We welcome the publication of the draft Waste Management (England and Wales) Regulations 2005 and the opportunity to comment on a number of issues pertinent to the Applied Research Forum.
The Applied Research Forum (ARF) was established by the levy boards in response to recommendations by the Policy Commission on Farming and Food and as a core membership drawn from the seven agricultural and horticultural levy boards within the UK . The seven development organisations represent growers and supply chain businesses that are integral to farming and food in the UK.
Managing agricultural waste is a challenge to growers and the supply chain but is one that the industry recognises must be addressed for business efficiency and environmental benefit. The response from the Applied Research Forum, as the umbrella organisation, identifies generic issues or ones that impact on one or more levy bodies within the industry. A number of specific issues are also relevant to the different levy bodies and we are aware that individual responses from levy boards are also being submitted in response to the consultation.
The key areas where ARF would wish to comment on are:
Farm tips are important in many grower businesses and provide the opportunity to dispose of waste plant material and soil, in particular where there are potential phytosanitary issues and where land spreading is not an option on plant health grounds. It is recognised that these would need to be maintained so as to minimise any environmental impact.
Farm plastics are a difficult waste management issue and we recognise that disposal of non-packaging plastic needs to be managed nationally. A number of options may be considered. Historically voluntary disposal schemes do not appear to have worked effectively and we believe that if plastic disposal is to be effective then a scheme with a statutory base should be developed for collection, recycling or recovery. It would be important that such a scheme is accessible to all growers to help meet any targets that may be set. Research that would develop techniques to minimise soil contamination of the crop plastics would be valuable and make management and disposal more efficient
We recognise the importance of exemptions in managing waste as they allow the continuation of certain practices that are integral to farming businesses. We have been involved in dialogue with the NFU and fully support their proposals for 'general' exemptions and would seek assurances that the bureaucracy for registration is minimal. With all of the exemptions there does need to be very effective communication and clear advice to growers to ensure that there is full understanding of the constraints.
It is noted that there is a proposed limit for the exemption on storage of 1250 tonnes. An alternative that makes better agricultural and environmental sense is to establish a limit that takes into consideration, for example, farm size and activity, soil type and location e.g. within NVZ's or other environmentally sensitive areas.
Such dumps e.g. for potato and tomato, are important for on-going farming activity and the proposed exemption is valuable The dumps provide a solution for handling agricultural waste in a situation that can be managed to minimise the risk of diseases e.g. blight and potential environmental contamination e.g. run-off. They are often managed for a number of years at the same site and we would seek assurances that this is exactly the scenario that would be covered by the exemption.
We seek assurances that full consideration has been given to ensure that there is adequate provision for the safe disposal of crops and animals affected by quarantine pathogens and any associated clean-up operations. These may range from outbreaks at a single location to multi-site outbreaks. Disposal and clean up must be under controlled conditions as required by appropriate legislation.
The handling and safe disposal of waste pesticide containers requires some clarification. If a hazardous waste disposal route is necessary considerable costs will be incurred by industry and there may be issues of non-compliance. Whereas with triple washing it should be acceptable to dispose of cleaned containers via a non-hazardous waste disposal route. This could be linked in with other controls e.g., those associated with good operator practice and commodity assurance schemes.
The outcomes of the consultation and initial implementation of the legislation will occur over a very short time period. This creates serious concerns within the industry and we welcome the 12-month transitional period proposed by Defra and Environment Agency. Growers and supply chain businesses will be starting from a low knowledge base of the legislation and we would encourage all of the proposed communication and education initiatives. In this context the Applied Research Forum is in a unique position to help inform levy payers and we would welcome working with Defra and EA in ensuring that our members are able to comply with the regulations.
If there are questions or issues arising from this response I would be pleased to discuss these with you.
(R&D Director, British Potato Council)
On behalf of the Applied Research Forum
Membership of the Applied Research Forum: British Beet Research Organisation (BBRO), British Potato Council (BPC), Home Grown Cereals Authority (HGCA), Horticultural Development Council (HDC), Meat and Livestock Commission (MLC), Milk Development Council (MDC) and Processors and Growers Research Organisation (PGRO).
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