MEMORANDUM BY THE LANES GROUP (DSW 51)
We are an informal community action group known
collectively as LANES.
Our special interest at this time is in the
national strategy to reduce the mass and volume of organic waste
by composting.
Living and working in a largely rural and farming
county we started with some practical experience and understanding
of the subject. Over the past year we have carried out research
at home and abroad, making use of the technical and administrative
skills of our members.
We have now considered the very large amount
of information and advice from a wide variety of reliable sources
including: universities, professional associations and leading
specialists, commercial organisations and government bodies across
Europe and North America.
It is disappointing to find no mention in Waste
Strategy 2000 on the use of waste disposal units (macerators)
for discharging domestic and trade catering waste into public
or private sewage systems. We believe that where capacity exists
that would be far preferable to "source separation"
and house to house or kerbside collection which inevitably increases
air pollution and traffic problems as well as creating hygiene
difficulties.
We suggest that the requirements and inspection
arrangements for containers and vehicles collecting kitchen waste
for composting should be no less stringent than those for the
same material collected for processing as pig swill (Stat Inst
1999 No 646 Part III).
Careful analysis of the research papers leads
us to prefer and entirely support the promotion of Home and Community
Composting and "On Farm" projects. We also find merit
in and commend well engineered enclosed or contained systems,
"In Vessel" composting as in the Dutch example and anaerobic
digestion to produce methane as practised by the Danes and others.
Provided always that organic waste treatment is within the boundaries
of the plant or community where it is generated.
We are strongly opposed to the increasing use
of long haul, large scale, open-air aerobic, windrow composting
because:
Hauling putriscible waste, say, county wide
or across county borders defeats the good intentions of the Proximity
Principle.
Each site creates 50 to 60 extra HGV passages
a day, some every day including weekends and most Bank Holidays
that obviously amounts to thousands of extra and increasingly
costly miles a week in total with the certainty of causing more
air pollution, roadwear, congestion and accidents.
Waste Management Licences allow the use of large
open top or netted skips on the collecting lorries. These have
the potential to spread plant diseases, pests and parasites en
route and to transfer dominant alien species from one habitat
to another.
Planning approval allows say, 40,000 to 60,000
tonnes annual input of decomposing material to be concentrated
on about 10 to 15 acres, sometimes on roadside land where emissions
of the order of 50 to 75 tonnes a day add to the most significant
greenhouse gases.
Good control of aerobic composting sets optimum
conditions for efficient decomposition. That creates an ideal
habitat for the growth of micro-organisms including fungus. Fungi
include pathogens and allergens harmful to people, livestock,
wildlife or crops. Frequent lifting and turning is necessary for
good management to aerate the mass of material. That causes fungal
spores and fragments to be spread abroad and scattered in the
wind. Some will remain aloft for days and travel many miles. They
are subject to Stokes' equation and other physical factors and
will not obey edicts from the Environment Agency anymore than
the waves would retreat for King Canute. We are unable to verify
the claim of the Composting Association that the concentration
of bioaerosols reaches background level at 200 metres from the
source. Some more independent people put it at 1,000 or 1,500
metres. Our own observation is that much depends on climatic conditions.
It is seasonal and that is especially evident when fungus is carried
with the Autumn mists. Remnants can establish new colonies on
naturally decaying vegetation thus moving out more slowly but
surely or they may contaminate the exposed finished compost.
The concentration levels of bioaerosols increases
in direct proportion of the size of the facility.
Allergy is widespread affecting one in four
of the population of the UK at some time in their life and the
numbers are increasing by 5 per cent each year. It is estimated
that 12 million of us are allergic to fungal spores such as those
produced by aerobic composting. Spores do not have to be viable,
fragments of colonies may be perfectly good allergens.
Consider just one example, Aspergillus fumigatus
because some work has been done on it and experts are agreed that
it is a species most pathogenic and allergenic to humans. It is
a natural part of our environment that can harm people, domestic
and farm animals, wild life and poultry. It is a cause for concern
in hospitals and when it invades the home, as well as around and
about aerobic composting sites. The minimum dose to cause adverse
health affects has not been established but it is known to be
very low in some cases when even "background levels"
can be dangerous.
Aspergillus Sinusitis can happen in healthy
people with normal immune systems and unpleasant symptoms are
common but if the fungus has entered the sinuses deep inside the
skull treatment using drugs and surgery together is usually successful.
Those with impaired immune systems, possibly due to widely prescribed
medication, may not be so fortunate.
Aspergilloma develops in people with damaged
lungs and is difficult to treat although sometimes surgical removal
is possible, especially if the patient is coughing blood.
People with damaged or impaired immune systems
are especially at risk from Invasive Aspergillosis. The fungus
can transfer from the lung to the brain, the eyes, the heart,
the kidneys and the skin. Early diagnosis is not easy and without
treatment they will die. Treatment with anti-fungal drugs is given
by vein in large doses that may damage the kidney and other organs.
Many do not survive.
There is a cost to all this and we may, in this
case, learn from the USA statistics where Allergenic Rhinits affects
10 per cent of the adult population. Over 600 million dollars
are spent annually on management of the disease. That does not
include the cost of two million lost work days, three million
lost school days and 28 million days of decreased productivity
from the symptoms of the disease or the side effects of the medication.
Aspergillus has an important role as a causative agent.
The risk to the health of people living, working
or passing in the vicinity of these sites cannot be assessed because
no satisfactory dose response data is available for the pathogens
and allergens that are undoubtedly present.
We suggest that the Precautionary Principle
should be invoked at National level.
Using a hazardous process to make a product
that is not healthy but may be handled by domestic gardeners or
horticultural workers and having stocks unsold or returned to
landfill is not a sustainable answer to the imperative to meet
our targets.
People are usually aware of the problem of smell
associated with composting yet in 1996 planning approval was given
for a 40,000 tonne site in Surrey. Councillors thought they were
doing a good thing and were assured by the contractor that there
would be no smell beyond the boundary. Complaints are documented
from 1997 and continue despite a change of contractor and installation
of a deodorising spray system. The system has an unfortunate tendency
to spray people riding their bicycles on the road. From Hilburn,
Rockland County, NY, we learn of a system of elaborate bio-filters
and discharge stacks with pretreatment scrubbers and a chemical
feed system yet the nearest people still keep over 1,000 feet
away.
Well intentioned people assume that composting,
being an essentially natural process is inherently benign, however,
when intensified and accelerated on an industrial scale in the
open air, it has harmful effects which do not arise or do not
present a problem using the methods we note as preferred or commended.
We respectfully suggest that further guidance
is needed and propose the following requirements for planning
approval and the issue of waste management licences for open air
windrow composting.
(1) It should not be permitted within 1,000
metres of any residence or workplace or any enclosure or building
housing animals (including poultry).
(2) Input of putriscible material should
be limited to 15,000 tonnes a year for each site.
(3) The haulage distances for each site should
be limited to 10 miles making collection from 314 square miles
possible.
(4) The statutory requirements and inspection
arrangements for the collection and transportation of kitchen
waste for composting should be no less stringent than those dealing
with material to be processed for pig swill.
From the trends we have noted elsewhere we believe
that if some of the saving on landfill tax can be used to help
develop the preferred and commended systems they will more than
compensate for these constraints.
September 2000
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