Volume 1: Findings and Conclusions
10. Pollution and waste control

1081 When slaughter and compensation measures were introduced, the carcasses of the cattle in question became the property of MAFF. The Ministry had already established disposal procedures to apply to the handling of BSE carcasses. Instructions were swiftly distributed to field staff. The preferred option was incineration at MAFF premises followed, 'in order of decreasing desirability', by off-farm burning on waste ground or at a local authority site, incineration on farm, burial at a local authority tip, and burial on farm by a contractor.

1082 The problem that arose with the BSE cases was their sheer volume. As numbers rocketed in 1989 and 1990, constantly outstripping forecasts, MAFF was forced to adopt various expedients while new incinerator capacity was being sought. This was not a simple undertaking. There was local hostility both to the emergency measures of open burning and tipping that had to be adopted and to the issue of planning permissions and other licences for new incinerator capacity. As fast as new provision was made, the number of reported BSE cases grew yet greater. Only in 1992, a year in which 43,449 carcasses had to be destroyed, did MAFF get the disposal situation fully under control. Thereafter carcasses were no longer buried and virtually all incineration was at designated premises.

1083 Volume 6: Human Health, 1989-96, Chapter 10 describes the steps that MAFF took and the difficulties it encountered. Ministers took a close interest in what was happening, both because they wished to be assured that the policies adopted were not creating health risks, and because of the continuing public sensitivity about some of the measures adopted. The potential impact on overstrained waste disposal facilities was not unnaturally a consideration in some of the policy issues that arose. By their nature carcasses had to be disposed of promptly if they were not to constitute a threat to public health. Moreover this was far from cost-free.

1084 Overall MAFF handled this difficult and unpopular task of carcass disposal both energetically and competently.

1085 In the process, however, they had to deal with various objections from those with responsibilities for environmental protection. There was growing public concern about the nature and persistence of the BSE agent in waste whether burnt, used as landfill or discharged as effluent. We shall return to this point. But first we review what happened with a different sort of waste, the Specified Bovine Offal.

1086 Here matters were not so straightforward. Responsibility for disposal did not rest with MAFF but with the owner of the material. Initially there was no requirement to distinguish SBO from other meat unfit for human consumption. Most of this unfit meat was not regarded as waste but rendered to produce MBM and tallow. As one renderer put it, 'We were very much a by-product industry. We cleared up the mess from the slaughtering industry trades.' In 1991, after the introduction of the animal SBO ban and SEAC's advice that the protein product of SBO should not be used as fertiliser, MBM could only be disposed of at a licensed destination. It had become controlled waste.

1087 The disposal of some other sorts of BSE waste was given much less attention than SBO. These were the side products of slaughtering cattle, and destroying, treating or processing cattle material.

1088 They took various forms. Effluent passed down drains to sewers and rivers. Blood, slaughterhouse or rendering plant waste, including that from plants that rendered SBO, and sewage sludge from works handling their effluents might lawfully be spread as fertilisers on land where animals subsequently grazed or crops were grown.

1089 While emissions from plants required formal consents from water authorities and others, in practice none of the usual precautions or conditions which applied to discharges would have inactivated the BSE agent. It appears to have been assumed that it was sufficiently diluted to pose no risk. This was a matter that was not thoroughly investigated until work was commissioned by the Environment Agency in 1996 to trace all the environmental pathways along which BSE material might travel, and to assess the degree of risk and appropriate precautions for each.

1090 Although much of the evidence offered to us about the BSE risk from effluent from the Thruxted Mill rendering plant in Kent related to a time outside the period covered by this Inquiry, the concerns expressed and the action taken in response to them illustrated some of the difficulties posed by BSE for those responsible for dealing with secondary wastes.

1091 The environmental regulation regime had been found wanting in many respects towards the end of the 1980s. Discussing the disposal of solid waste the Select Committee on the Environment observed in 1989:

Never, in any of our enquiries into environmental problems, have we encountered such consistent and universal criticism of existing legislation and of central and local government as we have during the course of this enquiry.

1092 The system was at the same time having to be adapted to meet EU requirements designed to ensure that waste was recovered or disposed of without endangering human health or harming the environment. The principle of 'producer pays' for disposal costs was being introduced. Major reorganisation of responsibilities was undertaken and new powers brought in under the Environment Act 1990.

1093 Thus the task of disposing safely of BSE carcasses and SBO took place within a regulatory system that was in trouble and in transition. Chapter 8 in vol. 14: Responsibilities for Human and Animal Health describes the main features of the system and the major changes introduced to rearrange responsibilities and to regulate waste and sewerage, waste tips, waste spreading and air quality.

1094 These were wide-ranging matters. We could not attempt to add detailed exploration of them to the many other topics our Inquiry has had to cover. It is clear, however, that as a potential transmission pathway for BSE, general waste disposal systems received scant attention prior to 1996. This matter was not specifically referred to or addressed by the Southwood Working Party, the Tyrrell Committee or SEAC. Yet all of them advocated a systematic review of the destination of all bovine materials. Had this been carried out as discussed in the earlier section of this chapter, it might have been expected to identify many of the matters touched on above, and to indicate where more research or development of new techniques would be valuable.