Prevention of environmental pollution from agricultural activity: guidance

Section 10: disposal of animal carcasses

Note - The Animal By-Products (Scotland) Regulations 2003 prohibit the routine burial or burning of animal carcasses on farm. The regulations provide for a derogation to allow the continued on-farm disposal of fallen stock in the designated remote area, which covers most of the Highlands and Islands and Argyll. This is the only area in Scotland where on-farm disposal is permitted.

Dos **1. Report all sudden deaths and seek veterinary advice. **2. Comply with the Animal By-Products (Scotland) Regulations 2003 and dispose of fallen stock through an approved disposal route, such as incineration or rendering. Only resort to burial on farm in the remote area and if an approved disposal route is not available. Where burial does take place: bury animal carcasses with at least 1 metre of covering soil to prevent dogs, foxes or vermin getting access keep a Location Plan of all burials and a note of type of animal buried choose sites where there is at least 1 metre of subsoil at the bottom of the burial pit make sure that incineration is carried out in a dedicated animal carcass incinerator, designed or adapted for that purpose make sure that burning of carcasses in the open is undertaken with care and by the approved method 3. Seek professional advice if in doubt. Advice on veterinary issues is available from your local Animal Health office. SEPA will provide advice on environmental pollution issues. 4. Consider subscribing to the National Fallen Stock Scheme. Don'ts **1. Don't leave carcasses unburied or open to dog or fox access for any length of time. **2. Don't add lime to a lined disposal pit. **3. Don't dump carcasses. **4. Don't operate an animal carcass incinerator without prior consultation with SEPA. 5. Don't bury carcasses any closer than 250m from any drinking water supply; 50m from any watercourse or 10m from any field drain. 6. Don't locate burial pits in areas prone to waterlogging or at risk of flooding, or that are underlain by sandy or gravelly soil. 7. Don't bury carcasses in polythene bags or other impervious material. 8. Don't bury carcasses on archaeological sites or on sites designated for their nature conservation interest.

Introduction

10.1 The disposal of animal carcasses on farm can present significant environmental, animal and human health risks. There is a serious risk of spreading disease to stock on that holding or on neighbouring farms, as well as a public health risk, including pollution of water courses.

What legislation must be complied with?

10.2 The statutory provisions of the Animal By-Products (Scotland) Regulations 2003 must be complied with. There are however several other pieces of legislation which are relevant to this topic, and the main ones are referred to in the individual paragraphs of this section.

10.3 Local authorities have the principal enforcement role under the Animal By-Products Regulations. Contact SEERAD for further details.

Deaths of cattle

10.4 At present, there are certain specific rules relating to cattle deaths that must be met. These are as follows:

• all sudden unexplained cattle deaths must be reported immediately to the local veterinary inspector or local Animal Health Office. The carcasses will be routinely tested for anthrax

• where deaths are explainable, all fallen cattle and bovine animals slaughtered on-farm for welfare reasons over 24 months old should be reported to the Rural Payments Agency (Tel: 0800 525890) who will arrange to collect the carcasses and arrange for testing for transmissible spongiform encephalopathies.

• explainable deaths of cattle 24 months old or under are not currently subject to special rules, and may be dealt with as described below

All other deaths

10.5 A number of options exist for disposal of carcasses of animals that die on the farm. The Animal By-Products (Scotland) Regulations 2003 stipulate that disposal should be by an approved route such as rendering or incineration. It is also permissible to consign carcasses to the local knackery, hunt kennel or zoo for disposal purposes. The routine on-farm disposal of fallen stock is only permitted within the designated remote area, and even then only where an approved disposal route is not available. Where carcasses are to be disposed of by burial or burning on a holding in the remote area, this must be done in accordance with guidance contained in this section.

Notifiable diseases

10.6 Irrespective of any other considerations, if ill health or death is thought to be caused by a notifiable disease, this must be reported to the Divisional Veterinary Manager at the local Animal Health Office (see Annex A), or the police station. In such circumstances carcasses should be made available for post mortem examination. In cases of unexplained sudden death of cattle, veterinary advice must be sought in order to eliminate anthrax as the cause of death. In such cases, the carcass will be routinely tested.

BSE surveillance

10.7 For cattle deaths which are explainable, all fallen cattle and bovine animals slaughtered on-farm for welfare reasons which are over 24 months old should be reported to Rural Payments Agency (Tel : 0800 525890) who will arrange to collect the carcasses and arrange for testing for transmissible spongiform encephalopathies.

10.8 Explainable deaths of cattle 24 months old or under are not currently subject to special rules, and may be dealt with as described below.

Disposal to a renderer or incineration plant

10.9 Your local Animal Health Office should be consulted as to renderers or incinerators in the area that are suitable for carcass disposal. The local authority is under no obligation to collect or dispose of animal carcasses.

On-farm disposal

10.10 On-farm disposal may only be practised within the designated remote area (see map) and even then only where there is no alternative disposal route.

10.11 Where on-farm disposal is being carried out, methods such as burial, incineration or burning in the open air should be carried out with care to prevent serious air, soil or water pollution. In such situations the following guidelines should be fully observed.

Burial

10.12 It is an offence under the Dogs Act 1906 to leave an animal carcass unburied in a place where dogs may have access to it. Under the Animal By-Products (Scotland) Regulations 2003, fallen stock must be disposed of without undue delay.

10.13 Under no circumstances should carcasses remain unburied or be disposed of in or near watercourses. It is an offence under the Control of Pollution Act 1974 to cause or knowingly permit any poisonous, noxious or polluting matter or solid waste to enter any controlled waters. Apart from risking prosecution for causing water pollution, there is a serious risk of spreading disease to stock on neighbouring farms as well as posing a public health risk.

10.14 If a notifiable disease is not suspected, or has been eliminated as a possible cause, and other means of disposal are not available, burial on-farm within the designated remote area may be considered if the following criteria can be satisfied. The burial site must:

• be at least 250 metres from any well, borehole or spring used as a source of drinking water (where byelaws specify a greater distance, this must be complied with). Byelaws may also impose restrictions relating to the distance of a burial site from a surface source

• be at least 50 metres from any other spring or watercourse, and at least 10 metres from any field drain

• have at least one metre of subsoil below the bottom of the burial pit, and the pit must be dug deep enough to give at least one metre of covering soil

• where possible, sites on soils which are moderately permeable should be used. Avoid waterlogged sites and sites on free draining subsoil. Ensure that the pit is dry after it is dug. Do not use a pit which fills with water

10.15 Records of all burial sites, including a field plan, should be kept, together with number and type of stock buried and dates of burial.

10.16 The Groundwater Regulations 1998, enforced by SEPA, aim to protect groundwater quality from pollution by certain substances. The burial and subsequent decomposition of animal carcasses could pose a threat to groundwater quality and possibly to human and animal health, particularly if drinking water supplies might be affected. If there is doubt over the suitability of a proposed burial site or scale of burial then SEPA should be consulted to ensure that the Groundwater Regulations 1998 are complied with. Under these circumstances, the local authority should be consulted first to ensure that the requirements of the Animal By-Products (Scotland) Regulations 2003 are taken account of.

10.17 Dogs and foxes must not gain access to carcasses. Carcasses placed in the pit must be covered immediately with a sufficient depth of soil to deter scavenging animals and birds. Placing an animal carcass in a manure store is not acceptable.

Lined disposal pit

10.18 For small carcasses such as poultry mortalities and foetal material, a pit with an impervious wall (precast concrete rings or glass fibre), and with its base open to the soil, may be used. It should be covered with a substantial top, fitted with a manhole cover. The pit should be sited on an area that fulfils the criteria given for burial sites and the local authority and SEPA should be consulted before construction commences.

10.19 These pits work best if started in spring or summer, using a bacterial starter. A slit in the abdominal wall to release intestinal contents also helps, as does the addition of a few gallons of water each week to keep the contents moist. Lime must not be added.

10.20 Be aware of the requirements of any farm quality assurance scheme concerning what is, and is not, acceptable for disposal of fallen stock.

Disposal by burning

10.21 Under the Clean Air (Emission of Dark Smoke) (Exemption) Regulations 1969, carcasses of animals which:

• have died or are reasonably believed to have died because of disease

• have been slaughtered because of disease

• have been required to be slaughtered in pursuant of the Animal Health Act 1981

are exempt from the Clean Air Act 1993 providing that:

1. there is no other reasonably safe preferable method of disposal.
2. the burning is carried out in such a manner as to minimise the emission of dark smoke.
3. the burning is carried out under the direct and continuous supervision of the occupier of the premises concerned, or the person authorised to act on his/her behalf.

Incineration

10.22 Dead stock should be burnt, preferably in an incinerator, within 12 hours of death.

10.23 Incinerators should be equipped with secondary combustion chambers where temperatures of greater than 1000°C over a flue gas residence period in excess of 2 seconds can be achieved throughout the incineration process. Professional engineering advice should be sought with regard to sizing, selection, installation and operation of incinerators and carcass storage facilities. Incinerators designed for, or operated at, loading rates of greater than 50kg/hour must be authorised by SEPA and operated in accordance with the Scottish Executive's Local Authority Guidance for Animal Carcass Incineration Processes under the Environmental Protection (Prescribed Processes and Substances) Regulations 1991. New incinerators are covered by the Pollution Prevention and Control (Scotland) Regulations 2000 as amended by the Waste Incineration (Scotland) Regulations 2003. All existing incinerators will eventually be covered by these new Regulations.

10.24 The design-loading rate of the incinerator should not be exceeded at any time.

Burning in the open

10.25 Fires should be located as far as possible from (and, where practicable, downwind of) public highways and residential areas. A shallow pit can be dug with additional cross trenches to provide an adequate air supply to the base of the fire, but this is not always necessary. The primary fuel, (straw, fuel oil, heavy untreated timbers and/or coal) should be placed in the base of the fire and the carcass (es) placed on top. The design should be so as to encourage burning to take place up and through the material rather than from the top down. This burning process gives a much higher temperature and also reduces the risk of creating dark smoke. The fire should not be overloaded with carcasses, and sufficient fuel should be provided to ensure complete combustion. The burning should be carried out under the direct and continuous supervision of the occupier of the premises, or a person authorised on his behalf. A fire extinguisher and water supply or bowser should be available for emergency use. Burning should take place only in daylight hours, and the local fire brigade should be alerted to the event prior to igniting the fire.

Notifiable disease outbreaks

10.26 The outbreak of a notifiable disease, such as foot and mouth, may require the rapid and wholesale slaughter of animals at the infected premises and, possibly, of animals on neighbouring properties. The disposal of carcasses on-farm in a disease outbreak situation is not confined to the designated remote area. Each farm should therefore prepare for such an outbreak and consider carefully which sites might be suitable for burning and/or burial to take place. This will be useful in determining what action needs to be taken in an emergency.

10.27 The State Veterinary Service will advise on what needs to happen to control the outbreak. Other agencies such as the police, fire brigade, local authority, public health consultants, Scottish Water and SEPA will also have a role to effectively protect human health and the environment. It is better for farmers and crofters to be prepared, than to have to consider these issues in the midst of an emergency.

National Fallen Stock Scheme

10.28 The Government recognises the cost to farmers of meeting the new requirements to dispose of all fallen stock using approved methods. It has developed the National Fallen Stock Scheme, to help farmers cope with the change by facilitating a cost-effective method of disposing of fallen stock in the areas outwith the derogation. Livestock farmers will be able to access the Scheme on payment of a nominal annual registration fee, with further charges depending on the farmer's usage of the Scheme. Farmers will be able to choose their preferred approved collector from a list provided by the National Fallen Stock Company.