With the start date for the government’s national fallen stock scheme pushed back until next autumn, the uncertainty surrounding the options for dead bird disposal continues. In this special feature, the Ranger answers the questions egg producers are now asking…
Can I legally bury carcasses on the farm? The answer is no. As from May last year this was prohibited under the EU’s Animal By-Products Regulation. However, Defra have said that because of the delayed start of the collection scheme enforcement agencies have been requested to take a “pragmatic approach”.
Will the collection scheme include poultry? The official line from Defra is that poultry will be included but the industry view is that it is unlikely to be cost effective—except perhaps for the very largest producers—and the scheme will certainly not be available for the fees first suggested.
Can I use an incinerator? This is likely to be the most practical option for egg producers but the incinerator must be of an approved type and meet the stringent new standards that now apply to low capacity incinerators (less than 50kg/hour throughput). Requirements include the fitting of an after-burner which is capable of heating the flue gases to a temperature of 850ºC and retaining them for at least two seconds. Producers will also have to keep detailed records of the operating temperatures.
How much will an ‘approved’ incinerator cost? So far only two UK manufacturers have gained approval for their incinerators (a third company has recently entered into receivership) and costs range from £5,000 to £7,500.
On top of this has to be added the cost of providing a concrete base and some form of structure to protect the incinerator from the elements. A power supply will also need to be laid on. One company, Bodo Fabrications, is currently trying to gain approval for a machine with a lower price tag but still capable of handling the mortality from all but the very largest free range units. The company has fitted a bigger after-burner to its popular ‘Norfolk’ model and with manual temperature recording as opposed to the automatic read-outs employed on more sophisticated machines, the price should be under £2,500. The equipment does not require an electricity supply offering a further saving. Subject to Defra approval, a company spokesperson told the Ranger that they hope to launch the incinerator in time for this year’s Pig and Poultry Fair.
Can I use my present incinerator? Unless you have bought a machine in the last month or so it is unlikely to have had ‘Type-Approval’ and therefore will not meet the current regulations. But Defra have agreed to a transitional period for those incinerators in operation on or before 1 November 2002. These will be allowed to continue until the end of this year providing they have been registered and inspected by Defra, and meet some basic requirements mainly regarding the handling and storage of the resulting ash.
To qualify for this transitional arrangement producers must have applied to Defra by 30 April 2004. This date has been extended from the original deadline of 29 February following direct intervention by BFREPA, who successfully argued with Defra that insufficient notice had been given to producers. The 12 page application form can be obtained from your local Defra Animal Health Office or downloaded from www.defra.gov.uk/corporate/regulat/forms/Ahealth/by-products/index.htm
Incinerators that started in use after 1/11/02 must meet the full requirements of the new regulations before they can continue in operation.
Can I convert my existing incinerator to an approved type?
It is possible that existing equipment can be converted to meet the new regulations but this may not prove a cost-effective solution. In the first instance producers are advised to contact the maker of the original equipment, or by contacting incinerator manufacturer Waste Spectrum (01905 362113) they can receive a free of charge health check on their existing incinerator and be advised on a possible upgrade.
Can I share an incinerator with my neighbour? Yes, this is allowed but the incinerator should be sited on premises which have no livestock. If the premises were originally part of the livestock holding, it must be treated as completely separate ie fenced, with a dedicated entrance and equipment, and, say Defra, with a dedicated operator where possible. The ash from a shared incinerator will be considered as controlled waste and disposal will have to be via land fill sites. In contrast, the ash from a producer’s own incinerator (provided it is derived from non-specified risk material, which poultry is) will be classed as agricultural waste and can be spread on the land.
What about oil-drum ‘incinerators’? It is no secret that there are producers who successfully reduce their dead hens to a pile of ash in nothing more than an adapted 45 gallon oil drum, powered by solid fuel. Clearly even the most imaginative and enterprising incinerator manufacturer is unlikely to come up with a conversion kit for these models!
When the Ranger approached Defra for their view on ‘oil drums’, not surprisingly there was no endorsement of this particular disposal method. A department official did say that if premises were inspected by Defra and such equipment was in use, they would expect the producer to be taking active steps to replace it with a fully approved incinerator, or switch to an alternative method of disposal. It should not be viewed, said Defra, as a means of delaying the purchase of the correct equipment until the end of the year.
Apart from incineration, what are the other options? In the absence of any firm details about poultry’s inclusion in the national fallen stock scheme, the other option open to the poultry industry is to use a commercial renderer. While very large producers may be able to justify a regular collection service, this is unlikely to be an option for most free range egg producers, due to the limited number of carcasses involved. However, it is permissible to deliver dead birds to a rendering plant and this could prove an economic solution for those producers within close proximity of the premises.
This is exactly what one BFREPA member does—who lives nine miles away from a plant—and he told the Ranger he was currently being charged a rate based on £50 per ton which amounts to around 10p a bird. The company had offered a weekly collection service from the farm but this would incur an additional charge of £45 a week. But with only seven plants able to handle poultry carcases in England, this method of disposal offers limited scope. According to the UK Renderers Association the plants are situated in Exeter; Nuneaton; Widnes; Stafford; Lincoln; Bradford; and Lancaster. The UKRA confirmed that charges would be in the region of £40 - £50 per ton for material delivered in this way.
There are also commercial incinerating companies who are licensed to handle livestock but again, with around 25 in total, delivering carcasses to them will only be an option if producers are based reasonably close, although the use of a freezer would minimize journeys. One such company, already accepting material from poultry farmers, told the Ranger they were charging 19p/kg. For 10,000 birds with average mortality, that could mean a bill of around £250 across the life of the flock.
A further possibility is that local hunts—who will have to operate approved incinerators or dispose of their animal waste through a legitimate outlet—may accept poultry, but again at a cost.
Can any more be done to oppose these new rules? The Animal By-Products regulation is an EU Directive and officials in the UK say their hands are tied.
However, BFREPA is extremely concerned about the financial impact—particularly for smaller producers where the cost of incinerating equipment will be crippling when spread across a small amount of birds—and the a
