Regulations back on agenda

Now that plans to implement the HACCP system governing sludge are now back in motion, Max Rooksby from Atkins Water describes how water companies are preparing themselves

War with Iraq may have given the water industry a temporary reprieve, but the clock is ticking with the voluntary guidelines governing sludge-to-land use set to become mandatory in the not-too-distant future.

The impending second update of the 1989 Sludge (Use in Agriculture) regulations was planned to come into force at the start of the year but due to other issues of concern to the government, this was put on the backburner.

Plans to implement the HACCP (Hazard Analysis and Critical Control Points) system to prevent human pathogens re-entering the food chain are back on the agenda and, although it is still not clear when the new regulations will become law, Max Rooksby, an environmental scientist for Atkins Water, says it will not be too long.

According to Rooksby: "They should come in towards the end of the year. At the moment we are doing a lot of work looking at implementation of the new controls to ensure water companies are following the guidelines."

With water companies being the main producers of sewage sludge, Rooksby said most were well prepared for the introduction of HACCP but needed help fine-tuning their systems before they are up and running. He added: "Water companies will already have assessed their sludge treatment processes. They should have all produced HACCP plans by now and be rolling them out.

"Most companies will be going through the processes of implementing these plans and the sort of support our clients want is verification of them.

"We can go in and audit plans and see whether they meet what is required. Now these controls are a statutory instrument, they have to be sure to meet the requirements set out in the regulations and have to be properly audited to prove compliance."

Rooksby says the introduction of mandatory regulations should be welcomed by the sludge producers rather than dismissed as another restrictive - and expensive - control over disposal. He explained: "The big plus for sludge producers is the securing of a disposal route. Companies have lost the option of dumping at sea. "The landfill directive will reduce the viability of disposal-to-landfill and there are concerns among the public about disposal by incineration.

"In putting these regulations on recycling-to-agricultural land into force, it should mean the securing of a safe disposal route for the future. It is putting public confidence in the system." Public disquiet after the numerous food scares of the 1990s prompted the latest revision of the sludge regulations. There are a number of fears over contaminants on land from sewage sludge, including the presence of potentially toxic elements, like heavy metals and nutrients.

The heavy metals issue is addressed by measuring their levels on farmland and restricting further contamination by strictly enforced maximum limits. Nutrient application is also controlled through maximum application levels, dependant on crop requirements and farming practices promoted to prevent nutrients leaching into watercourses. But it is the string of high-profile food scares from Salmonella to mad cow disease, via listeria and various other unsavoury stops, which are the hottest topic and persuaded Defra and the Welsh Executive to take action.

The food scares sparked fears such diseases could be passed back into the food chain via grazing animals on agricultural land fertilised with sludge. Over half of the sewage sludge produced goes down the agricultural land route because of the obvious preference for recycling organic matter over dumping or burning, but as Rooksby pointed out: "The idea of putting waste back onto the land does not appear a nice one to the public." Retail lobbying group the British Retail Consortium pressed for standards to stop the potential recycling of pathogens and, together with water companies, they funded research which came up with a Safe Sludge Matrix.

The matrix controls what type of sewage is being spread on farmland - in relation to land use - and stipulates post-allocation controls, as well as determining how soon crops can be harvested and considers the public using nearby rights of way. The principle of the HACCP system is to ensure sewage sludge is free of potential pathogens by identifying critical points in the treatment system and providing barriers to pathogens at those points.

"One of the critical points could be if sludge is being pasteurised," said Rooksby. "It might be that sludge will have to be held at a critical temperature for a critical length of time to eradicate any potential pathogens." The implementation has been welcomed by Atkins Water's new MD Piers Clark. He said: "Atkins Water recognises the industry's move towards greater auditing of sludge control centres and we are pleased to be able to provide our clients with help on their HACCP programmes.

"The regulations are a fundamental driver for shaping what the business is going to undertake in sewage treatment and biosolids recycling in the future." Atkins Water offers a comprehensive HACCP service and an audit that assesses each plan on a site-specific basis. The service identifies sites or issues that require further work and suggests solutions to problems encountered. This enables the sludge producer to ensure its individual site HACCP plans fulfil the requirements set out in the amended regulations and that sludge treatment facilities will be compliant when the new sludge regulations are implemented.

Additionally, the independent review of the control and monitoring procedures by Atkins can be used in support of HACCP plan registration.

The hope is that the water industry - and others - will be prepared when the new regulations come into force and able to eliminate public fears about recycling sludge in the most environmentally-friendly manner.



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