe the natural degradation of organic material by the action of
bacteria, fungi, insects and animals in an adequate air supply to reduce it to a stable material
which can be used to improve the fertility of soil (IWM, 1994). Whilst composting represents
a natural process, its efficiency can be improved by careful management of process
conditions and material inputs. Composting can be accomplished by a range of methods
including simple windrow systems, in-vessel systems and static pile aeration systems.
Interest is also growing in the development of home composting systems. Any material which
is biological in nature has the potential to be composted, but some materials are more
suitable than others.
Quantities
2.34
Very little waste is reduced by composting in Scotland. To date it has not been cost effective
to select composting over landfill, and there is a lack of demand for the product as farmers
have easy access to affordable chemical fertilisers and free sewage sludge (CA, 1997). The
situation in the UK is in contrast to that in Germany and other European countries, as well as
to that in the US and Canada, where composting is utilised to a greater extent, generally
driven by legislation restricting the quantity of organic material that can be accepted by
landfills.
2.35
Notwithstanding this, the extent of composting in the UK has been steadily increasing, going
from four composting plants in 1990 to 44 in 1996 (CA, 1997). This has largely been in
response to changes in legislation and in anticipation of further incentives to diversify waste
management and recycling practices (HDRA, 1998). In Scotland in 1994, the composting of
14,000 tonnes of household waste was reported by 22 local authorities. Of the compost
produced from this waste, 250 tonnes were sold to the public, 300 tonnes were used for
public parks and the rest was sold to farmers and public/local professional gardeners (Bionet,
1998). However very few applications for exemptions for use of composted waste have been
made under the Waste Management Licensing Regulations 1994 (final quarter of 1997: 8
tonnes), first quarter 1998: 2 tonnes) (SEPA, 1998).
2.36
There is currently no composting of MSW in Scotland. However, a number of local

authorities have experience of composting green wastes segregated from the MSW waste
stream. Source-separated botanical waste derived from 11,800 households along with
botanical waste from commercial premises, civic amenity sites and parks and gardens has
been carried out by Dundee City Council since 1991 (Olsen and Collier, 1994). Borders
Council has experience of composting and Dunfermline District Council conducted early trials
collecting household botanical waste and composting but with little success. A number of
12

local authorities have pilot tested a wide range of home composting systems but to date no
major implementation of this approach is evident.
2.37
In terms of private sector activity, only one company in Scotland has been involved with
composting organic wastes on a large scale (pers comm, Peddie, 1998). It is anticipated that
the level of composting activity in Scotland will markedly increase in the future (pers comm,
Olsen, 1998). Central to this expansion will be a number of composting initiatives.
Local authorities in Tayside (Angus, Perth and Kinross and Dundee City Councils) are
looking to provide a centralised closed composting system. It is anticipated that the
intention to fix charges for the acceptance of waste for composting will provide the
incentive for contracts to be established with food processing and other businesses in the
area. Dundee City Council will also be promoting composting by businesses, charging
only for uplift, and also within self contained communities such as military bases and
prisons
Renfrewshire Council is looking into composting green wastes in partnership with
neighbouring local authorities and the private sector (pers comm, Eving, 1998) and are
also looking to promote home composting.
2.38
Other composting activities in Scotland include co-operation between the University of

Abertay, Dundee and Dundee City Council. Furthermore, the University of Aberdeen has
started work on the composting of green waste in conjunction with the City of Aberdeen
Council, whilst the Macaulay Land Use Research Institute (MLURI) has specific interests in
the novel composting of distillery and other exempt industrial wastes as well as the novel
application of composted products, for example their use as biofilters (pers comm, Campbell,
1998).
Fallen stock
2.39
The problems in disposing of fallen stock are a consequence of the impact of BSE in the late
1980s which reduced the value of by-products from the animal industry (Tweddle, 1998).
Prior to the BSE controls farmers would receive a modest sum for fallen stock from the
knackery which would salvage hides or skins and meat not for human consumption. The
remaining waste material would be sold to or collected by renderers who could extract further
by-products. The closure of these outlets has resulted in an increase in the number of fallen
stock requiring alternative disposal routes. Renderers charge for treating material and the
relatively few renderers in Scotland have a market advantage. Knackeries now have to pay
for rendering wastes and the industry has increased its charges for uplifting fallen stock.
Consequently the customer base has declined and only four businesses continue to operate.
The result of this situation is that on-farm burial of fallen stock is increasing.
2.40
As a percentage of estimated fallen stock, the knackeries in 1997 dealt with approximately
50 to 66% of all cattle but only about 5% of all sheep. The inference is that one-third to one
half of cattle and the majority of sheep are either disposed of by burying or natural
decomposing of sheep on high ground. Pigs and horses are also dealt with by the knackery
and rendering system whilst poultry may be disposed of by incineration in-house by the larger
companies.
13

Table 2 - Numbers of animals collected by knackeries in Scotland 1997. (Source: Tweddle,
1998)
Total
As % of estimated deaths
2.41
Cows
10183
56
Stirks
8914
80
Calves
24741
55
Sheep
21842
6
If present trends continue the practice of on-farm burial will increase to such an extent that
the already depleted knackery industry will be jeopardised. Those farmers for whom on-farm
burial is not feasible or is restricted will face severe problems in disposing of fallen stock,
which may lead to improper or bad practice becoming more commonplace. Many parts of
Scotland are not suitable for on-farm burial because of high water table levels or thin soils.
The UK is unique within the EU in allowing widespread on-farm burial, albeit as the least
favoured option after knackeries, hunt kennels, landfill and incineration. Guidelines for safe
disposal methods are stated in the PEPFAA Code of Good Practice, which is not statutory;
neither does it take into account the differing geological conditions across Scotland.
Key players
2.42
There are many groups who have a legitimate interest in the subject of organic wastes
spread on land. The groups are wide ranging in origin and remit and as many as possible
have been contacted to provide information and background as part of this study. Annex 9
and 9a lists a those who are considered to be key players in Scotland and details their role
and particular interest. The principal players include :
2.43
Waste producers;
Waste carriers;
Waste contractors who apply the waste to land;
The landowners / occupiers on whose land the waste is applied;
The public living in the vicinity of the applications;
The Regulators (SEPA, SOAEFD, Local Authorities);
Farm advisers such as Scottish Agricultural College;
Food retailers and those in the chain from farm to fork; and
Environmental NGOs
The studys researches have produced a considerable amount of data and opinions. In order
to reduce the volume of text, all the important issues arising from a section have been
summarised in as brief a form as possible and presented as summary and issues. The
detailed arguments behind each statement are not necessarily given in the text, but the basic
background information is available either in the relevant section or the annexes.
Public perception
2.44
The role of public perception as a key driver in the acceptability of spreading organic waste
on land should not be underestimated. Many of the changes in practice which have
happened over the last year such as the intention to cease putting untreated sewage sludge
on land have resulted from public pressure. Similarly, at a local level, the public concerns at
Blairingone have precipitated much media interest in the topic. The questions of who
constitutes the public and whether the public lead or are led by major interest groups such
as the British Retail Consortium with its links to the supermarkets is not important in this
context instead, it is enough to recognise that the public in all its guises must have
confidence in the process if it is going to continue.
14

2.45
It only becomes necessary to identify the source of the concern in more detail when action is
to be taken because the concerns of one particular audience may differ from that of another.
For example, those living next to land where the activity takes place have different concerns
to those of the retail sector, although all share a common interest. The way each audience is
addressed will be different.
2.46
In general the public concerns about wastes going to land relate either to general issues such
as the fear of disease transmission, the effect of chemicals in the environment and the
concept of pollution of land and water or to the immediate and direct impact of odour
nuisance or vehicle movements in the vicinity of communities. Effective communication is
required to convey the degree of risk or otherwise and to promote the concept of beneficial
recycling of materials.
2.47
The ability of local interest/action groups to collate evidence of nuisance/risks associated

with waste application should not be underestimated, nor should the political pressure which
such groups can exert. In particular, access via the Internet to international web sites
devoted to waste-related issues enables such groups to be well informed, thereby requiring a
response which fully recognises the knowledge-base already held by such groups. It is
important to avoid greenwashing whereby coverage of issues of real concern is treated
superficially and the benefits of recycling are addressed disproportionally to the risk and
concerns.
2.48
Transparency of information is crucial. Communication in a format easily accessible to

consumers could have the greatest impact on acceptability of waste recycling to land. The
view of the Scottish Consumers Council is that consumers tend to believe supermarkets
rather than governments because governments are thought to act in the interest of certain
individuals such as farmers (Heaney, pers comm, 1998). Information needs to be
communicated in such a way as to advise, using a non-technical format where appropriate
but quoting reliable sources and informing how to get access to information.
2.49
The media are clearly major shapers of public perception in this field and it is important that
the regulators of waste application work with them to provide factual and relevant
information. Strong lines of communication from all sectors involved in the practice are
required with consumers, and these could be strengthened by various means.
2.50
As a means of addressing public stakeholder interest, consideration should be given to

managing the issue on both a local and a wider basis. This could take the form of :
Informing the public of large scale operations prior to them going ahead;
Providing a clear definition of the type of wastes and the nature of the treatment it
has received; and
providing a central register of waste recycling which is accessible to the public.
15

Summary and issues
1.
Current estimates of the percentages of the various wastes applied to land in

Scotland are:
agricultural waste
exempt industrial waste
sewage sludge
composted waste
96%
3%
1%
< 1%
2.
The amount of sewage sludge is likely to increase, but the increase is still very small
compared to the amount of agricultural waste applied.
3.
There is currently considerable pressure to increase the levels of treatment of

sewage sludges to reduce the risk of pathogen transmission. This is not reflected
with exempt wastes although there is concern over odour, which can be controlled
through treatment.
4.
There is currently no accurate record of the amounts of exempt wastes applied to

land, nor any indication of future trends.
5.
The six month pre-notification system for exempt wastes does not provide sufficient
level of information and there is no requirement to incorporate the information into
any farm plans.
6.
The current notification periods cause problems. Often the notification comes too
close to the application for a SEPA officer to attend. There is no real opportunity to
determine when the activities will take place as the wastes could be applied at any
point during the six months and dates may be changed due to inclement weather.
7.
Storage of exempt wastes is not practised at the point of origin, leading to problems
of handling and odour.
8.
Lack of storage means the requirement to carry out spreading to coincide with
crop/land demands is disregarded, leading to environmental problems in times of
unsuitable weather or low crop uptake.
9.
Multiple wastes can be applied to the same land without the landowner/occupier
needing to take account of any synergistic effects etc. or to have a farm waste or
nutrient management plan.
10.
Information pertaining to the nature of exempt wastes and agricultural wastes is

limited compared with that for sewage sludges.
11.
Farmers are often unaware of the nature of what is being applied to their land.
12.
Agricultural wastes applied to land are in general not treated.
13.
There is a lack of vocational training and certification for staff advising on application
of wastes and for contractors undertaking the application.
14.
Composted waste is currently a very minor arising but levels may increase in the
future. Little research has been carried out into its behaviour on land.
16

15.
Fallen stock does not currently pose a problem but difficulties might be expected in
future years due to cumulative effects of increased disposal.
17

3.
Underpinning science
3.1
The scientific knowledge base which underpins disposal practices for the organic wastes
included in this review is extensive in some aspects but lacking in others. The knowledge
base sometimes lags behind the issues and often reflects the pressure of different drivers at
different times. Research is often reactive, carried out in response to the issues as they
arise. This is not unusual or unexpected but there are differences in the extent of the
knowledge needed now to satisfy an informed public which is increasingly sensitive to scare
stories and which is increasingly sceptical of official information.
3.2
This change in public reaction to perceived risk, real or otherwise, is one which must
increasingly be taken into account in the formulation of policy and the design of research
work. The way in which results are promulgated will also require careful thought, given the
tendency of the media to overplay possible risks and the public to distrust science. The
disposal of organic wastes on land is an area which has the potential to be incorporated into
a wide range of scare stories, given the closeness of the activities to the food chain. Good
quality, reliable scientific information is a pre-requisite in underpinning the recycling of waste
to land and in ensuring that practices are discontinued where an unacceptable risk exists.
3.3
There are many benefits to be obtained from recycling wastes onto land, the most significant
of which relate to nutrient addition and soil conditioning. One of the interesting findings of
the study is how little the potential benefits are understood even by the farming community
and how the nutrient addition from what is in effect a free source is generally discounted.
Benefits of waste recycling

Fertilising benefits - nutrient addition
3.4
Fertilising can be defined as the application of materials containing nutrients which are
essential to plant growth. Many wastes can contain significant quantities of the following
nutrients:
-
Nitrogen
Phosphorus
Potassium
Magnesium
Calcium
Sulphur
Sodium
N
P
K
Mg
Ca
S
Na
Nitrogen is often present as ammonium-nitrogen (NH4-N) and nitrate (NO3) which are more
readily available for plant uptake, or in a bound organic form requiring mineralisation by
microbial activity in the soil to convert it to plant-available mineral nitrogen. Wastes which
contain significant quantities of these materials can, if rates and timings of application are
matched to the nutrient requirements of the growing crop, act as valuable fertilisers. Trace
elements may also be present in wastes, including iron (Fe), manganese (Mn), copper (Cu),
zinc (Zn), molybdenum (Mb), boron (B), and chloride (Cl). The concentration of these
elements is important because with many of them only low concentrations are acceptable.
3.5
Sewage sludges contain significant amounts of nitrogen and phosphorus, the total amounts
and availability being dependent upon the treatment to which the sludge has been subjected.
3
In general a surface application of liquid digested sludge applied at 50m /ha can supply 100
18

kg of N, and 50kg of P. Figures relating to total and available nutrients in sludge as spread
are given in annex 10.
3.6
Exempt wastes also contain varying amounts of nutrients. Nitrogen is the most common
beneficial element but some wastes such as gypsum will contain very little whilst others, for
example abattoir waste, contain high levels. Other nutrients such as P, K, Mg and S are likely
to be present. For most of the exempted wastes there is little or no evidence from field
experience or trials with which to optimise rates of application to the land to meet crop
requirements for nutrients. This represents a considerable gap in the scientific knowledge
relating to these wastes.
3.7
Agricultural wastes such as manures and slurries contain nitrogen mostly bound to organic
matter. The fertiliser value of manures and slurries varies from farm to farm, and is
dependent upon such factors as the type of livestock, the feed ration and the waste handling
system. Typical loadings of nutrients for various agricultural wastes are shown in the table
below. In order to place the data in context, it should be recognised that most crops take up
less phosphorus than is applied, usually less than 75kg P/ha .
Table 3 - Typical loadings of nutrients for different agricultural wastes (Aitken, 1998)
Application (assuming
3
applied at 50m /ha)
Cattle slurry
Pig slurry
Poultry broiler litter
Sewage sludge
3.8
Plant-available N
(kg)
37
200
1250
100
Phosphate (kg)
Potash (kg)
25
100
850
50
112
135
700
At present in Scotland, the potential fertiliser value of all of the slurry and manure collected
during the winter has been estimated at 21 million (SOAEFD, 1997). However, the amount
of nutrients applied to farmland from livestock manures is low in comparison with the
contribution from inorganic fertilisers, shown below.
Table 4 - Amount of Nutrients Applied to Farmland in Scotland (Aitken, 1998)
Nutrient
Inorganic fertiliser
Livestock manures
Sewage sludge (1991)
Other exempt industrial
wastes (estimate)
3.9
N addition
(t/yr)
212,200 (86%)
33,750 (14%)
290 (0.1%)
1000 - 2000 ?
P2O5 addition
(t/yr)
81,100 (89%)
10,635 (11%)
242 (0.2%)
200 - 500 ?
Composts, unlike peat-based alternatives, contain good quantities of nitrogen, phosphorus,

potassium and other trace elements, but a large proportion of the nutrients in compost are
not immediately available and hence compost can be effective as a slow-release fertiliser.
Soil conditioning effects

3.10
Certain wastes can act as soil conditioners and may add useful amounts of organic matter to
the soil. This improves soil condition by increasing its water holding capacity, reducing
evaporation, improving drainage and aeration. The structure, density, workability and
aggregation of soils all benefit from the addition of organic matter. When soil organic matter
falls below 3% the soil becomes unstable as a growing medium and needs reclamation. For
19

these soils in particular, the application of organic material is important. Wastes with a very
high calcium content such as gypsum can improve the structure of soils which have a high
clay content or which are saline. Wastes such as lime sludge can have a high neutralising
value which makes the waste a useful liming material in acid soils.
3.11
Compost contains a lot of organic matter and the use of composted waste can give
considerable improvement in soil quality as well as reducing the demand for peat based
fertilisers. (The extraction of peat has the potential to damage sensitive ecosystems). Some
research has shown that there may be an increased resistance to disease in plants after
exposure to compost (HDRA, 1998; Roy et al., 1997).
General environmental benefits

3.12
There are many beneficial properties common to all the wastes covered in this review. The
key ones are summarised below:
The use of such wastes as fertilisers should lead to decreased dependence on chemical
fertilisers, and their associated costs. Estimates are that the current economic value of
organic wastes, if considered as a replacement for inorganic fertilisers in Scotland, could
amount to 25M per annum (pers comm, Aitken, 1998);
The application of organic wastes can reduce the requirement for inorganic fertilisers
and their use is thus a potentially more sustainable approach than reliance on continuous
supplies of nitrogen fertilisers manufactured using energy intensive processes, and
phosphate fertilisers and peat soil conditioners derived from finite sources. This
contributes to habitat conservation and protection;
The overall environmental impacts are generally less than for incineration with its
associated problems of emissions in terms of greenhouse effect and ash to be disposed
of, loss of nutrients and energy imbalance and requirement for large centralised facilities;
Assuming there is sufficient land within the vicinity of the site where the waste arises then
the waste can be recycled to land without the need for (and environmental cost of)
transporting a distance to a licensed disposal facility. This reduces the use of fossil fuels
and reduces the costs to the waste producer in dealing with these wastes;
The advantages over landfill are not just economic, although the current disposal charge
of 7 per tonne plus tipping charge is a strong inducement to recycle. The proposed EU
Landfill Directive requires each member state to reduce the quantity of biodegradable
material sent to landfill for disposal, thus increasing the pressure to recycle. The EU waste
hierarchy places recycling above disposal although there is a need to take the full
environmental impact of waste disposal options into consideration. In many situations
recycling of waste to land is the Best Practicable Environmental Option (BPEO). A
BPEO methodology for sewage sludge has been developed (Powlesland and Frost,
1990).
Potential environmental impacts of waste recycling to land

3.13
Waste recycling has several potential environmental impacts on land, air and water. The
best documented impact is on the water environment where the practice can have immediate
effects due to spillage or seepage from stored wastes and during application or soon after
application in the event of rainfall. There are also longer term insidious effects due to diffuse
pollution. The impact on soil is one of the areas where scientific knowledge lags behind the
concerns. Most research has been concentrated in the past on the effects of nutrients and
20

metals in soil whereas current concerns are based on the presence of organic contaminants
and their long term impact. Air pollution is primarily a local nuisance issue or else of more
general concern relating to release of greenhouse gases.
3.14
In SEPAs recently published Environmental Strategy fifteen main environmental issues were
identified. The disposal of organic waste to land has potential to contribute to seven of
these, if carried out in an incorrect manner (SEPA,1998). These are:
3.15
Climate change;
Biodiversity pressure and decline;
Accumulation of toxic chemicals in Scotlands waters;
Endocrine disrupting chemicals - gender benders;
Accumulation of toxic chemicals in soil;
Eutrophication of surface waters; and
Reduced oxygen status in controlled waters.
SEPAs State of the Environment report, published in 1996 (SEPA, 1996) also highlighted
the management of soils, the pollution of watercourses by diffuse pollution sources such as
agricultural run-off, enrichment and eutrophication of surface and marine waters as being key
issues for it to address. The potential environmental impacts and the relevant scientific data
are presented below according to the receiving medium.
Potential impacts on water quality - nutrient enrichment

3.16
Application of organic wastes to land can result in both diffuse and point source pollution of
surface waters and groundwaters. The risk of water pollution is influenced by the manner in
which wastes are applied and the timing of application, with greater potential for pollution if
wastes are applied in close proximity to watercourses, injected close to field drainage
systems or into porous soils above field drainage systems. Injection or surface spreading
onto sloping ground can result in run-off and drainage to surface waters.
3.17
Where farm nutrient plans do not exist, over-application of nitrogen and phosphorus can take
place, especially if the amount of inorganic fertiliser applied is not reduced. Nutrient
enrichment and oxygen depletion are the principal impacts of this over-application.
3.18
There is good documentation of the loss of nutrients over time, especially nitrogen and
phosphorus, through surface run-off, transfer via field drains and leaching, causing
eutrophication in receiving waters. High levels of nitrate in drinking water can be harmful to
humans and animals. Wastes need to be applied under properly controlled conditions in
order to minimise losses. Much nitrogen leaching can be controlled by the timing of
application and the application methodology.
3.19
Poorly managed phosphate inputs can result in phosphorus enrichment of soils and losses to
watercourses where it can lead to the formation of algal blooms. These can result in
depleted oxygen levels in water and eutrophication. Phosphorus concentration is the ratelimiting factor for eutrophication of lentic and inland waters. In severe cases, the algal scum
produced can be toxic to humans and livestock. Although phosphorus tends not to leach
readily from soils, there is concern that phosphorus-saturated soils may leach phosphorus.
There are no restrictions on phosphorus inputs to soils despite evidence of leaching and
eutrophication. Phosphorus is often applied above the limits at which crops can utilise it,
typically taken as 75kg/ha.
3.20
The form in which phosphorus is present is important. The solubility of phosphorus applied in
sewage sludge to achieve 60mg/l extractable phosphorus is far lower than that derived from
21

animal manures. Information is lacking for exempt wastes. Despite the risks associated with
nutrient enrichment if organic wastes are incorrectly applied, the quantities should be placed
in context against the very substantially larger inputs from inorganic fertilisers.
Sewage sludge
3.21
The majority of water pollution incidents arise from runoff from fields where sludge has been
applied in inappropriate weather or where sludge is injected into field drains. Hydraulic
overloading with liquid sludges can lead to anaerobic conditions. Storage of sludge has
caused environmental problems, especially through leaching to groundwaters from dried
sludges. However, nitrogen release from sludges is very low relative to inorganic fertilisers
and the contribution of nitrogen loading to UK soils from sewage sludge is only 1% of the N
potentially spread on farmland from animal wastes (Smith, 1996).
Agricultural waste
3.22
Since 1982, there has been a general upward trend in the number of pollution incidents
associated with the run-off from animal wastes on farmland in Scotland (Scottish Farm
Waste Liaison Group/Scottish Agricultural Pollution Group annual statistics). Over the same
period, there has been a reduction in the number of pollution incidents associated with slurry
stores and silos. The focus on the prevention of pollution from livestock wastes in Scotland
has shifted from the steading (point source) to the field (diffuse source).
3.23
The risk of nitrate leaching is high if livestock wastes with a high percentage of nitrogen in
soluble form are applied when the uptake by crops is low or non-existent (SOAEFD, 1998).
Timing of application is crucial as leaching losses range from 0% if applied in spring to 90%
if applied in autumn. Nitrate leaching following applications of farmyard manure which
contains most of its nitrogen in organic rather than immediately available form is less likely
and thus the timing of the application is not as important.
3.24
Livestock manures and slurries can also be a source of phosphates. Research in Northern
Ireland indicates that excessive applications of slurry are a significant source of phosphate in
loughs (Foy, 1996). Agriculture is believed to be the second largest contributor to
phosphates in freshwaters, after sewage discharges. There is not such a direct association
between phosphate losses and fertiliser additions as there is with nitrates.
Exempt waste
3.25
It is SEPAs experience that the application rate of the waste is seldom if ever matched to the
nutrient needs of the growing crop where exempt wastes are disposed on land. As a result it
is suspected that nutrient leaching occurs widely. There is no published information relating
to this topic in respect of exempt wastes.
Compost
3.26
Studies (Insam and Merschak, 1997) have shown that use of compost causes only minor
increases in nitrate and ammonium in soil water and leachate. The high organic matter
content of compost results in lower concentrations of soluble/available nutrients and heavy
metals. Nitrogen is less readily available from composts than from other organic wastes
(HDRA, 1998), and presents less of a potential impact. Furthermore, compost can reduce
water pollution arising from run-off of applied mineral fertilisers (DoE, 1996).
22

Potential Impacts on water - oxygen depletion
3.27
Certain wastes have a high Biochemical Oxygen Demand (BOD). If such wastes enter
watercourses after application, their breakdown by micro-organisms depletes or totally
removes the available oxygen and can result in ammonium levels which are toxic to many
aquatic animals. Wastes with high BODs added to wet soils can give rise to anaerobic
conditions within the soil resulting in temporary soil oxygen depletion and poor plant growth.
For comparative purposes, a good quality, class A2 river will have a BOD of less than 4 mg/l.
Table 5 - Examples of typical BOD of various wastes
Pollutant
Raw milk
Silage effluent
Pig slurry
Liquid sewage sludge
Cattle slurry
Liquid effluent from slurry stores
Food and drink wastes
3.28
BOD5 (mg/l)
140,000
30,000 - 80,000
20,000 - 30,000
10,000 - 20,000
10,000 - 20,000
1,000 - 2,000
Up to 260,000
Many agricultural wastes such as slurries and silage effluent have very high BOD levels
(SOAEFD, 1998). Manures and slurries also contain suspended solids, which can increase
turbidity in water and smother benthic fauna and flora. All exempt industrial wastes have the
potential to cause water pollution if they drain into a watercourse. Many are highly polluting
with BOD levels as high as 260,000mg/l for some food and drinks wastes (Davis and Rudd,
1998), and pH values as low as 3.4 for pot ale from a distillery.
Potential impacts on soil - potentially toxic elements

3.29
Historically there has been much concern about the heavy metal content of sewage sludge
applied to land, especially where the soils are of low pH. The generic term potentially toxic
elements (PTEs) is used to describe the wide range of metals which originate in sewage.
Effective trade effluent control has ensured that many of the most toxic metals do not now
occur in sewage effluent but metals such as zinc and copper occur in domestic sewage and
need to be managed through controls on sludge spreading. Little is known about the effect of
other elements such as platinum and palladium which originate in car catalysts and enter
sludge through the road drainage system. If uncontrolled, PTEs can build up in the soil
leading to deleterious effects on soil microbial activity, as well as phytotoxic and zootoxic
effects. The quantity of metal applied depends on the source of the sludge. Other PTEs
include sodium and salinity which can affect soil structure and crop growth (Davis and Rudd,
1998). Distillery wastes which contain copper at levels of up to 1000mg/kg dry matter, can
have a beneficial effect on copper-deficient soils.
3.30
In the past, soil was seen as a receptor for wastes and emphasis was placed on ensuring that
contaminants were locked into the soil system thereby avoiding pollution of watercourses or
uptake into the food chain. In recent years more attention has been given to developing a
greater understanding of the sensitivity of those soils to which wastes have been applied and
the effects on soil ecosystem functioning and soil sustainability. Soil microbial biomass is
critical to soil organic matter breakdown and recycling of plant nutrients. McGrath (1994)
carried out a review of the effect of sludge-derived metals on soil microbial processes and
concluded that the aim of a soil protection strategy should ultimately focus on soil fertility.
23

Table 6 - Impacts of PTEs on plant and animal health
Effect
Phytotoxicity
Human food chain via crop uptake
Human food chain via offal from meat from
animals ingesting soil with elevated levels of
PTEs
Animal health
Soil Fertility
Causal element
Zn, Cu, Ni. Possibly Cr
Cd
Cd, Pb
Cu, As, Se, Mo and F

Zn
(from Carrington et al, 1998)
Sewage sludge
3.31
Good trade effluent control and waste minimisation initiatives have reduced metals at source
in industrial waste streams but less pressure has been placed on the producers of exempt
wastes or manufacturers of animal feeds/inorganic fertilisers to minimise levels of metals.
The EU Directive 86/278/EEC sets metal levels to protect soil fertility, plant yield, human and
animal health and allows a lower recommended and a higher mandatory level for each
metal. The UK has adopted the maximum permissible concentration at or near the upper
permitted mandatory levels whereas other states have adopted a more precautionary
approach. These controls do not exist for other wastes applied to land.
3.32
The recent review of the scientific evidence underlying the limits set for PTEs (Carrington et
al, 1998) suggests that the limits for Cu, Ni, Cd, are acceptable for the protection of
plants/animals/humans although the review suggests that further research is required
regarding intake of cadmium in the diet of sheep. However, it is recommended that a revised
limit of 200mg lead/kg would provide additional protection to avoid accumulation in liver and
kidneys. Further data are given in annex 11.
3.33
A recent study (Towers and Paterson, 1997) has shown that the majority of soils in Scotland
which may receive sewage sludge in future have a strong or very strong metal binding
capacity. However, it is essential to maintain the soil pH at current levels for this to be
sustained. The small proportion of sites which have low metal binding capacity should be
precluded from sludge recycling. The risk to groundwater has been found to be high or very
high in only 5% of sites, partly due to the hydrogeology of Scotland where there are few
major aquifers. Movement by surface runoff may be more of a problem. Little information
has been reported on the impact of sludge application on metal losses to surface and
groundwaters in Scotland.
Agricultural wastes
3.34
Manures and slurries can contain high levels of PTEs, particularly zinc and copper. The
quantities of manures and slurries added to farmland are such that these additions can be
appreciable. For example, the manure from fattening pigs may contain 300-2,000 mg Cu per
kg in the dry solids and 200 - 1500 mg Zn per kg (mean 600) (MAFF, 1985). These levels
may even be exceeded if the diets of fattening pigs are supplemented with Zn (Smith, 1996).
The application of these wastes to uncultivated grazing land has the potential for greater
accumulation of metals and pathogens in the upper layers. For comparative purposes, the
maximum levels of zinc and copper which can be applied in sewage sludges is 15 kg/ha and
7.5 hg/ha (annual rate of PTE addition over a 10 year period).
24

Exempt wastes
3.35
Certain exempt wastes can contain high levels of metals, for example copper in distillery
wastes. Little information exists on the overall PTE levels in exempt wastes because of the
lack of analytical data. The origin of PTEs which are loaded on to soils are given below in
data for England and Wales. This shows the percentage loading by source for selected
heavy metals. The importance of atmospheric deposition should be noted, putting the data
into context.
Table 7 - The percentage of PTEs deposited on soil, given by origin (figures for England and
Wales)
PTE
Source
Sewage sludge
Animal manures
Atmospheric deposition
Industrial by products
and wastes
Inorganic fertilisers
Zn
Cr
Cu
Pb
Cd
10
45
35
19
17
45
24
18
10
70
7
14
50
40
16
20
(from Carrington et al, 1998)
Potential impacts on soil - organic contaminants

General
3.36
3.37
Sewage sludges and certain exempt wastes may contain volatile organic compounds (VOCs)
such as benzene, chlorinated benzenes, chloroform, cyclohexane, tetracholoroethylene,
toluenes and xylenes. Endocrine disrupting chemicals, phthalates, phenols and polyaromatic
hydrocarbons can also occur in wastes, as can surfactants from detergents and persistent
trace organics. Although at low levels in the wastes, these will significantly elevate levels in
soil. The problems associated with the presence of organic compounds include:
leaching losses;
persistence in the soil; and
toxicity to grazing animals and soil biomass.

It is thought that the main risk with respect to organic contaminants is from surface
application of wastes to grassland and transfer to tissue fat and milk of grazing livestock. It
is considered that the detergent residues and plasticising agents represent the most
significant sources of organic contaminants in sludge (Carrington et al, 1998), although these
contaminants degrade quickly in aerobic soil environment, having a half-life of several days.
However, in general, the effects of these compounds on soil properties and organisms are
not well known. Although the potential risk posed by these organic compounds is thought to
be low, the uncertainty of their fate and rate of breakdown and the lack of current UK
standards in soils demonstrates a clear need for further research.
Exempt wastes
3.38
The data for exempt wastes are very sparse. It is known that waste with a high BOD can
give rise to anaerobic conditions within soils. Other wastes such as papermill sludge, can
25

result in limited benefit but due to the high carbon:nitrate ratios can result in nitrogen being
locked-up in the soil. Consequently, papermill wastes require prior treatment or need
organic matter to be added at the time of spreading in order to benefit the soil. Fungicides
and bactericides are used in many industries, including paper, and are likely to be present in
paper wastes. Research on organic contaminants in exempt wastes is reviewed by (Davis
and Rudd, 1998).
Agricultural waste
3.39
Some veterinary products from agricultural practices and their metabolites can have
unwelcome environmental effects when excreted by farm animals (RCEP, 1996). For
example, the widely-used anti-parasitic drug, ivermectin, is persistent and residues in the
faeces of treated livestock reduce the number and variety of dung beetles and insects,
affecting in turn insect-eating birds and mammals.
Potential impacts on air quality

General
3.40
Spreading organic waste on land results in the release of various gases to the atmosphere,
including ammonia, methane and nitrous oxide. The extent of release depends not only on
the type of waste, but on the timing and method of application. Volatilisation and
atmospheric losses can be reduced by injection of wastes or avoiding sprays and aerosols,
for example by using bandspreaders. The use of rainguns should be avoided.
3.41
Ammonia emissions can result in detrimental effects on the environment, including:

acidification of the soil through deposition of ammonia and ultimate transformation to
nitrate;
addition of nitrogen by deposition to upland areas, which may result in vegetation changes
or increased nitrate leaching losses to watercourses; and
promotion of increased sulphur dioxide deposition by atmospheric chemical reactions with
ammonia.
Methane is the second most significant anthropogenic greenhouse gas. Although its
atmospheric concentration is much less than carbon dioxide, its impact as a greenhouse gas
is significantly greater. Nitrous oxide has a global warming potential 320 times higher than
carbon dioxide on a 100-year timescale.
Sewage sludge
3.42
Atmospheric emissions from sludge depend on the type of sludge. For example lime
stabilised sludges have a significantly reduced ammonia content. Ammonia emissions from
sludge-treated soils are small compared with total ammonia losses from livestock wastes.
Injection or immediate incorporation prevents volatilization although the losses of nitrous
oxide can increase when sludge is injected.
Agricultural waste
3.43
Ammonia losses during the spreading of manures and slurries can be considerable,
particularly when waste is applied in the spring or summer, when all the ammonium nitrogen
could be lost (Aitken, 1996). Some 90% of the UKs emissions of ammonia are believed to
come from agriculture (IGER et al, 1996). Emissions in Scotland are mainly derived from the
26

volatilisation of ammonium compounds from farm manures. It is estimated that, of the total
of 70,000 tonnes of ammonia emitted in Scotland each year from agriculture, excretion
during grazing is the largest source (c. 24,500 t/yr), followed by emissions during spreading
(c. 21,000 t/yr) and storage of wastes (c. 14,000 t/yr) (Aitken, 1996). Poultry produce
substantially more ammonia than pigs and cattle (SOAEFD, 1997). Such atmospheric
emission results in the loss of a valuable nutrient.
3.44
In the UK, agriculture activity contributes 32% of the total anthropogenic methane emissions,
which is the second most significant contribution after landfills, with production from cattle
being the largest agricultural source. Methane is produced during storage and treatment of
agricultural wastes especially in liquid systems which encourage anaerobic conditions and
produce substantial amounts of methane. Solid waste (manure) management produces little
or no methane emissions.
Exempt wastes
3.45
Excess nitrogen applied to the soil and not taken up by the crop can be lost by denitrification
to the atmosphere as nitrogen and nitrous oxide gas in heavy textured soils during wet
conditions. Ammonia may be volatilised if present in the waste (Davis and Rudd, 1998).
Little information is available on atmospheric emissions from these wastes.
Potential impacts on animal and human health

3.46
Sewage sludges, some exempt wastes and agricultural wastes may all contain pathogens
posing potential risks to receptors such as humans, crops and grazing animals. The
significance of these risks is dependent on the potential for pathogens to occur in the waste
stream, the decay rates subsequent to application, the presence or absence of barriers to
transmission (for example treatment or land use restrictions) and the sensitivity of the
receptors.
3.47
The pathogens of concern include bacteria, viruses, and protozoa. Some of the particular
oganisms are:
Escherischia coli including E.coli 0157;

Salmonella spp.;
Cryptosporidium;
Campylobacter;
Giardia; and
Cytopathic enteroviruses and rotaviruses.
A summary of the potential risks from pathogens associated with the different wastes is given
in annex 12. Further details relating to these pathogens and occurrence in organic wastes is
given in (Davis et al, 1998). Many pathogens are host specific whereas others such as E.coli
0157 and campylobacter are freely transmissible between man and animals. Such zoonotic
pathogens present problems in the control of animal and public health. (Davis and Rudd,
1998).
Sewage sludge
3.48
The effects of the various pathogens known to be found in sewage sludge are well
documented for example Carrington et al, 1998, and Smith 1996 which includes a detailed
review of occurrence of pathogens in sludge, fate of pathogens in sewage and sewage
27

treatment, survival in soils and on vegetation, movement in soil and risks to water sources,
constraints on planting, and effects on natural ecosystems. It is important to note that
despite the potential risks, there are no reported incidences of links between disease and the
application of sewage sludge to land (RCEP, 1996). This view is supported by Professor
Pennington in the Scottish context (pers comm, Pennington, 1998).
3.49
The approach adopted by the Code of Practice for the Agricultural Use of Sewage Sludge
relies on a break in the cycles of transmission from pathogens in sludge through
contamination of soil and water to food, animals, crops and humans. This is achieved by
sludge treatment to significantly reduce pathogens and restriction of land use after
application. Details of this are summarised in annex 13. Definitions of processes effective in
reducing pathogens are based upon a 90% reduction in numbers of salmonella and 99%
reduction in coliforms. In addition a further barrier is provided by specifying constraints on
land use to allow pathogens to decay further ie by specifying waiting periods between the
application of treated sludge and resumption of grazing or cropping. Co-ordination of sludge
applications with planting and prohibition in applying it to growing fruit and vegetable crops
provides further effective barriers.
3.50
A review has recently been undertaken of the scientific principles underlying the approach
used by the Code (Carrington et al, 1998) and the adequacy of current controls for other
organisms not considered in the development of the Code. In general the earlier approach is
considered to be appropriate . However, the review identified several issues which need to
be resolved, namely:
The need for the terms pasteurisation and stabilisation in the context of sludge
treatment to be defined in terms of efficiency of microbial removal;
The need to describe treatment parameters;
The need for definitive information on the survival of some of the more recently
identified pathogens, including Listeria monocytogenes, E.coli 0157:H7, Giardia,
Cryptosporidium and viruses, particularly during liquid storage of sludge at low
temperatures, and following application. It has been noted that more sensitive
methods are required for detecting and measuring levels of bacteria and viruses
following sludge application. Research cited has shown that L. monocytegenes can
survive for eight weeks. Research is currently being carried out into the survivability
of pathogenic organisms contained in sewage sludge applied to land. This will
inform the effectiveness of the legislation and PEPFAA Code.
It is currently
believed that E.coli may be able to survive 180 days and may in fact be able to
multiply given the right conditions in the soil (pers comm, The Scottish Office).
These proposed studies would inform the controls on the land use management after
application of the sludge; and
The need for a review of the effectiveness of sludge treatment processes .
3.51
The Code has controls in place to prevent the transfer of pathogens to potatoes and
vegetables which are eaten raw.
However, no such controls are in place for other
vegetables brought into the home. There is also concern that inappropriate use of sewage
sludge could lead to the infection of livestock, on previously clean farms, with bacterial or
parasitic organisms (pers comm, The Scottish Office). This could lead to zoonotic disease
cycles being established with implications for human health.
3.52
The discussion so far has concentrated on the disposal of sewage sludge from treatment
works. Sludge from septic tanks is also collected and disposed of on land. This sludge has
been subject to a far lesser degree of treatment and can be aesthetically offensive. It is, in
effect, untreated and there is a widely held view that spreading it on land should be
prohibited.
28

Exempt wastes
3.53
Due to the varied nature of these wastes the potential health impacts also vary considerably.
Whilst many of the impacts will be similar to those from sewage sludges which are relatively
well researched and understood, other potential impacts have received little or no study and
are therefore not well understood. Pathogen content is variable depending on which carriers
exist in the community which has contributed to their existence. However, occurrence may
be sporadic and routine examination of each waste is considered unrealistic, due primarily to
insufficiently sensitive detection techniques (Davis and Rudd, 1998). A risk assessment
approach is more appropriate, based on a knowledge of the pathogens, the level of
treatment, the waste outlet and land use.
3.54
The approach put forward in Carrington et al 1998 is that wastes should be categorised. High
risk categories would include faecal-containing material such as abattoir waste. Such wastes
should be subsurface injected and incorporated into the soils. Medium risk wastes which may
contain pathogens include wastes from food industries, compost, waste soil and tannery
wastes. Low risk wastes include those from beverage industries, paper and textile waste and
wood as well as green plant waste. Paucity of data again precludes informed commentary
on the actual risk.
Agricultural wastes
3.55
In Scotland, 96% of the organic waste spread on land is agricultural in origin, mainly manures
and slurries. On the whole, these wastes are applied without treatment to remove
pathogens, and routes for faecal contamination of food animals are always going to be
present because of natural defecation. In addition, the restrictions on the application to land
of agricultural wastes are less stringent than other wastes, particularly sewage sludge.
Manures and slurries present a greater risk because of the large volumes, compared with
other wastes, for possible contamination of meat, poultry, dairy products and vegetables.
3.56
The infection route for pathogens that are excreted in faeces is generally by mouth. Infection
tends to spread in crowded situations and as a result of poor hygiene. Therefore, in an
agricultural unit when infection with a specific pathogen occurs, most members of the herd
will become infected (Carrington et al, 1998). In many cases, manures and slurries are
spread on the same farm they originated from. While this practice does not reduce the risk to
humans or wild animals, the resident animal population is likely to have developed some
degree of immunity and consequently is less likely to become re-infected. Many of those
interviewed during this study were concerned to ensure that farms are kept as closed cycles
for potential pathogens through not importing wastes from other sources.
3.57
It is believed that E.coli 0157 is present in 2% of the national herd (Jenkinson, 1996; Ball,
1997) although it is not easy to identify animal infection as there is no visible illness.
Available evidence suggests that the most significant source of the spread of infection is via
animal faeces from infected livestock (Pennington, 1997) and E.coli can remain viable for
over 70 days on grassland (Jenkinson, 1996). Although there is evidence of water, crop and
vegetable contamination from E.coli 0157, the impact of spreading manure and slurry on
land has not been fully evaluated and the available evidence is conflicting. It is not
sufficiently strong to suggest that spreading of such wastes should be prohibited (Pennington,
1997). However, there is a need to evaluate slurry treatment methods and due care should
be exercised in the use of untreated manure and slurry in the vicinity of crops, fruits or
vegetables and near sources of private and potentially untreated water supplies.
29

3.58
Cryptosporidium is present in agricultural wastes and is difficult to destroy although it can be

reduced by composting or by storage of manures. Salmonella spp. can survive several
months in stored slurry, and can survive up to 100 days in slurry applied to grass (Carrington
et al, 1998).
Compost
3.59
Organic wastes which contain materials of animal origin may contain a number of human
pathogens, such as E.coli 0157. When applied to land, a transmission pathway exists for the
transfer of pathogens to crops, which when eaten raw, can pose a risk. Work is currently
being carried out at the US Department of Agriculture to consider pathogen destruction in
composting manures, with attention being given to the variety of composting techniques used
by farmers (Gilbert, 1998a). Most wastes of plant origin contain only plant pathogens. A
notable exception is the fungus Aspergillus fumigatus. This is particularly associated with
composting plant materials because it is capable of both degrading cellulose and surviving at
o
temperatures of up to 60 C. If inhaled as a bioaerosol, it can cause allergies, inflammation
and infections in humans (CA, 1998).
Potential impacts on plant health

3.60
Data on plant health issues are sparse in relation to all the wastes. Certain codes of practice
or legislation relate to managing known pathogenic issues related to plant health but in
general there is little published information. There is no indication at present that sewage
sludge is a vector in the transmission of pathogens other than potato cyst nematodes. This is
controlled by the provisions of the Code of Practice for Agricultural Use of Sewage Sludge
(DoE, 1989). Potato cyst nematodes can survive the sewage treatment process and hence
the only effective barrier to transmission is an absolute prohibition on the application of
sewage sludge to land which is certified free from the nematode. Sewage sludge is not
implicated in the spread of brown rot in potatoes although there is circumstantial evidence
that effluent from sewage overflows has led to outbreaks.
3.61
The risks associated with the application of agricultural and horticultural wastes are not well
documented. (pers comm, The Scottish Office, 1998). This is particularly so with waste of
vegetable origin but few data are available. Vegetable wastes are not within the remit of this
study. Blood and gut contents are not thought to cause a problem in plant health terms but
again there is a paucity of data as far as exempt wastes are concerned.
Farm slurry spreading is not perceived to be a risk to plant health because it usually takes
place on the farm of origin. It is possible that potato cyst nematode may pass through the
animal gut if it is present in feed and therefore be contained in slurry. Composting may not
kill all plant diseases, especially those of vegetable origin but few data are available.
3.62
Odour nuisance
3.63
Odour as such is not a health issue. However in terms of public perception it is often linked
with alleged health complaints and must not be dismissed. Odour can travel long distances
and cause considerable discontent and distress to a receiving population. Odour emissions
have an instantaneous effect, it is usually easy to trace their source and there is a good
correlation between odour concentration and distance from the source. Odour is classified as
a nuisance by local authorities and odour complaints are usually dealt with by Environmental
Health departments.
3.64
Application of undigested liquid sewage sludge is often associated with odour complaints.
However, digestion significantly reduces odours and thermal drying does so to an even
30

greater extent. However, there are many variables and sludge odours may be singular for
particular sludges and can depend on age of sludge before being dried.
3.65
Good practice in terms of application can reduce odour, for example using appropriate
equipment such as low trajectory irrigation if surface spread. The addition of oxidising agents
can also have a part to play whilst soil injection significantly reduces odour problems.
Storage of dried sludges has to be managed carefully to avoid odour nuisance.
3.66
The first environmental impact of livestock production is almost always complaints about
odour. Pig and poultry farms produce the most complaints about odour (SOAEFD, 1997).
Although there is no evidence of an established correlation between odour and ammonia
(and other) emissions from agricultural waste, some techniques that reduce ammonia
emissions will also reduce odours, though not in the same proportions. However, unless there
is some legal obligation to control ammonia or other gases, as in the Netherlands, odour
control is a unlikely to be a high priority for farmers.
3.67
The application of many exempt wastes to land results in the release to atmosphere of
compounds which are particularly odorous giving nuisance to surrounding land occupiers and
users. Several types of exempt wastes are associated with odour problems, in particular
stomach contents, molasses wastes, and anaerobic paper crumble. The odours produced by
these wastes are slightly different to those produced by agricultural wastes and the public
appears to be less tolerant towards these odours. The practice of storage on farm prior to
spreading can also cause problems if the wastes turn anaerobic. This gives odour nuisance
when the crust is broken.
3.68
A summary of the benefits and disbenefits offered by the wastes reviewed in this report is
given in annex 14.
Summary and Issues

1.
If applied correctly organic wastes can reduce the demand for inorganic fertilisers
and can have beneficial fertilising effects.
2.
There are other beneficial environmental effects such as reduced resource demand,
soil conditioning and improvement and, indirectly, habitat conservation.
3.
The potential for both point source and diffuse pollution of watercourses is relatively
high, due to the high BOD of some exempt wastes and agricultural wastes,
inappropriate timing of application, or injection over field drains. The large volumes
of agricultural wastes going to land give rise to most water pollution incidents.
4.
The potential for pollution arising from over-application of nitrogen and phosphorus is
high, particularly in the absence of farm nutrient plans and if the amount of inorganic
fertiliser applied is not reduced in proportion with the amounts added from organic
wastes. However, the amounts of nitrogen and phosphorus applied from sewage
sludge and exempt wastes are small when set against the amounts applied from
agricultural wastes and inorganic fertilisers.
5.
Potentially valuable nitrogen can be lost by volatilisation and incentives have been
suggested for farmers to reduce volatilisation by using appropriate application
techniques. Emissions of gases of anthropogenic origin such as methane and
ammonia are of concern because of their respective contributions to global warming
and acidification.
31

6.
Sewage sludge has been the focus of considerable attention and scientific research
and a comparison of the levels of nutrients and PTEs applied to land indicates that
the input from sewage sludge is small relative to agricultural wastes. Input from
exempt wastes is not fully known.
7.
The extent of PTE accumulation in soils is not known, nor are the actual effects on
soil fertility.
8.
Emphasis on source reduction currently applies only to PTEs in sewage sludges and
not other wastes nor to other hazards.
9.
Whilst there is considerable understanding of the fate and impacts of nutrients and
PTEs in sewage sludges, there is a paucity of data pertaining to the other wastes.
There is very limited understanding of the effects on the receiving soil of organic
chemicals and endocrine disrupting chemicals in all wastes.
10.
Little attention is given to soil processes, including changes in soil status, pH, metal
mobility and effects of waste applications.
11.
Due to regulatory controls, the risk of pathogen transmission from sewage sludge
application is relatively low although tighter controls such as the phasing out of
undigested sludges on land will further reduce risk. However, the pathogen-related
risks associated with exempt wastes or agricultural wastes are not quantified or fully
understood. Pathogen related risks in sewage sludge are well documented in respect
of some organisms but further research may be justified into the behaviour and fate
of pathogens of more recent interest such as E.coli 0157.
12.
Problems associated with odour should not be overlooked as these are often the
major nuisance factor for local communities and a cause for concern. Some exempt
wastes may be particularly odourous. In all cases waste treatment can reduce odour
problems. Complaints due to odour are difficult to resolve due to the subjective
nature of the problem.
13.
Much useful guidance on good practice exists in the PEPFAA Code but is either
unknown or often not followed by those concerned.
14.
Further research is necessary into the effects of mixing wastes prior to application or
applying different wastes in the same growing season on the same land. This
research should cover the fate of pathogens, PTEs and other organic contaminants.
32

4.
Current legislation/regulation, guidance and control

mechanisms
4.1
There is a considerable number of pieces of legislation relating to the practice of applying

organic wastes on land. An overview is presented below.
Sewage sludge
Legislation and regulations
Sludge (Use in Agriculture) Regulations 1989
4.2
The Sludge (Use in Agriculture) Regulations 1989, as amended, place restrictions on the
application of sewage sludge to agricultural land and place duties upon the sludge producer,
operator and occupier of the land with respect to sludge use. The 1989 Regulations were
introduced to control the rate of accumulation of potentially toxic elements (PTEs) in soil
following the application of sludge to land, and to prevent the transmission of pathogens into
the food chain. They transpose the provisions of Council Directive 86/278/EEC into UK
legislation.
The regulations place legislative requirements on the sludge producer,
contractor, the farmer or land owner to ensure that sewage sludges recycled to land are done
so in an environmentally sound and sustainable manner. These requirements are found in:
The Sludge (Use in Agriculture) Regulations, 1989;
The Sludge (Use in Agriculture) (Amendment) Regulations, 1990; and
The Environment Act 1995 (Consequential and Transitional Provisions) (Scotland)
Regulations, 1996.
4.3
Sludge and septic tank sludge are both defined in the 1989 regulations. The Regulations
apply to sludges from public Sewage Treatment Works and from private Sewage Treatment
Works. The Controlled Waste Regulations, 1992 7(1) detail wastes that are not treated as
industrial or commercial waste for the purposes of Part II of the Environmental Protection Act
1990. The result of this is that sludge which is used in accordance with The Sludge (Use in
Agriculture) Regulations, 1989, is not controlled waste.
4.4
The Sludge (Use in Agriculture) Regulations, 1989, set requirements for, amongst other
things: sludge and soil testing; the limiting of PTEs to certain specified levels; cropping and
grazing; protection of soil and groundwater; and taking crop nutrient requirements into
consideration. The regulations restrict the planting, grazing and harvesting of certain crops
following the application of sludge. Sludge producers are required to analyse field soils and
sludges prior to application and to maintain detailed records of applications of all sludge to
farmland.
4.5
There are no statutory Codes or Regulations that cover the use of sewage sludge in forestry
or land reclamation, although a Manual of Good Practice exists for each outlet
(Wolstenholme et al, 1992, Wolstenholme and Hall, 1996).
Regulation
4.6
SEPAs principal role is in the auditing of the registers held by sludge producers, with
supplementary field inspection and analysis, as appropriate. The water authorities maintain
the registers which hold the analytical information.
4.7
In the event of a spreading activity resulting in sewage sludge entering a watercourse, SEPA
has ultimate recourse to Section 30F of The Control Of Pollution Act 1974 (as amended),
33

under which it is an offence if a person causes or knowingly permits any poisonous noxious
or polluting matter or any solid waste matter to enter any controlled waters.
Guidance
4.8
The Regulations are supplemented by a non-statutory UK Code of Practice issued by the

Department of the Environment, Transport and the Regions (DETR): Code of Practice for
nd
Agricultural Use of Sewage Sludge, 2 Edition, May 1996. This Code contains all the
statutory requirements of the Sludge Regulations with more guidance on certain PTEs and
specifications of sludge treatment processes not covered in the Statutory Regulations. Whilst
certain aspects are not statutory, it is considered that any infringement or pollution incident
resulting from failure to follow the Code would be difficult to defend. The Code of Practice
does not define storage requirements.
4.9
Additional guidance is provided by the SAC Technical Note (T450) on Use of sewage sludge
on agricultural land. This provides information on the nutrient content of both treated and
untreated sludges, potentially toxic elements and pathogenic substances which may be
contained within the sludge.
4.10
Guidance on storage and spreading is given in The Prevention of Environmental Pollution

from Agricultural Activity (PEPFAA) Code of Good Practice (1997). This was first
published by The Scottish Office in 1992, revised in 1997 and covers the main agricultural
activities which can give rise to pollution. It also outlines management practices which can
be adopted to avoid, or at least minimise, the risk of causing pollution. The PEPFAA Code is
not statutory, although certain sections have a statutory basis for example under Section 30
of the Control of Pollution Act 1974 (as amended). Thus, although contravention of the
PEPFAA Code does not constitute an offence, it may be taken into account in any legal
proceedings involving a water pollution offence. However, compliance with the PEPFAA
Code will not in itself be a defence in the event of water pollution occurring. It is intended as
a practical guide to be used by farmers and all parties involved in agricultural activities, and
includes information on non-agriculturally derived wastes and other organic wastes as well as
agricultural wastes, sheep dips, pesticides and disposal of animal carcasses. It summarises
statutory requirements for the various wastes and activities, and also provides general advice
and guidance. Relatively little attention is given to cake sludges and thermally dried sludges
with greater focus on liquid wastes. Its key aspects are that it:
encourages the use of Farm Waste Management Plans which should take account of any
imported wastes, to ensure that application of nutrients match crop requirements;
provides maximum surface application rates and recommended injection depths for liquid
wastes;
strongly recommends the analysis of PTEs all non-agricultural wastes, not just sewage
sludges;
gives guidance to help assess land suitability (in terms of proximity to watercourse, water
supply sources, field drains, sloping ground, field drains and proximity to dwellings), soil
capability and fertility.
4.11
Farmers participating in agri-environment schemes run by The Scottish Office are obliged to
follow the PEPFAA Code in order to qualify for payment. This scheme is considered to work
well. Voluntary Farm Assurance schemes run and encouraged by the private sector could
work in a similar way.
34

Exempt wastes to land
Legislation and regulations
Waste Management Licensing Regulations 1994
4.12
The Waste Management Licensing Regulations 1994 (WMLR94), made under the
Environmental Protection Act 1990 (EPA 90), exempt the application of certain nonagricultural wastes to agricultural land from the need to have a waste management licence.
Exemptions are subject to the provision that specified conditions are complied with and that
the activity meets the relevant objectives. The objectives are to ensure that the waste is
recovered without endangering human health and without using processes or methods which
could harm the environment and, in particular, without:
risk to water, air, soil, plants or animals; or
causing nuisance through noise or odours; or
adversely affecting the countryside or places of special interest.
4.13
The most commonly used exemption is the spreading of wastes on agricultural land in
accordance with paragraph 7 of Schedule 3 of the WMLR94. The application of wastes
listed in Table 2 of paragraph 7 are exempt from licensing only if:
the activity in question results in benefit to agriculture or ecological improvement
(although no definition is given for agricultural benefit or ecological improvement);
no more than 250 tonnes, or in the case of inland dredgings from inland waters, 5,000
tonnes of waste per hectare, are spread on the land in any period of twelve months;
specified information is provided prior to application to agricultural land
4.14
Paragraph 7 also permits a more limited range of wastes (waste soil, compost, waste wood,
bark or other plant matter) to be spread on specified non-agricultural land (operational land of
a railway, light railway, internal drainage board land or land which is a forest, woodland, park,
garden, verge, landscaped area, sports ground, recreation ground, churchyard or cemetery).
All exemptions are summarised in annex 7.
4.15
Paragraph 8 exempts the spreading of sludge on non-agricultural land only if it results in

ecological improvement and does not cause levels of PTEs in the soils in excess of those
given in Schedule 2 of the Sludge (Use in Agriculture) Regulations 1989 (as amended).
However, there is no requirement for levels of PTEs to be considered when paragraph 7
wastes are applied to agricultural land. In addition there is no definition of what constitutes
ecological improvements. This causes difficulties in determining whether or not the activity
should go ahead and in taking any enforcement action. Davis and Rudd (1998) provide
useful definitions in their report but these cannot be incorporated into UK domestic legislation
as there is no definition of agricultural improvement/ecological benefit in the Waste
Framework Directive 75/442/EEC as amended by 91/16/EEC.
4.16
If not specifically exempted, a waste management licence will be required for applications of
wastes to land. Guidance on the licensing of waste management facilities is provided in
Waste Management Paper No 4 (DoE 1994). SEPA is the enforcing authority in Scotland
for the Waste Management Licensing Regulations 1994. Composted municipal waste may
be the subject of an application for an exemption if it is to be spread on land or sold.
35

Regulation
4.17
A spreading activity is only exempt if certain particulars relating to the proposed operation
are supplied to SEPA in advance. The details that must be supplied to SEPA include a waste
description, including the process from which it arose, estimated quantity of the waste and
dates and location of the spreading. Where there is to be regular or frequent spreading of
wastes of a similar composition, the operator must supply details to SEPA every six months.
If the waste to be spread is of a different description then particulars must be supplied in
advance for that spreading.
4.18
The exempt activity must be conducted either with the consent of the occupier of the land
where the activity is carried on, or the person carrying out the activity must be otherwise
entitled to do so. In practice, some confusion exists as to the relative responsibilities of
those involved in the activity although it is clear that duty of care applies throughout the
chain of those handling the waste. This will involve all concerned with the production, import,
keeping, storage, transport, treatment, recycling, disposal or brokerage for the waste. This
almost certainly includes the occupier of the land, and they would fall within the provisions of
the Duty of Care Regulations if they had given permission for the activity to take place. Any
necessary enforcement action would be taken against one or more persons who were
responsible for the waste, according to the circumstances of the case. In practice, in most
cases, it is taken against the contractor.
4.19
The exemptions from licensing also include the temporary storage in secure containers or
lagoons on land where the material is due to be spread. This is not the case for septic tank
sludge, which may be kept elsewhere in a secure container or lagoon.
4.20
Although the Regulations make provision for exemption from licensing, they do not provide
exemption from prosecution. Should any of the conditions be breached, the exemption will
no longer apply and an offence under s33 of EPA 90 may have been committed (prohibition
on unauthorised or harmful deposit, treatment or deposit etc. of waste). Should the terms of
the exemption be met, but the activity results in pollution an offence may have been
committed under s33 of EPA90 or, in the case of water pollution, Section 30F of The Control
Of Pollution Act 1974 (as amended): causing or knowingly permitting any poisonous noxious
or polluting matter or any solid waste matter to enter any controlled waters.
4.21
The DoE Circular 11/94 (DoE, 1994) (SO (10/94)) discusses the requirements in the WMLR
1994 for landspreading of exempted wastes and states that in order to keep within the terms
of the exemption it is essential to establish on the basis of Properly Qualified Advice what
application rate is appropriate for each waste material, each soil and each site. The source of
the Properly Qualified Advice is not specified and is dependent on the type of waste and land
involved in the activity. There is, however, no statutory requirement to measure the level of
PTEs as there is with sewage sludge. Textile wastes, for example, may contain sheep dip
residues.
36

Guidance
4.22
There is no Government code of practice covering the spreading of wastes in accordance

with the exemptions. However, SAC Technical Note (T459) provides guidance, and as with
other wastes, the PEPFAA code should be followed although this is not statutory. In addition,
certain industries have produced their own guidance. For example the Code of Practice on
the Landspreading of Paper Mill sludges was developed by invited experts. This takes a
precautionary approach and includes appropriate testing regimes for paper mill sludges
which quantifies the benefits (pers comm, Paper Federation, 1998).
4.23
Producers of wastes which are spread in accordance with the exemptions are concerned that
the exemption conditions do not provide tight enough controls to give quality assurance
sufficient to establish public confidence in the activities (pers comm, Paper Federation,
1998). There is, therefore, a need to develop codes of practice/legislation to ensure that
landspreading is carried out responsibly and effectively.
Agricultural wastes
Legislative powers and responsibilities
4.24
Currently, wastes generated on-farm (such as livestock slurries and manures) are excluded
from the definition of controlled waste and are, therefore, not subject to the associated
statutory controls with respect to on-farm disposal. This is currently under consideration and
a set of UK regulations is being drafted for consultation in the near future.
4.25
Agricultural wastes which are imported onto farms from premises that are not classed as
agricultural, such as livestock marts, do fall within the definition of controlled waste and are
therefore subject to the associated statutory controls. Thus, a waste management licence is
required for the spreading of these wastes onto land and farmers/landowners are obligated
by the Duty of Care. It is known that such licences are often not obtained. SEPA is the lead
authority for enforcing the Waste Management Licensing Regulations 1994 in Scotland.
4.26
Under the Control of Pollution (Silage, Slurry and Agricultural Fuel Oil) (Scotland)
Regulations 1991, slurry is defined as the excreta produced by livestock in yards or
buildings, which is often mixed with bedding, feed residues, rainwater and washings. The
Regulations specify minimum standards for installations used for the storage of slurry. In the
event of a pollution incident arising from the escape of slurry or as a result of a spreading
activity SEPA may take action under Section 30F of The Control Of Pollution Act 1974
(as amended), which provides that it is an offence if a person causes or knowingly permits
any poisonous noxious or polluting matter or any solid waste matter to enter any controlled
waters. SEPA may also serve Notice under the Regulations to require improvements to be
made to installations which pose a risk.
Nitrate vulnerable zones

4.27
EC controls on water pollution caused by levels of nitrate from agricultural sources, were
introduced by Directive 91/676/EEC. This was mainly concerned with reducing existing
pollution and preventing further pollution from such sources. Member states are required,
amongst other things, to detail nitrate vulnerable zones (NVZs) and take measures to protect
these zones by establishing action programmes for them and to establish a voluntary code of
good agricultural practice. These provisions were transposed into domestic legislation by
the Protection of Water Against Agricultural Nitrate Pollution (Scotland) Regulations 1996.
These regulations also place a duty on SEPA to monitor surface and groundwater
37

abstractions and to review the eutrophic state of fresh, estuarial and coastal waters, every
four years. They also require the Secretary of State to produce action programmes, but
place a duty on SEPA to provide all necessary information for this. One nitrate vulnerable
zone has been set up in Scotland, at Balmalcolm, covering 12 farms. SEPA has also
recommended that two further NVZs be established, namely the Ythan catchment and at
Kinnesswood.
Agri-environment schemes
4.28
There are currently a number of these schemes being administered by the Scottish Office.
The three with most relevance to organic wastes being applied to land are the
Environmentally Sensitive Areas Scheme (ESA), the Countryside Premium Scheme (CPS)
and the Organic Aid Scheme (OAS). There are plans to merge the three schemes by the
year 2000.
4.29
The ESA scheme was introduced by the Agriculture Act 1986 and there are currently 10
ESAs throughout Scotland. Participation in the scheme is voluntary with landowners signing
a 10 year agreement with the option to leave after 5 years. The scheme provides grants for
agricultural holdings employing specific measures to promote conservation and good
agricultural practice as recommended in the PEPFAA code.
4.30
The CPS started in 1997 and applies outwith environmentally sensitive areas. Again,
membership is voluntary, but lasts for 10 years, although there is an opportunity to leave
after 5. In this case, an audit is carried out of the agricultural premises before membership is
granted, with grants being targeted on specific management options, such as stock disposal
or management of water margin. This will then require the farmer or crofter to follow good
agricultural practice throughout the farm as defined and recommended in the PEPFAA Code.
4.31
The smaller scheme, OAS, came into operation in 1994. This scheme is voluntary, with a
five year membership. In this case, financial incentives are provided for agricultural
practices to be changed, in whole or in part, to organic methods of production.
Animal wastes
4.32
The main European legislation governing the management of animal wastes is Directive 90/
667/EEC and Decision 92/562/ EEC. This places control with the veterinary authorities
within the member states and rules are laid down for the disposal and processing of animal
waste, for placing it on the market and for preventing pathogens in animal feedstuffs.
Controls on segregation and storage of the wastes are put in place by separate directives on
hygiene.
4.33
Animal waste is defined, within Directive 90/667/EEC as carcasses or parts of animals or

fish, or products of animal origin not intended for direct human consumption, with the
exception of animal excreta and catering waste.
4.34
Directive 90/667/EEC is implemented in Great Britain by the Animal By-Products Order

1992 as amended, which is enabled by the Animal Health Act 1981. The Animal ByProducts Order 1992, as amended, lays down controls for the elimination of pathogens from
animal waste, the handling of materials destined for further use and lays down the hierarchy
of control for disposing of animal by-products.
This is to be achieved by rendering in
approved premises, incineration or burning other than at an incinerator. If the by-product is
38

at a place where access is difficult or the amount or distance to the rendering premises or
incinerator is too large then the by-products may be buried at a depth where they are not
accessible to carnivorous animals.
It also sets out two risk categories for the wastes,
detailing different levels of control, with some derogations for each.
4.35
Controls are placed on the premises used for processing, equipment and treatment methods
used, standards of hygiene, microbiological safety and transportation of the wastes and
provisions made for enforcement.
4.36
Responsibility for taking enforcement action depends on the circumstances of the case. The
Meat Hygiene Service monitors activities at the abattoir. Once the carcasses have left the
abattoir, monitoring falls to the local authority. This may either be the Trading Standards or
Environmental Health departments and this is for the local authority to decide. In some
cases where an offence has taken place, different local authorities may become involved for
example where the abattoir is in one local authority area and the place of final disposal is in
another. Animal by-products which arise on premises used for agriculture are excluded from
the definition of controlled waste. Animal by-products arising from other premises are
controlled waste, but the keeping or treatment of such by-products in accordance with the
Animal By-Products Order 1992 is exempt from licensing under Schedule 3 paragraph 23 of
the Waste Management Licensing Regulations 1994. Waste management controls may,
therefore, apply where the 1992 Order does not control the activity.
4.37
Generally, where carcasses have not been properly buried, action will be taken under the
Animal By-Products Order 1992, as amended. However, local authorities may also pursue
offenders under the Dogs Act 1906, if a carcass has been left available for access by dogs.
If burial results in contamination of a watercourse, SEPA may take action under Section 30F
of The Control Of Pollution Act 1974 (as amended), under which it is an offence if a person
causes or knowingly permits any poisonous noxious or polluting matter or any solid waste
matter to enter any controlled waters.
4.38
Additional controls on animals and animal health include the Diseases of Animals (Waste
Food) Order 1973, which covers specified waste food and requires its processing under
certain provisions, excluding it from the scope of the Animal By-Products Order 1992, as
amended. The Animals and Animal Products (Examination for Residues and Maximum
Residue Limits) Regulations 1997 prohibit the use of certain substances which have a
hormonal or thyrostatic action and of beta-agonists and also lay down rules for monitoring for
residues in live animals and animal products. These materials could go to land as a
consequence of fallen stock or may be landfilled, if they are not rendered or incinerated. In
addition to this legislation, there may also be local by-laws, enforced by the Local Authorities
which further curtail activities.
The legislation on animal waste is due to be consolidated and a consultation paper on this is
expected shortly.
Plant health
4.39
4.40
The Plant Health Directive 77/93 sets out protective measures to prevent the introduction
and spread of organisms harmful to plants or their products. This is transposed into domestic
legislation by the Plant Health Order 1993, as amended, which itself flows from the primary
UK legislation, the Plant Health Act 1997.
The Plant Health Order and its amendments sets down controls on the movement of plants
and plant products into and within the European Community. It prohibits the importation of
39

certain plant pests, sets up protected zones and introduces a system of plant passports for
movement of plants, plant products and other objects within the community, with a register of
those involved in activities associated with them. Specific controls were put in place with
respect to potatoes and citrus fruits. The Order requires that the competent authority, which
in Scotland is The Scottish Office Agriculture, Environment and Fisheries Department
(SOAEFD), is notified of the presence of any plant pests and makes provision for
precautionary and remedial action if plant pests are found or are to be imported.
4.41
Three further Directives on Potato Wart Disease 69/464, Potato Cyst Eelworm 69/465
and Control of Potato Ring Rot 93/85 are concerned with specific potato plant diseases,
with another directive focusing on Potato Brown Rot currently under discussion. Current UK
regulations, which again focus on importing disease with potatoes are The Potatoes
Originating in the Netherlands Regulations 1997 and The Potatoes Originating in
Egypt Regulations 1998.
4.42
Currently, the Plant Health: Code of Practice for the Management of Agricultural and
Horticultural Waste has been published and the Disposal of Waste (Control of Beet
Rhizomania Disease) Order 1988 is currently going through the process of revocation. It
will apply to both domestic and imported material and outlines plant health safeguards within
the context of overall environmental policy. It recommends dealing with waste products in
accordance with an assessment of plant health risk, but emphasises the reduction or
recycling of waste wherever possible. While the Code is voluntary and has no legal force it
may be referred to in legal proceedings as a measure of good practice (pers comm - The
Scottish Office).
4.43
Enforcement action can be taken by SOAEFD to eradicate organisms and the type of action
taken would depend on the circumstances. Monitoring is carried out on a random sampling
basis, supplemented by inspections where they have reason to suspect that organisms are
present. The Scottish Office also undertake river surveys on an infrequent basis, again
dependent on suspicion of the presence of organisms. Tighter implementation of the
Egyptian regulations is being planned.
4.44
There is no specific plant health legislation which governs the spreading of sewage sludge to
agricultural land. Legislation covering the application of organic wastes to land is concerned
with human, animal and plant health. The Codes of Practice, such as Code of Practice for
Agricultural Use of Sewage Sludge and the PEPFAA Code do recommend constraints to aid
plant health. Plant waste which is diseased cannot be spread on farmland and waste from
plants imported from outside GB must be applied only to land approved for that purpose.
Groundwater regulations
4.45
The Groundwater Regulations (GWR) will come into force on 1 April 1999.
Persons making a direct or indirect discharge of List I and II substances to groundwater
(as specified in the EC Groundwater Directive 80/68/EEC on the protection of
groundwater from pollution caused by certain dangerous substances) will need to
apply to SEPA for an authorisation under the GWR unless a discharge consent under
COPA or Part 1 EPA already meets the requirements, the discharge is controlled subject
to the WMLR, or the discharge will not lead to a deterioration in water quality. Where
authorisation is granted under COPA or Part 1 EPA, this should be consistent with the
requirements of the GWR.
Direct discharge of List I substances is prohibited and authorisation of activities leading to
the indirect discharge of List I substances should be subject to prior investigation. Such
40

activities cannot be authorised if the prior investigation indicates that an indirect discharge
would result, unless the groundwater is permanently unsuitable for use or the presence of
such substances will not impede exploitation of water resources. Authorisations can
include conditions to require technical precautions to prevent indirect discharge.
The GWR limit the introduction of List II substances into groundwater. Prior investigations
are required for direct discharges and activities relating to indirect discharges. An
authorisation can only be granted if technical precautions are taken to prevent
groundwater pollution. Anyone intending to discharge, dispose or tip List II substances
should make an application for authorisation.
Prior investigations are to include the hydrogeological conditions of the area concerned,
the nature of soil and sub-soil and the risk of alteration of the quality of groundwater.
An authorisation can only be made if SEPA has checked that groundwater quality will be
subject to requisite surveillance. Authorisations should be reviewed at least once every
four years. Compliance with the authorisation will need to be monitored. If the conditions
of the authorisation are not complied with, the authorisation can be revoked.
4.46
With respect to the application of organic wastes to land, it is not yet possible to say with
certainty exactly what wastes/activities are going to be covered by the GWR, but it is
considered that the application of organic wastes will be affected.
Planning controls
4.47
The issue of the disposal of organic waste to land in general terms has not been addressed
within the land use planning system. However, the disposal of sewage sludge in particular
has been recognised and addressed by national planning guidance issued through The
Scottish Office Development Department.
4.48
As a general point, NPPG (National Planning Policy Guideline) 1 - The Planning System
outlines the EC Urban Waste Water Treatment Directive, recognises that all significant
discharges of sewage should be treated and states that :
In some areas this will be an extra consideration of strategic importance in preparing the
structure plan. More generally, sewage authorities will require to find sites for the treatment
and disposal of both sewage and sewage sludge. This will be an important issue for local
plans.
Planning authorities must therefore consider the issue of sewage sludge in the production of
their development plans (structure and local plans).
4.49
More specific guidance is provided in relation to the disposal of sewage sludge to land in
NPPG 10 : Planning and Waste Management. Planning controls will only apply where
sewage sludge is disposed of on land other than agricultural land. Where waste is used
solely for agricultural purposes, deposit is exempt from planning control. In addition, the
guidance also raises the possibility that a site for the depositing of sludge may require the
preparation of an environmental assessment if judged to have significant environmental
effects under Schedule 2 of the Environmental Assessment (Scotland) Regulations 1988.
National waste strategy : Scotland

4.50
SEPA is charged with producing the National Waste Strategy : Scotland and has published a
draft Strategy for consultation which is being worked into a final document through a process
of wide consultation, due for publication in 1999. The Strategy encompasses the principles
41

of the European Fifth Action Programme on the Environment, whereby a hierarchy of
desirable practice is set out. Waste minimisation is the preferred route, followed by re-use or
recycling, incineration without heat recovery and finally landfill. Whilst the relative merits
and demerits of the hierarchy are open to debate, it is clear that the recycling of organic
waste to land is an activity compatible with other policy objectives sought by SEPA.
Summary and issues

1.
There are concerns over the differences in the level of control provided for through the
legislation for the different wastes and the lack of integration of statutory Codes of Practice
into the controls.
2.
The provisions of the Code of Practice for Agricultural Use of Sewage Sludge (CAPUSS) and
the Prevention of Environmental Pollution From Agricultural Activity (PEPFAA) Code of
Practice appear to be effective if followed. However, many farmers are unaware of the
Codes. There is scope for further reduction of the risks from applying sewage sludge through
tightening of the provisions of CAPUSS.
3.
The information and guidance in the Codes does not have a statutory basis.
4.
There are no statutory limitations for nutrient additions or organic contaminants in soils
following application of sewage sludge or any other material, and no limitations for Potentially
Toxic Element additions in wastes other than sewage sludges.
5.
Precautions such as the restrictions on land use following sludge application, as set out in
CAPUSS, could be extended to other wastes where there is a high risk from the pathogen
content.
6.
Legislation offers a good level of protection for plant health and the phasing out of untreated
sewage sludge will further assist this.
7.
Certain aspects of the Waste Management Licensing Regulations 1994 are unclear insofar
as they apply to exempt waste activities. In particular:
The definition of sludge from biological treatment plants requires clarification with
respect to waste types and treatment processes;
There is no legal definition of what constitutes agricultural benefit or ecological
improvement; and
Properly Qualified Advice (PQA) needs to be defined.
42

5.
Discussion
Introduction
5.1
The preceding sections have set out the current practices, the state of scientific knowledge
on the subject, summarised the legislation and regulation as it affects the various waste
streams and identified the environmental impacts. This section analyses the available
information and identifies deficiencies in management of the wastes. In order to process the
data in a rational and all encompassing way, a risk assessment methodology was adopted
using the source - pathway - receptor model. This model, used in conjunction with a multi
criteria analysis exercise based on a matrix of possible impacts against each waste, brought
clarity to the outcome and led to unanimity within the expert group conducting the exercise.
5.2
This exercise then culminated in deriving management options for the wastes and in
identifying a preferred option. Throughout this part of the analysis, care has been taken to
ensure that the proposals utilise existing principles which are already common practice in
regulation and that the proposed option operates at the least bureaucratic level possible
consistent with achieving the overall aims. Consideration has also been given to the
accommodation of a charging scheme.
Current deficiencies in managing organic waste spread on land

Regulation and responsibilities
5.3
The current regulation of organic wastes spread on land is not consistent. Sewage sludge,
which is relatively homogeneous and comprises 1% of the waste going to land, is well
regulated through legislation which controls the application of PTEs and subsequent land
use. There are also supporting Codes of Practice. Exempt wastes, which are heterogeneous
both within a sector and across different sectors of origin, have few controls exercised over
them once they have satisfied the conditions of the exemption. This includes the undefined
requirements of agricultural benefit or ecological improvement. Agricultural wastes,
comprising 96% of the waste going to land, are not controlled, although guidance is given in
the PEPFAA Code.
5.4
There is no statutory requirement for any farm or site where waste is being applied to have a
management plan which records the addition of nutrients, PTEs and contaminants to the
land. No consideration is given to the possible consequences of any synergisitic or
antagonistic effects when different wastes are applied and taken up or retained through time.
In particular, there is no statutory requirement to match nutrient application with the needs of
crops, the natural condition of the soil or the current state of the soil.
5.5
As a result of the general lack of management information there is scope for much loss of
nutrients from the land and for negative environmental impacts on surface and ground
waters. There is currently no statutory requirement for the farm or site owner to take into
account the nutrient value of the organic wastes already applied when calculating the
inorganic fertiliser requirement for the land. This negates the beneficial effects of the wastes,
uses other resources unnecessarily, poses potential pollution risks and has an economic
impact through unnecessary expenditure.
5.6
The owner or occupier of the land does not have a clear requirement to be responsible for
the way in which the land is being used when wastes are brought there for recycling. This
includes calculating if the soil will benefit from application of the waste and the nutrient
43

balance in the soil. Many owners or occupiers are passing this responsibility de facto to the
contractor bringing in the waste, particularly in the case of exempt wastes.
5.7
The management of most waste is controlled through extensive regulation in the UK. The
concept of exempting some waste spreading activities from licensing was brought in to
encourage the beneficial use of the exempt materials, not to provide a route for avoidance of
legal controls. In the waste management Duty of Care chain there is also a requirement for
the producer of the waste and others in the waste chain to know, describe and take
responsibility for the waste arising. This constraint does not apply to agricultural waste
which is not controlled waste. Although the requirements of Duty of Care are recognised by
the responsible waste contractors, many others in the chain do not realise or recognise their
responsibility. This includes farmers. This is an important factor in the attitudes which
currently prevail amongst the producers of exempt waste.
5.8
Sewage sludge has to meet a specification within certain defined parameters prior to
application to land. There is no reason why exempt wastes should not be brought under a
similar degree of control.
5.9
The case for all agricultural wastes to be controlled in this way is much less clear. Some of
the agricultural wastes may be brought into the waste management licensing system shortly
anyway, either through extension of the regulations or through the introduction of Integrated
Pollution Prevention and Control (IPPC). It may be possible to address the need for
landowners and occupiers to know what is going to their land through a requirement to have
a farm nutrient management plan. This concept is one developed by the agricultural
advisers to assist better farm management.
5.10
Much of the relevant information is already available including guidance on how to operate a
farm waste (not nutrient) management plan. However, this guidance is held in non-statutory
Codes of Practice such as the PEPFAA Code. These Codes are not widely known or
followed in the agricultural community. Some of the guidance within the Codes is general in
nature and open to interpretation whilst other parts refer to compliance with regulations and
legislation which set a baseline standard. Some information within the Code is statutory
whilst other parts of the Code make non-statutory recommendations, leading to confusion
amongst users as to its exact status.
5.11
It is recognised by many of those involved in spreading organic waste on land that a more
prescriptive approach to the overall management of sewage sludges and exempt wastes is
required. Public opinion, reflected through the views of the British Retail Consortium appears
to demand higher standards than the Code. The use of a voluntary Code does not give
enforcement Agencies such as SEPA proper control. A statutory Code based on, for
example, PEPFAA or Regulations which require the Code to be followed would achieve the
desired aim. The PEPFAA Code could form the framework but would benefit from a careful
review if it is to achieve a higher status than it currently has.
Attitudinal problems
5.12
The application of organic wastes to land is potentially beneficial and is part of a long
established concept of nutrient recycling. This concept is well understood amongst the
agricultural community, although there is some lack of appreciation of the changes in slurry
and manure content as intensive farming has developed. The public response to agricultural
waste being returned to the land also reflects a basic understanding and tolerance of the
practice. Each of the wastes considered in this report can have beneficial effects if applied
appropriately, with the exception of disposal of large numbers of fallen stock.
44

5.13
Attitudes to sewage sludge or exempt wastes are different. The water authorities recognise
and are keen to promote the beneficial effects of sludge recycling although public sensitivity
to the issue and concerns over pathogen transmission mean that the outlet is potentially
insecure unless steps are taken to reduce all perceived risk. The agreement to phase out the
disposal of untreated sludge to land by the end of 1998 exemplifies the flexibility necessary
to adapt to changing external pressures, in this case from the British Retail Consortium and
public pressure.
5.14
Waste activities which are exempt from licensing are an area where the attitude of the waste
producer needs to be amended. Currently the practice is viewed by some as waste
disposal, using land as a way of getting rid of an unwanted material. Little attempt is made
to manage the quality of the material because it is viewed as a waste and therefore of no
value. Expenditure on improving quality is seen as a cost and exemption from the waste
management licensing controls reinforces this view. If the activities are to continue, it will be
necessary to ensure that a shift in attitude takes place whereby the material is seen as a
beneficial addition to the soil which is being recycled. This attitude needs to flow through the
whole chain from producer to final recipient. Proper controls over the quality parameters,
storage and handling practice through to an understanding of the nutrient being received by
an individual holding will change attitudes. Correct use of terminology will assist in
developing a culture of recycling as opposed to a culture of disposal.
Operational practice
5.15
Minimum storage capacities and standards are stipulated in the Control of Pollution (Silage
Slurry and Agricultural Fuel Oil (Scotland) Regulations 1991) for handling farm wastes to
ensure that environmental damage does not occur and that waste is only spread when the
application will result in agricultural benefit. Similar restrictions should be applied to exempt
wastes to ensure they do not cause problems in handling off-site and are only used when
they will give agricultural benefit or ecological improvement. Placing the responsibility with
the producer is in alignment with all other waste management procedures and will lead to
stimulation of waste minimisation techniques.
5.16
There is a false assumption that all soils in Scotland are suitable for receiving wastes for
recycling. Inappropriate injection into the soil above field drains can cause water pollution
whilst topography is also important in ensuring safe spreading. There is a need to know
where potable aquifers underlie the land as well as other topographical and pedological data.
The Macaulay Land Use Research Institute has developed an automated land evaluation
system which identifies the suitability of land for various uses, based on a Geographical
Information System. There could be scope for further use of this system.
5.17
Waste management site licence operators are required to have suitably qualified staff on
site, holding the Waste Management Industry Training Accreditation Board (WAMITAB)
qualification. No equivalent qualification is required for contractors who apply wastes t land
although SAC is currently working on an accreditation scheme equivalent to those currently
in existence for pesticides and fertilisers. Introduction of a formal certificate would assist in
raising standards and public confidence in the process.
Recording systems
5.18
The water authorities are required to keep records of the land on which they recycle sludge.
Exempt waste has to be notified in general terms whilst agricultural waste is not notified or
recorded. A single site could in theory be receiving wastes from a number of sources for
which there is no integrated recording system. Proper nutrient management on a specific
site would rely on the ability of the landowner/occupier to record and analyse the data, if he
45

demanded it. There is no integrated geographically based recording system at present.
Concerns were expressed during the research over naming individual farms and waste
received, despite the fact that details should be adequate through registration. This is an
issue which would have to be addressed in detail.
5.19
Improved coordination between waste producers, local councils (in their role as protector of
private water supplies) and the water authorities (with responsibility for public supplies) is
necessary. This would allow easier communication with the public in respect of concerns or
queries.
5.20
Much of the agricultural community is now involved in Quality Assurance schemes which rely
on traceability and audit trails to provide public assurance. These farm quality assurance
schemes are particularly concerned with epidemiological traceability which gives an audit
trail from the food product back to the farm. Extension of this to the waste chain would
reinforce the duty of care and would assist in building public and retail confidence. Some but
not all contractors can trace sludges from source to field but this is the exception rather than
the rule.
Public health
5.21
At present there is no monitoring of the wastes (pre- or post- application) for microbiological
quality, either by SEPA or Environmental Health officers. Whilst the Sludge Use In
Agriculture Regulations (1989, as amended) do not specifically address microbiological
parameters there is a general requirement to ensure that sludge application does not impair
groundwater or surface water quality, and it could be inferred that this should include
microbiological quality. In contrast the Waste Management Licensing Regulations (1994) do
specify that waste treatment or disposal, including exempt activities, must among other
things be undertaken without endangering human health. However, there is no requirement
for SEPA to assess the proposed exempt activity in advance of application.
5.22
It is the responsibility of the operator to obtain Properly Qualified Advice (PQA) and to ensure
that the objectives of the exemptions are met. Only in the event of pollution can SEPA take
action such as prosecution and SEPA does not have any powers at present to serve
enforcement notices to stop activities. At present local authorities do not monitor land
application of wastes. Persons concerned about waste application in their vicinity believe
that no-one is taking responsibility for public health issues and are understandably
concerned. Lack of public confidence could lead to requests for post application monitoring
for pathogens. It has been suggested that local authorities could take on the responsibilities
for public health monitoring following waste application, (P Madden DoH, pers comm, 1998).
However, there are advantages in having the enforcement role vested in one authority such
as SEPA.
5.23
Irrespective of the level of post-application monitoring, it is clear that a full assessment of the
risks to plant, animal and human health should be made in advance of the waste application
by the operator on the basis of PQA. The landowner/occupier should be fully involved. It is
considered unrealistic to monitor all wastes for numbers of pathogens, but instead a risk
assessment should be carried out. Whilst the use of sewage sludge is controlled in terms of
barriers to disease transmission, such barriers do not exist for other wastes. It is suggested
that the land use restrictions such as a restricted grazing period between sludge application
to the surface of grassland and the return of stock to pasture or restriction on cropping
practices should be extended to all wastes spread on land.
46

Scientific understanding and risk assessment
5.24
The level of understanding of the nature and impact of the different wastes is variable with
the most highly controlled waste, sewage sludge, being subject to the most detailed research,
both historically and at present although there remain unanswered questions as
demonstrated by the increasing concern over pathogens in sludge.
In contrast, little
research has been carried out on exempt wastes and the level of scientific knowledge is low.
There are varying levels of scientific background data relating to agricultural wastes, fallen
stock and composted wastes. Whilst the instinctive response to many questions about
pathogens is that experience demonstrates there are no problems, the level of reassurance
required by the public and others is such that proper scientific research is needed to back this
up. This is an area which requires a co-ordinated approach in order to use resources
effectively.
5.25
A more holistic approach is required, looking at soils as one of the main environmental sinks
for pollution and recognising that it is a key natural resource whose carrying capacity must
not be exceeded if it is to be used sustainably. The present approach to the status of soils is
based on snapshots of soil quality with little attention being given to processes such as the
transfer and behaviour of pathogens and metals. It will also be necessary to ensure that
critical loads are understood and allowed for in the particular climatic and soil conditions in
Scotland. No use is currently made of the existing soil classification system for Scotland to
ensure land is suitable for waste spreading. It is also known that wastes are applied in
mixtures and little is known about the potential impacts of such practices.
Research requirements
5.26
Further information is required on the following topic areas:

The behaviour in soils of chemicals for which long term studies are sparse. These include
oestrogenic compounds and metals such as palladium.
Soil fertility issues. The long term impacts of waste applications to Scottish soils need to
be reviewed taking account of any changes in climate and pH. Critical loads and dose
response relationships for organic wastes should be included in this research.
Pathogens and viruses which have become the focus of recent concerns need to be
studied in the soil context including Listeria monocytogenes, E.coli 0157:H7, Giardia,
Cryptosporidium and in particular persistence and transmission of pathogens in Scottish
soils, related to moisture content, soil temperature etc. The levels of detection of
pathogenic organisms is not sufficiently sensitive and new, rapid assay techniques are
required
The effectiveness of various levels of treatment for different wastes should be reviewed
and clearly defined in terms of efficiency of microbial removal. On an operational basis a
description is needed of the necessary treatment process parameters. The consequence
of treatment in terms of reduced nutrient availability should also be investigated.
Risk assessment
5.27
Spreading organic waste on land as a method of recycling beneficial materials into the soil
carries with it a degree of risk. Management of that risk to an acceptable level will ensure
that the activity can continue, allowing the beneficial aspects to be maximised and potential
harm to be negated. A qualitative risk assessment exercise was undertaken in order to
47

identify why certain aspects of the practice are currently posing a risk, followed by an
assessment of possible control options to remove that risk. The working sheets from the
exercise are given in annexes15 and 16.
Table 8 - Summary of potential causes for concern
Potential causes for
concern
Sewage
sludge
Agricultural
waste
!
!
Variability of waste stream

Limited knowledge about
the nature of waste/limited
scientific understanding
Limited waste treatment
Exempt
waste
! for some !
Compost
Fallen
Stock
!
!
sludges
Problems associated with

application methodology
Public perception
Lack of current controls
!
!
5.28
The potential causes for concern are summarised in Table 8. Each waste stream has
associated risks but as the table demonstrates, those relating to exempt wastes are
considered to be the greatest. This is due primarily to the lack of research and
understanding of the nature of the material, the variability of the waste streams and the lack
of knowledge of how much material is going to land and in what location. A risk assessment
of the individual wastes has been carried out by the Scottish Agricultural College (SAC,
1997b - annex 17) which highlighted the considerable risks associated with sludge from
biological treatment plants, waste hair and effluent treatment from tanneries, blood and gut
contents from abattoirs and septic tank sludge. The inclusion of these wastes on the list of
wastes which can be exempt from licensing should be reviewed with a view to their removal
from it.
5.29
Agricultural wastes pose a high risk to the water environment if they are not handled
carefully. They also have a medium to high probability of causing human and environmental
impact when disposed of on land, on account of their pathogen and PTE content. Odour
nuisance has been classified as air pollution.
5.30
Although sewage sludge currently comprises only 1% of the waste going to land, its potential
environmental and human health consequences illustrate why it is highly controlled and why
much research has been carried out on its nature and effects. The impact of pathogens has,
however, been neglected in the past and the phasing out of untreated sludge to land is to be
welcomed. This is consistent with the risks identified with the waste.
5.31
Fallen stock represent an area of concern, principally due to the potential pathogenic content
and to the fact that this is an area where rapid changes in practice are occurring. Little is
known about the pathogens associated with increased burial of fallen stock on farm. In
SEPAs experience past practice has not caused problems because the numbers of stock
have been small and Codes of Practice have usually been followed. However, with the
change in the structure of the knackery and rendering industry, it is possible that problems
will be caused if animals are buried in inappropriate areas. The MLURI land suitability data
shows that the best areas for burying animals do not, in general, coincide with the major
areas of stock rearing although individual site circumstances vary (Tweddle, 1998).
48

5.32
The UK is the only EU Member State which allows on farm burial with the exception of Spain
and Ireland where specific permission and controls are required. In view of the changing
circumstances which are likely to lead to more on farm burial and the unknowns relating to
the environmental issues of larger scale burials, it is recommended that alternatives to on
farm burial are encouraged.
5.33
There is no evidence that the risks associated with spreading composted waste on land are
high although there could be risks to plant health from any pathogens which survive the
composting process if the source material was predominantly green waste.
5.34
In general, the hazards and the environmental and health consequences associated with
sewage sludge, agricultural wastes and exempt wastes are not considered to differ widely
from one another. However, because the volume of agricultural waste applied to land is
1
considerably greater than that of the other wastes, the risk associated with agricultural waste
is greater.
Management options
5.35
The risk assessment options approach has identified areas of concern where a greater
degree of management or control is needed if the practice is to continue and with the public
confident that it is safe, beneficial and does not pose unacceptable risks to human health or
the environment. A variety of potential options was considered for each waste, with the
intention of devising a simple, effective, light-handed framework which reflects the principles
of existing waste management legislation and ties in with other existing good practice (annex
16).
5.36
The management options considered were as follows :
Increased storage (possibly at the producers premises)

Improved pre-treatment/waste minimisation
Pre-notification of spreading operations
Prior justification against objective criteria to protect the land
site suitability assessment

revised application rates
revised application timing
revised application methodology
development of farm nutrient plans/farm management plans
preparation of working plan
Authorisation of company/operator competency including training and QA

Centralised collection
Financial incentives and possible links with farm assurance schemes
Revisions to codes of practice/legislative changes.
Risk is a combination of the probability, or frequency, of occurrence of a defined hazard and the magnitude of the consequences of
the occurrence (Royal Society, 1992).
49

5.37
Consideration of the possible options has identified six specific areas where action would
improve the management of the practices. The six preferred options are:
1.
2.
3.
4.
5.
6.
Increased storage capacity (possibly at the producers premises)

Increased treatment of exempt waste
Prior justification against objective criteria
Common framework of statutory standards
Certification of contractors
Use of incentives to encourage recognition of beneficial effects
5.38
The centralised collection of wastes would not be a practical option for dealing with large
quantities of wastes dispersed throughout Scotland and hence has not been put forward as
an option, although it would be considered suitable for fallen stock.
5.39
A system for pre-notification of wastes was not considered to offer any significant benefits to
the regulator or the waste operator. The disbenefits associated with this practice relate to the
perceived dilution of responsibilities for the persons applying the waste should prenotification be interpreted as prior-approval. SEPA would not have the resources to evaluate
such applications and give prior-approval. Rather than pre-notification, it is suggested that
greater benefit would be offered by the keeping of detailed records by the waste producers/
contractors and land owners and the auditing of these records by SEPA, assuming that prior
justification against objective criteria could be demonstrated, based on Properly Qualified
Advice.
Option 1
5.40
Many problems are caused by the lack of storage capacity which generally exists at the
producers premises, especially for exempt wastes which means that outlets for the waste are
constantly required. Proper storage for a defined period of time should be required, as it is
for agricultural slurries on farm (Control of Pollution (Silage Slurry and Agricultural Fuel
Oil)(Scotland) Regulations 1991). Production of a Farm Waste Management Plan can
reduce the time needed for on farm storage and the general principles of this may be
transferable.
Option 2
5.41
Increased treatment of exempt waste
Public pressure has ensured that sewage sludge will now be treated to a greater extent. This
will encourage continued public acceptance of this practice. This is not the case with wastes
exempt from licensing and it is recommended that those exempt wastes which present a high
risk in terms of disease transmission or odour nuisance should be treated prior to land
spreading. It is not considered either practical or necessary to apply this approach to the
majority of agricultural wastes.
Option 3
5.42
Increased storage capacity at the producers site
Prior justification against objective criteria
In order to protect both soil and the wider environment and to ensure that the practice is
recognised as a beneficial recycling exercise and not a form of waste disposal, it is
recommended that all wastes spread on land should receive prior justification against a set of
objective criteria. These criteria would constitute a clearer definition of agricultural benefit
or ecological improvement. They would include assessment of site suitability in terms of
location, soil type, permeability, hydrology and topography, risk assessment of the wastes
and details of the application methodology. This information, which can be developed with
Properly Qualified Advice, should be collated into a working plan which would take account
of the application rates and timings. This constitutes the broad concept of a Farm Nutrient
50

Management Plan which requires further detailed design. Detailed records of actual practice
are considered to be of greater value than the general pre-notification which currently exists
for exempt wastes. This Plan would also allow greater recognition of the beneficial value of
the wastes, encouraging less use of inorganic fertiliser with potential environmental benefits.
Option 4
5.43
The current PEPFAA Code and Code of Practice for the Agricultural Use of Sewage Sludge
set limits on the level of treatment required, maximum loadings which can be applied to land
as well as land use restrictions around crop growing seasons and post spreading. These
should be placed in a common framework for all wastes spread on land with minimum
standards embodied in Regulations, with other standards in Codes of Practice.
Option 5
5.44
Certification of contractors
Good management practice and ensuring that public concerns are addressed requires that in
many facets of agriculture and waste management, quality assurance schemes, operator
training and audit cycles are used. Waste management licensing for facilities such as
landfills or transfer stations requires that operators have a WAMITAB qualification. It is
considered that the introduction of some equivalent competency for operators who spread
waste on land would do much to increase the status and acceptability of the practice. The
contractors involved in application of exempt wastes and sewage sludge are not opposed to
this approach.
Option 6
5.45
Common framework of statutory standards
Use of incentives to encourage recognition of beneficial effects
It is recognised that some form of incentive to encourage landowners/occupiers to adopt

Farm Nutrient Management Plans and better practice may be required. Links through to
quality assurance marketing schemes may be appropriate as well as information ion the
possible savings in inorganic fertiliser use may be appropriate. This area needs further
consideration.
Restrictions
5.46
It is considered that if the options for control set out above are adopted then the benefits of
recycling waste to land will be able to continue in a controlled manner. There are, however,
some wastes and operational practices which should be discontinued regardless of the
control options adopted. These are :
1.
2.
3.
4.
5.
5.47
The application of blood and gut content from abattoirs.

Spreading of septic tank sludge.
Injection of wastes in land with field drains - additional treatment of some wastes
would negate the need to inject because pathogens and odour would be removed.
Hours of operation should be limited to daylight hours.
Spreading should not be allowed in designated heritage sites as a precautionary
measure.
It is suggested that septic tank sludges should be disposed of at designated water authority
sewage treatment works, and that suitable pre-treatment and discharge to sewage treatment
works be adopted for blood and gut contents.
51

Charging scheme
5.48
Any amendments to the current regulation of organic wastes spread on land will potentially
involve SEPA in new duties or an increased workload. SEPA is required to consider full cost
recovery in its regulation. A charging scheme is therefore proposed in section 6.
52

6.
Conclusions and recommendations
6.1
The overall conclusion from this strategic review is that the current approach to the
regulation and management of organic waste spread on land is inadequate and inconsistent,
leading to practices which pose a risk to the environment and have potential public, animal
and plant health risks.
6.2
There is a lack of public confidence in the practice which threatens what is basically an
activity which can have environmental benefits
6.3
There is a culture of waste disposal amongst some producers, whereby the application of
organic waste to land is not seen as a recycling activity but as disposal.
6.4
With the exception of sewage sludge, the input of nutrients to land is not recorded. Records
of different wastes going to land are not collated for specific farms and links are not usually
made between the organic waste nutrient input and inorganic fertiliser application.
6.5
There are gaps in the scientific knowledge which must underpin the activity, mainly relating
to the pathogenic content of wastes, the fate of pathogens and organic contaminants in soil
and the changes in soil processes brought about by continued application of organic wastes.
6.6
There are seldom storage facilities at the producers site, particularly for exempt wastes
which results in pressure on contractors to spread waste when conditions may not be
appropriate or to store in an uncontrolled manner on farm with the attendant spillage risks.
6.7
There are no vocational qualifications required for operating a waste spreading business,
unlike waste management which requires vocational training.
6.8
The Codes of Practice contain sound practical advice but are not statutory. This is a
substantial weakness. There is confusion over the status of some parts of the Codes.
6.9
A charging scheme will be necessary to finance effective regulation.
Recommendations
6.10
It is recommended that a consistent legislative framework for all organic wastes spread on
land is developed incorporating relevant Codes of Practice as necessary, with statutory
status and clear definitions of agricultural benefit and ecological improvement.
6.11
It is recommended that there should be a need to demonstrate beneficial recycling using the
definition of agricultural benefit or ecological improvement. The philosophy of matching
application of waste with nutrient requirements should be incorporated for all wastes, not just
sewage sludge.
6.12
It is recommended that the regulations cover mixed waste streams and set minimum
standards for safe acceptance loadings for different wastes on a range of soil types.
Consideration should be given to utilising current databases such as the MLURI land
evaluation database.
53

6.13
It is recommended that minimum standards of treatment for all wastes spread on land are
stipulated, except for the majority of agricultural wastes. Minimum storage capacity at the
producers site should be stipulated.
6.14
There is a need for Properly Qualified Advice (PQA) to be readily available which will take
account of nutrient requirements, inputs and adverse components of the waste. What
constitutes PQA needs to be defined. It is recommended that sources of PQA are
identified.
6.15
In order to minimise the risk from pathogens, restrictions on land utilisation following the
application of farm wastes and exempt wastes similar to those applied to sewage sludge are
recommended. This could be partially achieved through requiring the waste producer to
prove benefit and provide proper analysis of the waste. There should be a statutory
requirement for exempt wastes to be analysed for chemical and microbiological parameters
prior to disposal.
6.16
It is recommended that the concept of land management plans is introduced. The term is
deliberately wider than a farm nutrient plan or farm waste plan. The plan would encompass
the beneficial and detrimental aspects of all wastes going to the farmland as well as
incorporating inorganic fertiliser inputs. The responsibility for the land management plan
would rest with the landowner/occupier. It is understood that some farms already operate a
variety of management systems which would permit the introduction of this plan as an
evolution of existing practice.
6.17
The key requirement of any control system is to ensure that the responsibility for specific
actions rests with the correct person and that it is carried out. The proposed mechanism in
Table 9 places the responsibilities in the appropriate place, consistent with other current
legislation or regulations. It is recommended that this proposal is considered further and it,
or a similar system, is adopted.
6.18
It is recommended that a competency scheme for contractors is introduced, similar to the

WAMITAB qualification for waste management licence operators.
6.19
It is recommended that the following wastes are not spread on land:

1.
2.
6.20
It is recommended that the following practices are prohibited:

1.
2.
3.
6.21

Septic tank sludge
Injecting wastes in land with field drains

Spreading outwith daylight hours
Spreading in designated heritage sites
A suggested scheme of regulation is presented and it is recommended that consideration is

given to developing and refining it.
A waste producer who wishes to recycle organic waste to land should be required to
fulfill the following conditions.
54

Conditions are:
provision of analysis, pre-treatment of waste and necessary storage facilities
that the producer must spread the waste themselves or go through an authorised
contractor
that waste can only go to land which has a land management plan
the waste producer keeps records
the contractor (which may be the producer) has to demonstrate that there is a
land management plan for the site and that the wastes were deposited there.
A clear audit trail will then exist which can be audited by SEPA.
6.22
It recommended that a charging scheme is developed to effect the regulation through

SEPA. Charges would be levied for auditing the compliance and if required the certification
of contractors who hold the appropriate competency. An annual charge would accrue to the
waste producer, similar possibly to the banding schemes of CoPA or the waste charging
schemes.
55

Table 9 - Proposed mechanism for regulating organic wastes to land
Responsible
body
Producer
Responsible for
Details
Characterisation of waste
including analysis
PTEs, nutrients
pathogen content (risk
assessment and routine
monitoring for high risk
wastes)
Only accredited
laboratories used in waste
analysis
Providing information on
nature of waste to
contractor
Forwarding information on
nature of waste to Land
owner/occupier
Contractor
Identifying suitable sites &

conducting risk
assessment for the site
and waste
Forwarding information on
nature of waste and
application details to Land
owner/occupier
Agricultural benefit or
ecological improvement to
be justified
Site selection, suitability
for wastes, timing of
application, rate of
application
Demonstrating
competency, QA process
Provision of QA audit trail
Controls on staffing and

operation
Land owner/
occupier
Holding farm nutrient

management plans
Informing waste
contractor of any
additional wastes applied
to the land, in particular
inorganic fertilisers
SEPA
Farm nutrient
management plans
includes information on
soils (slope,
characterisation etc, and
record of all nutrients
supplied (organic and
inorganic), and PTEs)
including timing
Auditing of records held

by the waste producer,
contractor and land
owner.
56

References
Aitken, M. A. (1996). Ammonia Volatilisation Losses from Agriculture. SAC paper.
Aitken, M. A. (1998). Overhead from presentation to the SEPA Waste to Land Task Team, January
1998 (from unpublished SAC research).
Aitken, M. A. (1998b). Personal communication between Mark Aitken SAC and SEPA organic wastes
to land task team.
Aitken, M. A. & Virtue, W. A. (1998). Agriculture as a Source of Phosphates in Surface Waters.
Article for 1998 Scottish Agricultural Pollution Group Annual Pollution Review.
BAG, (1998). Blairingone & Saline Action Group - Submissions to SEPA re review of the spreading
of organic waste to land in relation to public , animal and plant health, environmental pollution,
protection of the soil legislation controls. Ed. Duncan Hope.
Bionet, (1998). Web site produced by Bauhaus-Universitt Weiman summarising information
sourced from M. De Groot, DHV, Composting in the European Union, Amersfoort, Netherlands, June
1997.
British Retail Consortium/ADAS Matrix (1998). Correspondence Water UK. Draft June 1998.
Campbell C. (1998). Personal communication between Colin Campbell, MLURI and Paula Woolgar,
SEPA, telephone conversation of 7/8/98.
Carrington E, et al (1998) Review of the Scientific Evidence Relating to the Controls on the
Agricultural Use of Sewage Sludge:. Part 1 - The Evidence Underlying the 1989 Department of the
Environment Code of Practice for Agricultural Use of Sewage Sludge and the Sludge (Use in
Agriculture) Regulations.
Carrington E, et al (1998) Review of the Scientific Evidence Relating to the Controls on the
Agricultural Use of Sewage Sludge:. Part 2 - Evidence Since 1989 Relevant to Controls on the
Agricultural Use of Sewage Sludge.
Carrington E, et al (1998b) A Users Guide to Research on Application of Organic Waste to Land.
WRc/SAC Draft Report to SNIFFER September 1998.
Chalmers, A.G., Dyer, C.J., Leech, P.K. and Elsmere, J.I (1992). Fertiliser Use on Farm Crops,
England and Wales, 1991. Survey of Fertiliser Practice. MAFF Publications. London.
Composting Association (CA), (1997). The state of composting in the UK: a blueprint for action. CA,
Coventry, UK.
Composting Association (CA), (1998). Health & safety at composting sites: a guidance note for site
managers. CA, Coventry, UK.
Davis, RD and Rudd C, (April 1998) Investigation of the criteria for, and guidance on, the
landspreading of industrial wastes. Final report the Environment Agency and MAFF. WRc report
4088/5 .
Davis, R D and Dalimier, F (1994.) Waste Management - Sewage Sludge. Part 2 - Quality Criteria,
Classification and Strategy Development. WRc Report No EC 3757. WRc Medmenham, Marlow.
57

Department of the Environment (1995). (national air quality statistics).
Department of the Environment (1993). Composting of waste derived fines rejects at Castle
Bromwich, summary report CWM/081/93. Available from WRC, Swindon, UK.
Department of the Environment (1996). Markets and quality requirements for composts and
digestates from the organic fraction of household wastes, CWM 147/96. Available from WRc,
Swindon, UK.
Department of the Transport and the Regions secretariat to the Composting Development Group
(1998). Report of the Composting Development Group.
ENDS Report 252, January (1996). Modified Feed Cuts Air Pollution from Livestock Farms.
Eving, A (1998). Personal communication between Alison Ewing, Renfrewshire Council, and Paula
Woolgar, SEPA, telephone conversation of 14/8/98.
Fleming, G A (1993) The production of animal wastes. In: Environment Agriculture and Livestock
Farming in Europe. Proceedings of European Conference, Mantova, Italy. Commission of the
European Communities.
Foy, B. (1996). Research undertaken for the Department of Agriculture for Northern Ireland.
Gartland, K (1998). Personal communication between Kevin Gartland, University of Abertay, and
Paula Woolgar, SEPA, telephone conversation of 4/8/98.
Gendebien, A, Carlton-Smith, C, Izzo, M and Hall, JEH (1998).
National Presentation. WRc Draft R&D Technical Report P165.
UK Sewage Sludge Survey -
Gilbert, J (1998). Research projects: pathogen destruction in manures. The Journal of the
Composting Association, Volume 3, Issue 3, p10.
Government Response to the 19th Report of the Royal Commission on Environmental Pollution
(Sustainable Use of Soil). January 1997.
Government Response to the House of Commons Select Committee - Sewage Treatment and
Disposal. (July 1998). Cm 4023.
Greenslade, C. (1998). Personal communication with Eva Cahill, June, 1998.
Hancock, D.D., Besser, T.E., Rice, D.H., Heriot, D.E. and Tarr, P.I. (1997). A Longitudinal Study of
Escheria coli in Fourteen Cattle Herds. Epidemiology and Infection 118, 193 - 195.
HDRA Consultants Limited, (1998). Researching the use of compost in agriculture, report of work for
1997. Henry Doubleday Research Association, Coventry, UK, March 1998.
Heaney, D (1998) - personal communication Eva Cahill/ D Heaney, Scottish Consumer Council 13
July 1998.
Holland, (1998). Real life composting. The Journal of the Composting Association, Volume 3, Issue
2, p8-9.
58

House of Commons (1998). Select Committee on the environment Transport and the Regions memorandum of inquiry by environment sub-committee on Sewage Treatment and Disposal. 24
February 1998.
IGBP Home Page: http://www.unep.ch.iucc
Misselbrook, T.H., Chadwick, D.R., Pain, B.F., and Headon, D.M. 1998. Dietary Manipulation as a
Means of Decreasing N Losses and Methane Emissions and Improving Herbage N Uptake Following
Application of Pig Slurry to Grassland. Journal of Agricultural Science, Volume 130, P. 183-191.
Institute of Grassland and Environmental Research/ADAS/Silsoe Reserach Institute (1996). Joint
research into UK ammonia emissions should read Pain, B.F., Van Der Weerden, T.J., Chambers,
B.J., Phillips, V.R., and Jarvis, S.C. 1998. A New Inventory for Ammonia Emissions from UK
Agriculture. Atmospheric Environment, Vol. 32, No. 3, pp.309 - 313.
Insam H. and Merschak P., (1997). Nitrogen leaching from forest soil cores after amending organic
recycling products and fertilisers. Waste Management & Research, Volume 15, p277-291.
Institute of Wastes Management (IWM), (1994). Down to earth composting of municipal green
wastes. IWM, Northampton, UK.
Jenkinson (1996). Review of the Current Evidence on Escherischia coli 0157:H7. Report submitted
to Pennington Group
MAFF (1985). Advice on Avoiding Pollution from Manures and Other Slurry Wastes. Booklet 2200.
HMSO, London.
MAFF (1991). Code of Good Agricultural Practice for the Protection of Water. MAFF London.
MAFF (1991). Code of Good Agricultural Practice for the Protection of Water. MAFF London.
MAFF (1985). Advice on Avoiding Pollution from Manures and Other Slurry Wastes. Booklet 2200.
HMSO, London.
MAFF (1998). Taken from MAFF site on internet (MAFF Environment Matters)
MAFF/DOE (1993). Review of the Rules for Sewage Sludge Application to Agricultural Land. Food
Safety and Relevant Animal Health Aspects of Potentially Toxic Elements. Report of the Steering
Group on Chemical Aspects of Potentially Toxic Elements. Report of the Steering Group on
Chemical Aspects of Food Surveillance. MAFF Publications, London.
Mawdsley, J.L., Bardgett, R.D., Merry, R.J., Pain, B.F., Theodorou, M.K., Read, I.A., Svoboda, I.F.,
Bukhari, Z., Smith H.V., Kemp, J.S., Wright, S.E., and Coop, R.L. (1993). Pathogenic Microorganisms in Livestock Waste and Factors Influencing their Transport to the Aqueous Environment.
Appendix 1 of: Protozoan, bacterial and viral pathogens, farm wastes and water quality protection
(Kemp et al 1995). Final report, MAFF Open Contract CSA 2064.
McGrath, S.P (1994) Metal concentrations in sludges and soil from a long-term field trial. Journal of
Agricultural Science, Cambridge 103, 25-35.
Misselbrook, T. H., Chadwick, D. R., Pain, B. F., and Headon, D. M. (1998). Dietary Manipulation as
a Means of Decreasing N Losses and Methane Emissions and Improving Herbage N Uptake
Following Application of Pig Slurry to Grassland. Journal of Agricultural Science, Volume 130, P.
183-191.
59

NFU (1998). Personal communication between Eva Cahill and Ian Melrose & Henry Murdoch NFU
July 1998
Olsen, P and Collier, P (1994). Source-separated waste composting: the quest for quality. Journal
for Waste Management & resource Recovery, Volume 1, p 113-117.
Olsen, P (1998). Personal communication between Peter Olsen, Dundee City Council, and Paula
Woolgar, SEPA, telephone conversation of 10/8/98.
Pain B. F., Van Der Weerden, T. J., Chambers, B. J., Phillips, V. R., and Jarvis, S. C. (1998). A
New Inventory for Ammonia Emissions from UK Agriculture. Atmospheric Environment, Vol. 32, No.
3, pp. 309 - 313.
Paper Federation (1998). Information supplied in Questionnaire Response to SEPA - Bryan
Bateman - Director Business Affairs and Environment, Paper Federation.
Peddie, D (1998). Personal communication between Donald Peddie, Super Organics Ltd and Paula
Woolgar, SEPA, telephone conversation 14/8/98.
The Pennington Group (1997) - Report on the Circumstances Leading to the Lessons to be Learned,
The Stationery Office, Edinburgh, 1997.
Pennington (1998). Personal Communication Hugh Pennington and Eva Cahill July 1998.
Powlesland, C and Frost, R (1990). A methodology for Undertaking BPEO Studies of Sewage
Sludge Treatment and Disposal. WRc Report No 2305-M/1. WRc Medmenham, Marlow.
Roy S., Leclerc P., Auger F., Soucy G., Moresoli C., Cote L., Potvin D., Beaulieu C. and Brzezinski
R., (1997). A novel two-phase composting process using shrimp shells as an amendment to partly
composted biomass. Compost Science & Utilisation, Volume 5, p52-64.
Royal Commission on Environmental Pollution (RCEP), (1996). Nineteenth Report: Sustainable Use
of Soil. HMSO. London.
Royal Society (1992). Risk Analysis, Perception and Management. ISBN 0-85403-467-6
SAC (1997a). Technical note T450 Use of Sewage Sludge on Agricultural land
SAC (1997b). Technical note T459 - Use of non-agricultural wastes on farmland
SAC (1998). Information received in questionnaire to SEPA supplied by Dave Merrilees
Scottish Agricultural College (SAC) (1998) Options for Disposal of Animal Carcasses Originating on
Farms: A report Commissioned by the Scottish Office Agriculture, Environment and Fisheries
Department under Advisory Activity 201 (Economic Assessment).
Scottish Agricultural Pollution Group, (1996). Annual Pollution Review.
Scottish Farm Waste Liaison Group/Scottish Agricultural Pollution Group Annual Pollution Reviews,
(1982 - 1997).
Scottish Office (1992). Prevention of Environmental Pollution from Agricultural Activity (PEPFAA
Code)
60

Scottish Office (1997). Prevention of Environmental Pollution from Agricultural Activity (PEPFAA
Code)
Scottish Office (SO), (1997). Report on the assessment of input materials effects on the quality of
composted green waste. Prepared by the University of Abertay, Dundee. Available from the
Foundation for Water Research, Marlow, UK.
SEPA (1996). State of the Environment Report. SEPA.
SEPA, (1998a). Data obtained from review of SEPA records obtained by Jennifer Lowry - July 1998.
SEPA (1998b). SEPAs Environmental Strategy. SEPA.
Smith, S. R (1996). Agricultural recycling of sewage sludge and the environment. CAB International
SOAEFD (1992). Survey of Fertiliser Practice. Quoted in evidence from SAC.
Soil Survey and Land Research Centre/Silsoe Research Institute (1996). Research into greenhouse
gas emissions from agriculture: status unknown.
Towers, W (1995) Sewage Sludge Utilisation on Agricultural Land in Scotland - Trends in Physical
Constraints and their Implications. MLURI Internal Paper January 1995.
Towers, W and Paterson, E (1997) Sewage Sludge application to land - a preliminary assessment of
the sensitivity of Scottish soils to heavy metal inputs. In Soil Use and Management 13, 149-155.
Tweddle, J M (1998) Options for Disposal of Animal Carcasses Originating on Farms. A report
commissioned by the Scottish Office Agriculture Environment and Fisheries Department.
Wolstenholme, R., Dutch, J., Moffat, AJ., Bayes, C D and CMA Taylor (1992) A Manual of Good
Practice for the use of Sewage Sludge in Forestry. Forestry Commission Bulletin 107. HMSO,
London.
Wolstenholme, R & Hall, J E (1996). A Manual of Good Practice for the Use of Sewage sludge in l
and reclamation. Draft for Consultation. WRc report. CO 4014.
Wright S, 1998. Personal communication with between Sandie Wright, NOSWA and Paula Woolgar,
SEPA, fax dated 7 August 1998.
Legislation
CEC: Council of the European Communities (1969) Directive on Control of Potato Cyst Eelworm
24.12.69 69/465/EEC. Official Journal of the European Communities No L323
CEC: Council of the European Communities (1969) Directive on Control of Potato Wart Disease
24.12.69 69/464/EEC. Official Journal of the European Communities No L323
CEC: Council of the European Communities (1980) Directive on the Protection of Groundwater
Against Pollution Caused by Certain Dangerous Substances 26.1.80 80/68/EEC. Official Journal of
the European Communities No L20.
61

CEC: Council of the European Communities (1986) Council Directive of 12 June 1986 on the
protection of the environment and in particular the soil when sewage sludge is used in agriculture
(86/278/EEC). Official Journal of the European Communities No L181/6-12.
CEC: Council of the European Communities (1990) Directive Laying Down the Veterinary Rules for
the Disposal and Processing of Animal Waste, for its Placing on the Market and for the Prevention of
Pathogens in Feedstuffs of Animal or Fish Origin and Amending Directive 90/425/EEC 27.12.90
(90/667) . Official Journal of the European Communities No L363 EEC.
CEC: Council of the European Communities (1990) Directive on the Disposal and Processing of
Animal Waste 27.12.90. 90/667/EEC. Official Journal of the European Communities No L363.
CEC: Council of the European Communities (1991) Directive Concerning the Protection of Waters
Against Pollution Caused by Nitrates from Agricultural Sources 31.12.91 (91/676/EEC.) Official
Journal of the European Communities No L375.
CEC: Council of the European Communities (1991) Directive Concerning Urban Waste Water
Treatment OJ L135 30.5.91 91/271/EEC.
CEC: Council of the European Communities (1992) Commission Decision on the Approval of
Alternative Heat Treatment Systems for Processing High Risk Material 9.12.92 92/562. Official
Journal of the European Communities No L359.
CEC: Council of the European Communities (1993) Directive on the Control of Potato Ring Rot
18.10.93 93/85/EEC. Official Journal of the European Communities No L259.
CEC: Council of the European Communities (1994) Waste Framework Directive 75/442/ EEC.
Official Journal of the European Communities 25.7.75 L194 as amended by 91/156/EEC ibid
26.3.91 L78/32-377.
CEC: Council of the European Communities (1997) Directive on Protective Measures Against the
Introduction into the Member States of Organisms Harmful to Plant or Plant Productivity amended by
91/27/EEC and 91/683/EEC 31.7.77 77/93/EEC. Official Journal of the European Communities No
L26.
Department of the Environment (1993) Sludge use in agriculture 1990/91. UK Report to the
Commission Under Directive 86/278/EEC Department of the Environment. HMSO, London.
Department of the Environment/ Scottish Office/Welsh Office Joint Circular (1994) Environmental
Protection Act 1990: Part II waste Management Licensing. the Framework Directive on Waste. DoE
Circular 11/94.
Department of the Environment (1996) Code of Practice for Agricultural Use of Sewage Sludge.
HMSO.
DoE (1996) Code of Practice for Agricultural Use of Sewage Sludge. DoE, London.
DoE/Scottish Office/Welsh Office (1996)
Environmental Protection Act 1990, Section 34:
Waste management, The Duty of Care, A Code of Practice.
HMSO (1994). Waste Management Paper No. 4, Licensing of Waste Management Facilities:
Guidance on the drafting, supervision and surrender of Waste Management Licences.
62

Scottish Office (1998) Plant Health Section 21st July 1998 Written Correspondence on Plant Health
Scottish Office, Unpublished August (1998) Draft Plant Health: Code of Practice for the Management
of Agricultural and Horticultural Waste.
SI: Statutory Instrument (1967). Plant Health Act 1967.
SI: Statutory Instrument (1974). Control of Pollution Act 1974.
SI: Statutory Instrument (1981). Animal Health Act 1981.
SI: Statutory Instrument (1989). The Sludge (Use in Agriculture) Regulations 1989 Statutory
Instrument 1263, HMSO.
SI: Statutory Instrument (1990). The Sludge (Use in Agriculture) (Amendment) Regulations 1990.
Statutory Instrument 880, HMSO.
SI: Statutory Instrument (1991). The Control of Pollution (Silage, Slurry and Agricultural Fuel Oil)
(Scotland) Regulations 1991 Statutory Instrument 346 (S35). HMSO.
SI: Statutory Instrument (1991). The Environmental Protection (Duty of Care) Regulations 1991, SI
2839, HMSO.
SI: Statutory Instrument (1992). The Controlled Waste Regulations 1992 Statutory Instrument No
588, HMSO.
SI: Statutory Instrument (1992). Animal By-Product Order 1992 Statutory Instrument 3303. HMSO.
SI: Statutory Instrument (1993). The Plant Health (GB) (Amendment) (No.2) (Potatoes) Order 1993
Statutory Instrument 3213. HMSO.
SI: Statutory Instrument (1993). The Plant Health (GB) Order 1993 Statutory Instrument 1320.
HMSO.
SI: Statutory Instrument (1990). Environmental Protection Act 1990.
SI: Statutory Instrument (1994). The Waste Management Licensing Regulation 1994. Statutory
Instruments No 1056, HMSO.
SI: Statutory Instrument (1994). The Waste Management Licensing Regulation 1994. Statutory
Instruments No 1056, HMSO.
SI: Statutory Instrument (1995). The Plant Health (GB) (Amendment) (No. 2) Order 1995. Statutory
Instrument 1358. HMSO.
SI: Statutory Instrument (1996). The Animal By-Products (Amendment) Order 1996. Statutory
SI: Statutory Instrument (1996). The Environment Act 1995 (Consequential and Transitional
Provisions) (Scotland) Regulations 1996Statutory Instrument 973 (S104). HMSO.
SI: Statutory Instrument (1996). The Plant Health (GB) (Amendment) No. 2) Order 1996. Statutory
63

SI: Statutory Instrument (1996). The Protection of Water Against Agricultural Nitrate Pollution
(Scotland) Regulations 1996. Statutory Instrument 1564 (S137). HMSO.
SI: Statutory Instrument (1997). Animal By-Product (Amendment) Order 1997. Statutory Instrument
2894. HMSO.
SI: Statutory Instrument (1997). The Plant Health (GB) (Amendment) Order 1997
. Statutory
SI: Statutory Instrument (1997). The Potatoes Originating in the Netherlands Regulations 1997.
Statutory Instrument 2441. HMSO.
SI: Statutory Instrument (1997). The Animals and Animal Products (Examination for Residues and
Maximum Residue Limits) Regulations 1997. Statutory Instrument SI1719. HMSO.
SI: Statutory Instrument (1998). Disposal of Waste (Control of Beet Rhizomania Disease) Order
1998. Statutory Instrument 45. HMSO.
SI: Statutory Instrument (1998). The Potatoes Originating in Egypt Regulations 1998. Statutory
64

ANNEX 1 - BRIEF AGREED WITH THE SCOTTISH OFFICE
Introduction
1.
Recent public concern and media interest in issues such as risks to public health from
spreading organic wastes on land and public nuisance caused by organic waste spread on
lands has heightened the necessity for a strategic overview of the subject.
2.
It is evident that in general discharges to water and air are effectively controlled through a
large body of legislation, regulation and guidance, usually implemented and enforced through
a small number of clearly defined agencies. The same situation does not hold for discharges
onto land, where a number of different organisations and departments operate the controls.
This situation was indirectly recognised in the Royal Commission on Environmental Pollution
report on Sustainable Use of Soil published in 1997.
Scope of the project

3.
Both The Scottish Office and SEPA have recognised that the current situation makes it
difficult for stakeholders, in particular the public, to identify who is responsible for controlling
activities relating to waste spread on land and the related issues of environmental protection,
human, animal and plant health and general protection of soil. It may be that the current
legislative framework is not coping adequately with current waste spreading activities. The
importance of the underpinning science in assessing these issues is recognised but data may
not be available or may be of limited value. Further research may be necessary to inform the
decision-making process.
4.
It is in order to pull together the different strands of these inter-related issues that SEPA has
been directed by the Secretary of State to undertake a strategic review of issues relating to
waste spread on land and to make sure such recommendations as it sees fit.
5.
The basic framework of the report will consider how far soil may be a receptor for a range of
waste materials by examining the following:
(a)
(b)
(c)
(d)
and
(e)
Current practices causing present or potential future concern

The key players
The underpinning science
The current legislation/regulation/guidance
Providing conclusions and recommendations
6.
These strands will be examined individually before being drawn together. It is understood
that the report will ultimately be made public. The scope of the report is illustrated in greater
detail below, along with identified constraints and limitations.
(a)
Current practices causing present or potential future concern
7.
The practices causing greatest concern are the spreading of sewage sludge on land, exempt
wastes on land and the burial of fallen stock. Issues of potential concern in the future include
spreading of slurry and disposal of composted municipal waste on land. SEPA will review
what wastes are currently spread on land, quantifying where data exist and will endeavour to
provide information on the geographical spread of the practices. Probable constraints in this
section will be the lack of readily available data. SEPA will seek to collate such data as are
available both internally and within other organisations such as water authorities, local
65

authorities and The Scottish Office. It does not intend instigating a specific data capture
exercise for data believed to be unavailable at this stage.
(b)
The key players
8.
There are several key players who have a legitimate interest in waste on land issues. These
include SEPA, water authorities, The Scottish Office, health boards, local authorities, SAC,
MLURI, commercial operators, farmers, the public including local residents, food producers
and retailers including the major supermarkets. The role, concerns and legitimate interests of
these players will be examined.
(c)
The underpinning science
9.
SEPAs expertise lies in understanding the environmental impact on water, air and land
caused by-spreading waste on land. It does not have the in-house capability to assess how
such impact translates into effects on human, animal or plant health or the long-term effects
on soil structure or fertility. These skills exist in other public bodies including The Scottish
Office itself. Many of these issues are addressed in recent and current research contracts
commissioned by DETR, and SEPA will build upon and take account of this work.
10
SEPA will comment upon all the environmental issues which are within its technical
competence including the wider environmental context in which the issues sit. It will
acknowledge, draw together and, where appropriate, comment upon human, animal and
plant health issues and will identify key questions and potential players in resolving them.
Potential constraints in this section will relate to SEPAs recognition that it does not have
inhouse expertise to address the latter issues in detail. It will seek comment from external
parties as appropriate, and where necessary will gain access to relevant expertise, for
instance from the Scottish Centre for Infection and Environmental Health, appropriate
academic departments, and the Royal Environmental Health Institute for Scotland.
(d)
The current legislation/regulation/guidance
11.
Items of legislation, regulation or guidance which either control or address waste spread on
land will be identified and examined for their effectiveness and their ability to be applied in a
practical way. This will include reference to the National Waste Strategy: Scotland where
appropriate; to Codes of Practice, EU and UK legislation and supporting regulations; and to
SAC Technical Notes, for example on sewage sludge. SEPA will have regard to any relevant
statements of Government policy affecting these areas during the course of the review.
(e)
Discussion, conclusions and recommendation
12.
The information gathered in the preceding sections will be collated and analysed to provide
a series of conclusions. In particular, the conclusions will seek to identify areas where the
situation is satisfactory, where it is clearly unsatisfactory and any aspects which could be
improved. The conclusions may find aspects of the subject where there are gaps in
knowledge or where practices require changes in legislation in order to address them
satisfactorily. Recommendations will be produced for a way forward, which may include
further research or impinge upon other parties.
Project management
66

13.
The project will be directed by SEPA reporting to a Steering Group drawn from SEPA, The
Scottish Office and COSLA. The Steering Group will receive interim reports on the project at
key milestones. SEPA will put the final report in an agreed format to the Steering Group by
the end of October 1998.
67

ANNEX 2 - QUESTIONNAIRE
STRATEGIC OVERVIEW OF ORGANIC WASTE SPREAD ON LAND
SEPA is seeking information from a wide range of sources in order to bring together
a number of inter-related issues for analysis, from which conclusions can be drawn
and recommendations made to the Secretary of State for Scotland.
The questionnaire is being sent to many different sectors to collect the data we
need. If you feel any question is irrelevant to you, please indicate this. If you have
anything you wish to add in greater detail, or any papers etc. you feel we should
have, please send them to us.
It is our intention to follow up many of the responses with either a phone call or a
meeting. It would be helpful if you could give us a contact name and phone
number.
Thank you for your assistance in responding to us.
68

QUESTIONNAIRE
Section 1
Name of Respondent:.
(Please print)
Position:.
Company/ Organisation:.
(Please print)
Address:
(Please print)
.
.
Contact Name (if different from above):
(Please print)
Contact phone number Contact Fax No
Section 2(A)
Current practices causing present or potential future concern. These include:
sewage sludge on land, exempt organic waste spread on land, burial of fallen stock,
slurry spreading or other agricultural waste disposal on land and disposal of
municipal composted waste on land.
(1)
Do these practices cause you concern?
Yes
No
(2)
If yes which practices cause the most concern and why?
Please continue on a separate sheet if required.
69

(3)
If no please state why
(4)
Could you please provide any data you have available on:
the tonnage and type of sewage sludge arising per annum

Tonnage
the tonnage and form (solid, sludge etc.) of exempt waste arisings per
annum (for example abattoir waste, paper waste etc.)
Tonnage
Type
Form
the numbers of fallen stock arising per annum

Numbers
the tonnage and form (solid, sludge etc.) of slurry and other organic
agricultural waste arising per annum
Tonnage
Form
the tonnage and of municipal composted waste arising per annum

Tonnage
the geographical distribution of the sources and disposal routes

adopted for any of these wastes. (You may wish to enclose a map)
Disposal routes
70

Section 2(B)
There are many organisations and groups who have a legitimate interest in organic
waste spread on land, the key players.
(5)
Please set out what you perceive your role, concerns and legitimate interest
to be.
Role:
Concerns:
Legitimate interest:
Section 2 (C)
We wish to obtain a clear picture of the scientific knowledge which underpins the
practice of spreading organic waste on land.
(6)
Please could you state any concerns you may have regarding the adequacy
of the scientific knowledge?
71

(7)
Can you provide us with information on the chemistry and micro-biology of

any of these wastes?
(8)
Can you provide us with information on the effects of any of these wastes on
land, soil or plant, animal or human health?
(9)
Do you have any information or views on the environmental impact of these

wastes, both short and long term?
72

(10)
Have you participated in any research programmes relating to this issue?

Yes
No. If so, please could you reference it here?
Section 2 (D)
(11)
In your opinion, do the present regulations and legislation offer proper control
over the practice.
Yes. Please state why.
No. If not, which aspects would you like to see amended?
(12)
In your opinion, is there any case for reducing the controls exercised over the
practice?
No.
Yes. Please state why.
73

Section 3
SEPA will be collecting and analysing the information provided in order to make
recommendations to the Secretary of State for Scotland.
Are there any further comments you wish to make on any aspect of the issue?
Signature:..
Date:
THANK YOU VERY MUCH FOR CONTRIBUTING TO THIS OVERVIEW
74

ANNEX 3 - LIST OF PERSONS CONTACTED
Company Name
Blairingone Action Group
Environment Agency
East Ayrshire Council
East of Scotland Water
Friends of the Earth Scotland
Loughborough University
Meat and Livestock Commission
MLURI
National Farmers Union of Scotland
North of Scotland Water
REHIS
RSPB Scotland
SAC
SAC
SAC
J Sainsbury plc
SCIEH
Scottish Association of Meat
Wholesalers
Scottish Consumer Council
Scottish Food Quality Certification
Ltd. (incorporates SQBLA)
Scottish Wildlife Trust
SEPA Board and Regional Boards
Shanks & McEwan plc
Snowie Ltd
Tesco plc
Thames Water Utilities Ltd.
The Paper Federation
The Scottish Office
The Scottish Office
The Scottish Office
The Scottish Office
The Scottish Office
The Scottish Office
The Scottish Office
The Scottish Office
Contact Name
Various
Dr. Nina Sweet
Mr John F Crawford
Mr Bryan Wallis
Mr Kevin Dunion
Dr Judith Petts
Dr M P Grantley-Smith
Professor T J Maxwell
Mr E Rainy Brown
Mr Andy McQueen
Mr John Fraser
Ms Caroline Davies
Professor Garth Foster
Professor Chris Doyle
Dr. Mark Aitken
Ms Alison Austin
Dr Colin Clark
Mr J H A Stevenson
Mr Martyn Evans
Ms Margaret E M Harvey
Mr Ian Duncan Miller
Mr Pete Pollard
Mr Robin Reid
Mr Malcolm Snowie
Ms L Neville-Rofe
Mr Tony Dearsley
Mr Brian Bateman
Mr Stephen Rooke
Dr Andrew Rushworth
Mr A Oliver
Ms F Reid
Mr C Greenslade
Dr P Madden
Mr R McLachlan
Mr J Milne
75

Company Name
The Scottish Office
The Scottish Office
The Scottish Office
The Scottish Office
The Scottish Office
Transorganics Ltd
University of Aberdeen
West of Scotland Water
Contact Name
Ms A Wiseman
Ms J Robson
Mr T Hooton
Mr M Morgan
Mr G Calder
Mr M Holt
Professor T H Pennington
Mr David Stevenson
The contributions from these individuals and organisations is acknowledged with thanks.
76

ANNEX 4 - DESCRIPTION OF SEWAGE SLUDGE TYPES
Sludge type
Undigested liquid
Typical dry
solids
content (%)
2-5
Digested liquid
Undigested sludge cake
20-25
Digested sludge cake
25
Thermally dried
95
Alkaline admixture
60
Description of
process
Description of
product
Arises from primary

settlement and
aerobic biological
treatment of sewage
A liquid with
strong/offensive
odour and potentially
high pathogen
content
Tarry liquid with
reduced odour and
pathogen content
Jelly like - friable
product
Liquid sludge treated

(usually by
anaerobic digestion)
Liquid undigested
sludge which is
dewatered by
pressing
Digested sludge
which is dewatered
by pressing
Cake sludge
subjected to high
temperature
Sludge processed
with alkaline mixture
for example cement
kiln dust
Granules or powder
Soil-like consistency
77

ANNEX 5 - MONITORING REQUIREMENTS - SLUDGE USE IN AGRICULTURE
Sludge Use in Agriculture Regulations - monitoring requirements for PTEs
Maximum permissible concentration limits (mg kg-1 dm) and addition rates (kg ha-1y-1) for
metals in sludge-treated soils.
PTE
Directive 86/278/EEC
Limit
Cd
Cu
Ni
Zn
Pb
Hg
Cr
1 to 3
50 to 140
30 to 75
150 to 300
50 to 300
1 to 1.5
-
Addition rate*
0.15
12
3
30
15
0.1
-
Code
Limit
3***
135**
75**
300**
300***
1***
400***
(provisional)
Addition rate*
0.15
7.5
3
15
15
0.1
15
(provisional)
*
maximum permissible average annual rate of PTE addition over a 10 year period
**
pH 6 - 7
***
pH 5.0 and above
(provisional) applies to Cr
78

ANNEX 6 - BRITISH RETAIL CONSORTIUM/WATER INDUSTRY AGREED MATRIX
REGARDING SAFE APPLICATION OF SEWAGE SLUDGE TO AGRICULTURAL LAND
The UK water industry has reached an agreement with the British Retail Consortium regarding the
safe application of sewage sludge to agricultural land where produce is supplied to retailers.
The matrix specifics target dates by which application of untreated sludge must be phased out, and
specifies those crops to which application of digested or advanced-treated sludge is considered not to
pose a risk to food safety.
The matrix precludes the use of untreated sludge for fruit, salad, vegetables and horticultural
produce, and requires the phasing out of untreated sludge applied to grass and maize by end of
1998 and to combinable and animal feed crops by end of 1999.
The matrix allows for the continued use of advanced-treatment sludge sewage where carried out in
accordance with the Sewage Sludge Regulations and the 1996 DoE Code of Practice for the
Agricultural Use of Sewage Sludge.
The matrix also allows for continued use of digested sludge (with the exception of sludge applied to
fruit, salad and horticultural products) but only where various conditions as specified in the guidance
accompanying the matrix are met.
A steering group has been established, made up of technical experts from the food retail and water
industries together with government and regulatory bodies and chaired by ADAS. The group will be
involved in examining the results of the research programme which the water industry has put in
train to provide the necessary assurances that food safety is not compromised. The results of the
research programme could affect the matrix.
79

ANNEX 7 - EXEMPTIONS TO WASTE LICENSING (WMLR(1994))
Ref
Waste Type
Outlet
Requirements
Waste soil or compost
Agricultural
land
Must provide benefit to

agriculture or ecological
improvement
Waste wood, bark or other plant matter

Sch 3,
Para.
7 (1)
Waste food, drink or materials used in or

resulting from the preparation of food or
drink*
No more than 250 t/ha (or

5000 t/ha of dredgings from
inland waters) to be applied in
any 12 months
If more than one waste applied

then amounts to be combined
Waste lime
lime sludge from cement manufacture or
gas processing
Info must be supplied to SEPA

NB PTE limits do not apply
Waste gypsum
Paper waste sludge, waste paper and
de-inked paper pulp
dredgings from inland waters
textile waste
septic tank sludge
sludge from biological treatment plants
waste hair and effluent treatment sludge
from a tanneries
Sch 3
Para 7
2(a)
Sch 3
Para 7
2(b)
Sch 3
Para 8
Sewage sludge
Railway or
internal
drainage board
operational
land
Forest,
woodland,
park, garden,
verge,
landscaped
area, sports
ground,
recreation
ground,
churchyard or
cemetery
Non
agricultural
land ie
forestry, land
reclamation
sites etc
Must result in ecological

improvement and not cause
exceedance of PTE levels in
soil (as defined in Sludge use
in Agriculture regns)
80

Ref
Waste Type
Outlet
Requirements
Sch 3
Para 9
Waste consisting of soil, rock, ash,

sludge, dredgings from inland waters or
from construction or demolition work
Land
reclamation
sites
Only applies if .the land is

incapable of beneficial use
without treatment
The spreading is in accordance
with a planning permission for
the reclamation or impvt and
results in agric benefits or
ecological impvts
3
No more than 20,000 m /ha

applied
Not applicable to landfill sites
81

ANNEX 8 - AGRICULTURAL WASTES STATISTICS AND TREATMENT
Manure and slurry treatment processes*
Manures and slurries can be subjected to certain treatment to achieve one or more of the following
objectives:
minimise the potential of impacts on water, air and soil quality;

reduce odour;
minimise the potential risks to human, animal and plant health;
reduce transport or landspreading costs;
improve marketability through enhanced public perception of the wastes.
Treatment processes include mechanical, anaerobic and aerobic digestion, acidification and
composting. The suitability of any treatment method is dependent on the chemical and physical
nature of the manure/slurry and the economics of processing and disposal. The potential of many
on-farm treatments is currently limited by high capital costs, and the difficulty of marketing
th
by-products (Govt. Response to 19 Report of RCEP, 1997). Also, it is important that the overall
production and management system should be considered in relation to the control of emissions.
This is because a reduction in one point of the storage/handling process may lead to an increase in
emissions at a later stage.
Mechanical separation
The separation of the solid and liquid fractions of slurries by using mechanical separators such as
screen or belt processes, vibrating screens or centrifuges, may ease handling and storage difficulties.
Separation can produce storable liquids which can be composted and give rise to minimal odour
when applied to land. The liquids, which contain up to 80% of the nutrient value of the unseparated
slurry, pose less of a risk of smothering crops.
Anaerobic digestion
Controlled anaerobic digestion takes place in an insulated gas tight tank. The contents of the tank are
agitated regularly and heated to 35 or 55C. The length of the treatment depends on the type of
slurry: usually 12 to 15 days for pig slurry and 20 days for cattle and poultry slurries.
The main benefits of anaerobic digestion are:
significant reduction in odour (Gornall, 1997, demonstrated this to be as much as an 80-85%
reduction);
reduction in BOD (Gornall, 1997, demonstrated this to be as high as 90%) and dry matter, thus
minimising the chance of creating soil anaerobic conditions and minimising the pollution of
drainage water after field application of digested slurry;
some destruction of harmful organisms and weed seeds (Gornall, 1997 stated that cattle could be
grazed a week after being spread with digested slurry, compared to months for undigested slurry)
improved fertilising value of digested slurry (for example nitrogen stability enhanced);
biogas produced, which can be used for energy production.
Aerobic treatment
Whole or separated slurry can be aerated in specially built tanks, slurry storage tanks or lagoons
through using compressed air or mechanical aerators powered by electrical motors. Correctlydesigned systems can treat slurry in a relatively short period (3 to 10 days), thereby achieving:
82

reduction in odour;
reduction in BOD;
an increased proportion of (plant available) ammonia nitrogen in the slurry, or up to 70% removal
of total nitrogen in the form of nitrogen gas;
pathogen reduction (Ginnivan et al, 1980, demonstrated rapid destruction of Salmonella sp.)
During the aeration, the heat produced increases the temperatures in the insulated tanks to over
30C. This, in turn, accelerates the treatment, and when the temperature rises to 50C, this achieves
killing of some of the harmful organisms and weed seeds in the slurry.
Slurry acidification
By acidifying slurry using mineral acids such as nitrate, sulphuric or phosphoric acid, ammonia
emissions during and after land application can be prevented, thereby increasing the amount of
ammonia available for plant growth.
Use of nitrification inhibitors

Nitrification inhibitors can be added to the slurry prior to spreading to try and reduce the leaching of
nitrogen. Inhibitors maintain the nitrogen in the slurry in the form of ammonia, as opposed to easilyleached nitrate.
The effectiveness of this method is strongly dependent on weather conditions. In addition, it is likely
to work best with surface-spread slurry compared to slurry which is injected or rapidly incorporated
into the soil.
Use of slurry additives/deodorants

Masking agents/additives can be added to slurry to control site smells when it is not possible to deal
effectively with the source. However, the effectiveness of this approach is open to question.
Composting
Composting is a natural aerobic process which stabilises organic matter, such as livestock manures
and slurries. This helps to prevent further degradation of the wastes which, stored under normal
anaerobic conditions, can generate gases and obnoxious smells. The high temperature which occurs
during composting can significantly reduce the viability of weed seeds and kill off harmful organisms.
The following livestock wastes are suitable for composting: the separated solids from cattle and pig
slurry and poultry manure/litter. Composting can provide a potentially marketable product.
Silage effluent
Silage effluent can be treated by an aeration process which achieves a 95% reduction in BOD, to
approximately 1000mg/l. Although this effluent is not suitable for direct discharge to a watercourse, it
can, however, be applied to land without dilution (while still observing the PEPFAA Code
recommendations for land applications of waste). Aeration can also increase the pH value of the
effluent from 4 to over 8, thereby reducing its corrosive nature.
* Further details can be found in reference (SOAEFD, 1997).
83
Represents local authorities

who are regulators and
waste collection authorities
Environmental and Public
Health
Waste Water Treatment and
Beneficial recycling of the
sludges
NGO; environmental
pressure group
Academic studies of public
perception of risk
Promotion of meat
production and consumption
Research and advice
CoSLA
Adviser on public health;

professional institution
Conservation NGO
Food retailer
REHIS
RSPB
J Sainsbury plc
Promotion of farmers
interests
As ESWA
National Farmers Union

of Scotland
NoSWA
Meat & Livestock

Commission
MLURI
Loughborough University
Friends of the Earth
ESWA
East Ayrshire Council
Role
Local public
Organisation
Blairingone Action Group
Effect on bird habitats

Impact on business; protection of
customers
Safety; effect on human health
84
Environmental Protection/ensuring effectiveness of legislation

Safeguard customer confidence
Duty to dispose of societys waste and part of core business to

achieve this under BPEO - secure outlet for sludge; cost
human health; safety of practice; transmission vectors
Undertake research commissioned by SOAEFD on behalf of

public
Provide information and advice to protect soil
Promotion of sound environmental practice by members
Impact on soil and plant health
Detrimental effect of practices on

members business
Impact on core business
Ensuring current practice does not affect its interests
Independent pressure group view of environmental policy and

protection
Source of information
Local Authoritys public and environmental health protection

roles
Secure outlet for sludge; cost
Interest
Public interest in ensuring activity is legal and does not cause
nuisance
Local Authorities public and environmental health protection
role
Impact on meat production
Environmental interests and best use

of resources
Outlets for waste; nuisance; public

health
Concern
Detrimental impact on quality of life
ANNEX 9 - PARTICULAR INTERESTS IN ORGANIC WASTES SPREAD ON LAND

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Contacted
Yes
Water authorities
Health
Animal health - vet
Plant health
Industry dept.
Energy, Economic
impact
Sustainable
development unit
Organisation
SEPA sponsor
Waste
Scottish Office
Scottish Food Quality

Certification Ltd.
SCIEH
Scottish Association of
Meat Wholesalers
Scottish Consumer
Council
Organisation
Scottish Agricultural
College
Interest
Concern
Role
85
secure route for sludge disposal costs

vector for disease, standard of practices, practices carried out
vector for disease, security and outlet for animal wastes
vector for disease, plant health in long term
cost implications for industry, promotion of best practice;
promotion of renewable energy sources
secure outlet for all waste arisings
sustainability of practices
National waste strategy, outlet for

waste
Secure sludge outlet/costs
Human health implications
Animal health; security and outlet
Effect on plant health
Power generation from waste, impact
on industry
To see sewage sludge treated to make it free of pathogens and

with defined analysis. To ensure current practices are safe and
can be quality assured
Health implications for consumers; cost; represent consumers
Impact on human health
To ensure wastes on land are free

from pathogens
Human health; safety of practice; transmission vectors

Quality assurance
Interest
To bring detailed professional skills and advice to the subject
area; to provide information on policy trends and to undertake
research
Effect on human health

Impact on members business
Concern
Impact on soil, plant and animal health
policy
policy
policy
policy
policy
policy
policy
Government policy and

development
Role
To provide advisory,
consultancy and scientific
services for government
departments, regulators,
farmers, waste producers
and waste contractor to
promote and support
responsible waste
management
Adviser on public health
Representative body in part
of food chain
Represent, promote and
safeguard the interest of
consumers in Scotland
Farm Assurance Schemes

Contacted
Yes
?
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Contacted
Yes
Lead body for the paper

industry
Independent company
specialising in the recycling
of suitable wastes to
agricultural land owned by
third parties
Expert advice via Professor
Pennington
As ESWA
The Paper Federation
Transorganics Ltd
WoSWA
University of Aberdeen
Tesco plc
Waste Management
Contractor
Food retailer
NGO with conservation

interests
Waste Management
Contractor
Snowie Ltd.
Shanks & McEwan plc
Scottish Wildlife Trust

Impact on business; protection of

cust9omer
Landspreading is an important re-use
option for the paper industry which
provides a BPEO option that is
preferable to landfilling. It contributes
to the Governments waste strategy
Impact on business
Impact on business
Impact on business
Impact on habitats
86
Security outlet for sludge; cost of disposal
Research and development; provision of advice
The continuation of recycling or organic wastes to agricultural

land and believe that this be done efficiently with correct checks
and benefits to ensure sustainable long term outlet
Need to safeguard consumer confidence by practically looking

at and resolving threats
Securing re-use option outlet
Independent pressure group view of environmental policy and

protection
To provide some possible alternative management solutions
which make use of existing facilities (or new technologies) and
best working practices as well as utilising existing control and
monitoring regimes currently used by SEPA
Safe disposal of wastes to land
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

ANNNEX 9a - SUMMARY OF CONCERNS RAISED BY BLAIRINGONE ACTION GROUP
General
Uncertainty as to what is contained in the waste
Greater inspection facilities required
Better liaison required between those involved in transportation, application of materials, Local
Authorities, water authorities, inspection and environment control groups, contractors, landowners,
farmers and community councils
Public, animal and plant health

Immediate response required to public concerns re contamination of land water or air (including
odour)
Proximity to human settlements should be considered in detail
Night-time application should cease
Information required on application of waste to land and subsequent use of land for grazing, hay,
crops, public access and recreation
Exempt wastes should be certified as free of harmful substances by independent analysis at
expense of waste producer
More attention should be given to odour control
Prosecution should follow if pollution occurs
Protection of the soil

No untreated wastes should be applied unless rigorous analysis establishes the waste as
innocuous
National and local registers should be publicly available including at the site during application
Spot checks should be conducted by regulators on the nature of material and rate of application
Code required detailing qualities of wastes and active constituents
Scientific proof required that wastes applied result in land improvement without detriment
Research required into long term use of such materials
Better knowledge required re how land and water tables react to application and injection of
wastes, including multiple wastes
Knowledge of farm drainage systems should be improved
Statutory testing of farmland required to determine nutrient requirements
Specific rules should apply to exempt wastes that include mixtures of wastes and their interaction
Legislation
Application methods, rates and monitoring of application currently inadequate

Clear distinctions should be made in legislation regarding types of sewage treatment
Contractors should make public the nature and content of the material being disposed of
Increased powers of enforcement required for example for SEPA
Consideration required re appointment of a new agency specifically equipped for this task
Consideration should be given to the possibility of regulators suffering a penalty in failing duty to
regulate
Records should be kept by farmers and landowners of materials used on land including on-farm
wastes (including inorganic fertilisers)
Substantial penalties required for those failing in duties to apply regulations
Controlled application of safe organic fertilisers should be in the control of the public sector
Recommendations of good practice in the PEPFAA code not applied or enforced
87

ANNEX 10 - NUTRIENTS IN SEWAGE SLUDGE AS SPREAD
Table 1
Sludge Type
Total
Available
P2O5
K2O
P2O5
K2O
1.5
0.7
0.1
0.5
0.3
0.1
Digested liquid (kg/m )
1.8
1.0
0.1
1.1
0.5
0.1
Undigested sludge cake (kg/t)
9.5
7.0
0.3
1.9
3.5
0.3
Digested sludge cake (kg/t)
10.0
12.0
0.4
2.0
0.6
0.4
Thermally dried (kg/t)
35
44
2.0
5.0
10
2.0
Alkaline admixture (kg/t)
4.5
4.1
6.0
0.7
0.6
6.0
Undigested liquid (kg/m )

3
Conversion factors
3
kg/m x 9 - units/1,000 gallons
kg/t x 2 = units/ton
Some loss of N is inevitable, largely as a result of nitrate leaching losses, particularly if digested
liquid sludge is applied in the autumn. Digested liquids can also lose nitrogen by ammonia
volatilisation when surface spread in warm sunny conditions. These losses are less with other sludge
types which contain far less ammonium nitrogen. A guide to the potential losses of available nitrogen
is given in Table 2. Phosphate is not readily lost by leaching although potash may be subject to
leaching losses.
Table 2
Sludge Type
Available nitrogen loss (%)

Timing
Autumn
Winter
Spring
Summer
Digested liquid - surface spread
80
40
0-20
0-30
Digested liquid - injected
100
70
0-20
Digested cake, thermally dried or

alkaline admixture treated
20
10
In addition to nitrogen and phosphate, sludge can also be a good source of sulphur, magnesium and
sodium. A typical sludge application (5 t/ha as dry solids) will supply 50-80 kg/ha sulphur with up to
40% being available (depending on the type of sludge). However, sulphur from sludge will be liable
to leaching during the autumn and winter. In some treatment processes (for example alkaline
admixture treatment), lime is added and this makes the sludge a useful liming material for acid soils.
Care must be taken to avoid raising the soil pH too high through excessive applications of sludges
containing lime as this may lock up some trace elements.
(Source: SAC technical note T450)
88

ANNEX 11 - TYPICAL CONCENTRATION OF POTENTIALLY TOXIC ELEMENTS IN
SCOTTISH SOILS AND SLUDGES AND THE NUMBER OF SLUDGE APPLICATIONS TO
RAISE AN UNCONTAMINATED SOIL UP TO THE MAXIMUM ACCEPTABLE
CONCENTRATION. (Source SAC technical note T450)
Typical sludge metal

concentration (mg/kg)
Potentially toxic element

Nickel Cadmium Lead Mercur
y
(Ni)
(Cd)
(Pb)
(Hg)
Zinc
Copper
(Zn)
(Cu)
630
300
30
270
2.2
55
20
25
0.5
20
0.1
50
Normal soil concentration

(mg/kg)
Chromium
(Cr)
80
UK Maximum allowable
soil concentration, pH
5.5-6.0 (mg/kg)
200
100
60
300
400
Number of applications *
to reach limit value
113
160
700
500
553
245
3,818
(Pb)
(Hg)
(Cr)
170
2.0
* Assumes each application
QUALITY OF SLUDGE USED IN AGRICULTURE IN SCOTLAND

(Source: Gendebien et al, 1998)
Sludge concentration
-1
mgkg ds median
(Zn)
(Cu)
(Ni)
508
254
20
(Cd)
1.23
37
89

ANNEX 12 - COMPARATIVE RISKS RE PATHOGENS ASSOCIATED WITH LAND
APPLICATION OF SEWAGE SLUDGES, FARM WASTES AND EXEMPT WASTES
Highest risk
#####
!
####
Waste
!
###
!
##
Minimal risk
#
Animal
health
Plant
health
Human health via

1
animal products
Human health
2
via soil
###
#
#
#
#
##
##
##
##
#
#
#
#
##
##
##
####
##
##
##
##
###
###
###
##
#
#
#
#
##
##
##
#####
###
##
#
####
###
###
##
####
###
##
##
##
##
##
#
#
###
#
##
####
###
##
##
##
#
####
##
#
#
#
#
##
#
#
#
#
#
#
#
#
##
###
#
#
#
#
#
#
#
#
#
#
#
#
#
#
#
#
#
Sewage Sludge 4
Raw Sludge
Pasteurised
Digested - thermophilic aerobic
Digested - mesophilic anaerobic
Composted
Lime stabilised
Stored - as liquid
Dewatered and stored
Farm animal wastes
Upper range5
Lower range5
Exempt wastes
Septic tank sludge & cesspit waste
Blood & gut content from abattoirs
Waste from food industries
Compost and waste soil
Water works sludge
Dredgings from inland waters
Waste hair & effluent treatment
sludge from a tannery
Waste from beverage industries
Waste from vegetable processing
Wood & green plant material
Paper industry waste
Textile waste
Lime, cement & gypsum waste
* Source. Davis et al, 1998
Actual risk to human health will be dependent upon herd management, hygiene during product processing and kitchen hygiene.
Contaminated soil brought into the kitchen on vegetables and subsequently contaminating other foodstuff.
4
Assumes treatment and disposal in accordance with the Code of Practice
5
Dependent upon farm husbandry practices, waste treatment practices and waste disposal practices
2
90

ANNEX 13 - SLUDGE TREATMENT TO REDUCE PATHOGENS
Process
Descriptions
Sludge pasteurisation
Minimum of 30 minutes at 70oC or minimum of 4

o
hours at 55 C (or appropriate intermediate conditions)
followed in all cases by primary mesophilic anaerobic
digestion.
Mesophilic anaerobic digestion
Mean retention period of at least 12 days primary

o
o
digestion in temperature range 35 C 3 C or of at
least 20 days primary digestion in temperature range
o
o
25 C 3 C followed in each case by a secondary
stage which provides a mean retention period of at
least 14 days.
Thermophilic aerobic digestion
Mean retention period of at least 7 days digestion. All

o
sludge to be subject to a minimum of 55 C for a
period of at least 4 hours.
Composting
(windrow or aerated piles)
The compost must be maintained at 40oC for at least

5 days and for 4 hours during this period at a
o
minimum of 55 C within the body of the pile followed
by a period of maturation adequate to ensure that the
compost reaction process is substantially complete.
Lime stabilisation of liquid sludge
Addition of lime to raise pH to greater than 12.0 and

sufficient to ensure that the pH is not less than 12 for
a minimum period of 2 hours. The sludges can then
be used directly.
Liquid storage
Storage of untreated liquid sludge for a minimum

period of 3 months.
Dewatering and storage
Conditioning of untreated sludge with lime or other

coagulants followed by dewatering and storage of the
cake for a minimum period of 3 months. If sludge has
been subject to primary mesophilic anaerobic
digestion storage to be for a minimum period of 14
days.
91

ANNEX 14 -
A SUMMARY OF THE VARIOUS BENEFITS AND DISBENEFITS OFFERED

BY THE WASTE TYPES COVERED IN THIS REVIEW (Summarised from
Davis and Rudd 1998)
Waste
Sewage sludge - undigested
liquid
Sewage sludge - digested
liquid
Sewage sludge - cake
Sewage sludge - thermally
dried
Agricultural waste
Compost
Soil
Waste Wood, Bark Or Other

Plant Matter
Dairy Wastes
Sludge
From
Biological
Treatment Plants For Food
Wastes
Benefit
Slow release nitrogen and phosphorus
Disbenefit
Pathogen content
Nitrogen and Phosphorus
Rapid release of nutrients can lead

to water pollution
less suitable for grazing land - slow
breakdown
high organic matter content - good soil

conditioner
high organic matter content - good soil
conditioner. N & P content & relatively
odourless
Nutrients and soil conditioning
Nutrients
Soil is spread on land to assist in the
formation of a soil or to act as a soil
substitute in land reclamation or
levelling.
Long term benefits can be realised due
to the high organic nature of the waste.
Chipped wood or bark can be used as a

mulch to discourage weed growth and
conserve soil moisture
Dairy wastes can act as a source of
nitrogen, potassium, phosphorus and
trace minerals
Produces a waste which is high in

readily available nitrogen.
Metals in pig slurries, nutrient

enrichment pathogens
Soils can be contaminated with
metals
and
other
phytotoxic
substances which can have a
detrimental effect on plant growth.
Sawdust and other wood wastes can
contain preservatives such as
pentachlorophenol and lindane, and
pesticides such as copper chrome
arsenate.
Waste plant matter can act as a
source of infection for succeeding
crops.
Due to the high BODs (average
26,000mg/l, max 260,000 mg/l
present in many dairy wastes they
can be highly polluting with
potentially serious consequences
should they contaminate a water
course.
Dairy wastes with an oil or fat
content => 4% can have detrimental
effects on plant growth. The oil or fat
coats the soil particles creating a
waterproof barrier preventing plants
roots from extracting water
Some of these wastes can have a
high nutrient and BOD content which
if over-applied especially in wet soils
can cause anoxic soil conditions
leading to crop growth problems.
High BODs and nutrient contents
can cause severe pollution in water
courses.
92

Waste
Salty Food Wastes
Benefit
Large concentrations of N, P and K
(>1kg/m3) are often found
Sodium will be present in moderate

amounts which is required as a plant
nutrient by specific crops.
Lime sludge
Vegetable/Soil
The high pH of this waste means it has

a neutralising value of 10-20% and is
used to correct, decline or raise soil pH
values
Vegetable matter has a high N,P and K
content.
Brewery, Distillery and Soft

drinks Wastes
Most of these wastes have a nutrient

content which can be beneficial. The
nutrient content of some wastes is high
for example kieselguhr sludge used to
clarify brewing liquors
Blood
Blood has a high nutrient content and is

therefore of excellent fertiliser value.
Nitrogen content is extremely high, in
excess of 15 kg/m3 total N, and 2 kg/m3
of ammonium nitrogen being typical.
Potassium and phosphorus contents are
of the order 1-2 kg/m3
Stomach Contents
A balanced mixture of nutrients is

usually present: N 5 kg/m3; K 1 kg/m3;
and P 1 kg/m3.
Disbenefit
The salts in salty wastes can lead to
soil structural damage, reduce the
availability of soil water for plant
uptake, and can be toxic to plant
growth
Application of salty wastes can
produce
high
soil
electrical
conductivity
resulting
from
applications in dry conditions.
The over application to certain soils
and crops can result in trace element
deficiencies in crops and soils.
Often these wastes have a low solids
content, approximately 1%, which
means there is a high transportation
cost in proportion to the quantity of
nutrients carried. This also means in
order to get any benefit from the
waste the application rates can often
be high increasing the risk of
pollution of water courses.
The nutrient content of some of
these wastes is low therefore the rate
of application is high to realise any
benefit leading to an increased
pollution risk.
Many of these wastes have a high
carbohydrate content which on
oxidation can lead to a reduction in
pH of the waste.
Distillery wastes can have a
significant levels of copper which is
phytotoxic.
High salt concentrations can lead to
the problems identified in the earlier
section on salty food wastes.
The high BOD nature of blood
means over application can result in
anaerobic soil conditions.
If surface spread on soil there is the
possibility of disease transmission.
Blood wastes will contain pathogens.
If surface spread on soil there is the
possibility of disease transmission.
Stomach contents can cause a foul
odour.
93

Waste
Waste Lime and Lime Sludge
From Cement Manufacture
Or Gas Processing
Benefit
These wastes have pHs in the order of
10-12 and have neutralising values in
the order of 20-40%
Waste Gypsum
Gypsum is a useful soil conditioner

particularly effective on soils which have
been subject to saline intrusion and clay
soils.
Paper Waste Sludge, Waste

Paper and De Inked Paper
Sludge
In soils which are sulphur deficient

gypsum can significantly improve crop
yield
High organic content can improve the
soil structure.
Depending upon the process the waste

can have a lime content which can give
a neutralising value of around 10%.
Dredgings
Waters
From
Textile Wastes
Inland
Dredgings can supply organic matter

and nutrients in the form of phosphate
and organically bound nitrogen
The major nutrients are present.
Disbenefit
Cement kiln dusts usually contain
the residues from the combustion of
materials used to generate the high
temperatures. These residues are
potentially toxic to crops there
consumers.
The production of acetylene gas
produces thiourea as a by product
the consequences of land application
of which may be uncertain.
Contamination
by
metals
is
common.
Flue gas desulphurisation gypsum
will contain residues from the
combustion process from which it
arises
Paper wastes have a high C:N ratio

which will deprive crops of N or
immobilise when they are applied to
the soil.
There is the possibility of other
contaminants in the waste for
example Zn in wastes from recycled
waste paper, other metals from the
dyes used to colour the papers, and
dioxins from the bleaching of papers
using chlorinated compounds If
stockpiled for long periods of time
the wastes can go anaerobic leading
to odour nuisance when the crust is
broken.
Inland water ways often run through
urban and industrial areas and
sediments have become
contaminated with various
contaminants. As well as chemical
contaminants there may be a risk of
pathogenic contamination if the
dredgings were for example taken
from downstream of a sewage
works.
Dyes in textiles can be washed into
and concentrated in these wastes.
These dyes have a metal content
which can reach levels of several
100 mg/kg
Organophosphorus and
organochlorine compounds can be
found in the grease fraction of the
sludge.
94

Waste
Septic Tank Sludge
Benefit
Septic tank sludge can supply nitrogen,
phosphorus and potassium
Sludge from Biological

Treatment Plants
The organic content of these wastes

consists of bacterial cells therefore high
levels of N, P and K at neutral pHs can
be found
Waste Hair And Effluent

Treatment
Sludge
From
Tanneries
High levels of N can be found in this

waste.
Mixtures of wastes
Wastes which can offset disbenefits off

other wastes can be mixed together for
example wastes high in freely available
nitrogen can be mixed with paper waste
to offset the problem of tie up of N due
to high C:N ratio.
If analysis is carried out and wastes
mixed in measured quantities wastes
with different nutrient properties can be
blended to provide a better nutrient
balance.
Disbenefit
Odour and pathogenic problems
Litter items in septic tank sludges
include condoms and backings from
sanitary towels.
These
sludges
can
contain
contaminants from the processes
they serve. These will be process
specific & will include metals and
organic contaminants
Due to a high sulphide content these
wastes can be odorous. These
wastes may also contain a high
sulphide content.
There has been little work carried out
on the synergistic effects of mixing
wastes prior to application to land.
Mixing can result in stripping of fields
due to the variable nutrient content
in the wastes.
95
High
Medium
Low
pathogens
Consequence
future
< 1%
Compost
Probability
pathogens
Probability
Consequence
Chronic
BOD +
nutrients
pathogens
small
BOD,
POPs
POPs
pathogens
Fallen
Stock
chronic
acute
/
pathogens)
Consequence
Envt
Human
Surface water
Sludge
Probability
Sewage
1%
Consequence
Waste
Probability
3%
Exempt
Probability
Consequence
96%
Agricultural
Waste
Quantity
Waste
ANNEX 15 - RISK ASSESSMENT MATRIX - working sheet

pathogens
nitrate
E.coli &
nitrate
Human
96
pathogens
depends on
waste
?
nitrate
?
Human
POPs metals
?
pathogens
/ as above
Envt
/pathogens
metals
pathogens
metals
/POPs
metals, EDCs
nutrients
as above
as above
Risk Assessment
Land
? nitrate
pathogens
Envt
?
Groundwater
untreated
treated
Human
Air
Envt
/
depending
on source of
material
regardless
of trt
Social
Implication
Revisions of codes of practice/legislative changes
less appropriate
appropriate
highly appropriat
$
$$
$$$
$$$
$$
$$$
$$$
97
Replace with a common framework embodied in regulations
Link to financial incentives
Farm Assurance schemes
$$$
$$$
Financial incentives
$$
Centralised collection
$$$
$$$
$$$
$$$
Authorisation of contractors/operator competency
Prior justification against objective criteria to protect

land
Site suitability assessment
Revised application rates
Revised application timing
Revised application methodology
Farm nutrient plans/farm management plans
Preparation of working plan
Pre-notification of spreading operations
not practical
$$$
$ $ $ (varies
according to waste
type)
Improve pre-treatment/waste minimisation
$/$$$
$$$
$$$
Increase producer storage
Sewage
Sludge
Exempt
Waste
Agricultural
Waste
Control Option
ANNEX 16 - ASSESSMENT OF MANAGEMENT OPTIONS - working sheet

(The following represent the ideal situation as opposed to the existing system).

$$$
$$$
$$
RENDER
NO
Fallen
Stock
$$$
$$
$$$
$/$
$$$
Compost

ANNEX 17 - POTENTIAL ADVERSE EFFECTS FROM APPLYING EXEMPT WASTES
TO AGRICULTURAL LAND
Material
Potentially
toxic
elements
Organic
Contaminants
Pathogens
Water
pollution
risk
Soil
pollution
risk
Air
pollution
risk
L-M
Waste wood, bark or

other plant material
Unlikely to be
contaminated
Waste food, drink or

materials used in the
preparation
L-H
M-H
Unlikely to be
contaminated
Blood and gut contents

from abattoirs
Waste lime
L-M
L-M
Lime sludge from

cement manufacture or
gas processing
L-M
Waste gypsum
Paper waste sludge,

waste paper and deinked paper pulp
L-M
M-H
Risk of
contamination
depends on
source
Textile waste
L-H
Risk of
contamination
depends on
source.
Septic tank sludge
High risk of
pathogens,
odours and
water pollution
Dredgings from any

inland waters
General
Comments
Risk of
contaminants
depends on
source
High risk of
pathogens and
water pollution
Risk of
contamination
depends on
source. Avoid
over-liming
Risk of
contamination
depends on
source. Avoid
over-liming
Risk of
contamination
depends on
source
Risk of
contamination
depends on
source. Maybe N
lock-up
98

Potentially
toxic
elements
Organic
Contaminants
Pathogens
Water
pollution
risk
Soil
pollution
risk
Air
pollution
risk
General
Comments
M-H
Risk of
contamination
depends on
source
Waste hair and

effluent treatment
sludge from tanneries
M-H
Risk of
contamination
depends on
source
Brewery waste
M-H
L-M
Unlikely to be
contaminated
Distillery waste
L-H
L-M
Possible high
copper content
Fish farm waste
L-M
L-M
L-M
L-M
Possible
residual
pesticides
L-M
MH
M-H
Possible
Scorching Due
To High Salt
Content And
Risk Or Odour.
Material
Sludge from biological

treatment plants
Dairy/Cheese Waste
L
M
H
=
=
=
low risk, unlikely to be a problem

medium risk, a possible problem unless strict precautions are followed
High risk and likely to be a serious problem unless strict precautions are carried out
(Source SAC technical note T459)
99
Plate 1: Injection of sewage sludge
Plate 2: Experimental trial using digested sewage sludge
Plate 3: Application of slurry
Plate 4: Application of slurry
Plate 5: Application of farmyard manure
Plate 6: Application of distillery waste
Plate 7: Paper mill sludge post application
Plate 8: Composting process

OrganicWasteSpreadOnLand PDF

Încărcat de

Informații document

Descriere originală:

Titlu original

Drepturi de autor

Formate disponibile

Partajați acest document

Partajați sau inserați document

Opțiuni de partajare

Vi se pare util acest document?

Este necorespunzător acest conținut?

Drepturi de autor:

Formate disponibile

OrganicWasteSpreadOnLand PDF

Încărcat de

Drepturi de autor:

Formate disponibile

STRATEGIC REVIEW OF ORGANIC

WASTE SPREAD ON LAND

Current legislation/regulation, guidance and control mechanisms

Conclusions and recommendations

STRATEGIC REVIEW OF ORGANIC

Brief agreed with Scottish Office

List of persons contacted

Description of sewage sludge types

Sludge use in Agriculture Regulations - monitoring requirements for PTEs

British Retail Consortium Matrix

Exemptions to Waste Licensing

Agricultural wastes statistics & treatment

Particular interests in organic wastes applied to land

Summary of Blairingone Action Group concerns

Nutrients in sewage sludge as spread

PTEs in Scottish soils and sludges

Comparative risks from pathogens associated with land application

Sludge treatment to reduce pathogens

Benefits and disbenefits of the various wastes

Risk assessment matrix

Control options matrix

Risks - exempt wastes

Injection of sewage sludge

Experimental trial using digested sewage sludge

Application of farmyard manure

Application of distillery waste

Papermill sludge post application

STRATEGIC REVIEW OF ORGANIC

Current estimates of the tonnage of waste applied to land in Scotland are:

STRATEGIC REVIEW OF ORGANIC

A competency scheme for contractors should be introduced, similar to the WAMITAB

STRATEGIC REVIEW OF ORGANIC

STRATEGIC REVIEW OF ORGANIC

Information relating to fallen stock is also discussed

STRATEGIC REVIEW OF ORGANIC

The nineteenth report of the Royal Commission on Environmental Pollution on Sustainable

STRATEGIC REVIEW OF ORGANIC

East of Scotland Water Authority

STRATEGIC REVIEW OF ORGANIC

North of Scotland Water Authority

West of Scotland Water Authority

Industrial wastes which are exempt from licensing - exempt wastes

STRATEGIC REVIEW OF ORGANIC

STRATEGIC REVIEW OF ORGANIC

Amount recycled to land 1997

STRATEGIC REVIEW OF ORGANIC

There is currently no composting of MSW in Scotland. However, a number of local

STRATEGIC REVIEW OF ORGANIC

Other composting activities in Scotland include co-operation between the University of

STRATEGIC REVIEW OF ORGANIC

STRATEGIC REVIEW OF ORGANIC

The ability of local interest/action groups to collate evidence of nuisance/risks associated

Transparency of information is crucial. Communication in a format easily accessible to

As a means of addressing public stakeholder interest, consideration should be given to

STRATEGIC REVIEW OF ORGANIC

Current estimates of the percentages of the various wastes applied to land in

There is currently considerable pressure to increase the levels of treatment of

There is currently no accurate record of the amounts of exempt wastes applied to

Information pertaining to the nature of exempt wastes and agricultural wastes is

Agricultural wastes applied to land are in general not treated.

STRATEGIC REVIEW OF ORGANIC

STRATEGIC REVIEW OF ORGANIC