Sewer inputs from many small businesses are not subjected to trade effluent regulation. Funeral directors in the UK for example, are billed for water and sewerage in the same way as a normal household. But according to an independent consultant who does not wish to be named: “The fact is funeral directors are not regulated in the same way as other businesses, simply because no-one in the water industry wants to go near the mortal remains of other people.”

The disposal of human remains is big business in the UK. Every year 0.5M people die and many of these bodies are embalmed in some way either before burial or cremation. According to Adrian Hayler of the British Institute of Embalmers (BIE): “Around half of all bodies in the UK undergo some form of embalming.” According to the independent consultant: “Some of the chemicals used in the embalming process have a high COD and the human wastes have a similarly high BOD.” But Hayler, a qualified embalmer who also works for embalming fluid supplier Dodge, does not share this view: “The concentrations used are not of a level likely to cause a problem. We supply a solution which equates to 30% formaldehyde, which is then diluted to a 1-5% solution. Even if discharged into the sewer system, formaldehyde degrades naturally, and if high concentrations are found in the environment, they are far more likely to be from an industrial process such as plastics manufacture.” There are several other sources of formaldehyde in the environment, including combustion – from car exhausts to cigarettes – and the production of plywood in which it is used as a preservative. By far the biggest use of the chemical is in plastics manufacture.

Although embalmers and hospitals are relatively small users, Dodge alone sells several thousand litres of embalming fluid every year in the UK. Embalming fluid consists mainly of formaldehyde and dyes which are used to return colour to the skin. Hospitals use formaldehyde in a number of ways, from the preservation of biological samples to some forms of specialized surgery. Water companies depend to an extent on good practice but there is evidence that this is not always the case. According to the water industry consultant: “Once I visited a sewage treatment plant and found half a dozen eyeballs on the intake screen.” In this case the remains were not confirmed as human and could conceivably have come from an abattoir. According to an unnamed source at a large UK water company: “If human this sounds like an illegal disposal of clinical waste. Our advice to funeral directors, hospitals and laboratories is that this kind of material should not be disposed of to sewer. But in 25 years of working in effluent regulation I have to say I have never come across an incident caused by this kind of activity.”

The modern embalming process, unlike that practised by the ancient Egyptians, does not involve the wholesale removal of organs – except in very unusual circumstances. Now it is referred to as arterial embalming and carried out in much the same way as a blood transfusion. The blood is drained and replaced with a solution of embalming fluid which slows the natural process of decomposition. Wastes produced by this process are flushed into the normal sewerage network, whereas any organs are classed as clinical waste. All local authorities in the UK offer an incineration service for this kind of special waste in order to prevent a public health hazard. Interestingly the French have taken this a step further, as Hayler explains: “In France all embalming wastes must now be stored and incinerated. This is a classic example of people setting the law without knowing what they are talking about.” Asked if this could get incorporated into EU law, Hayler replied: “It’s a possibility, but if so we would fight it tooth and nail.”

According to the water company source: “Discharge from funeral director’s premises would normally be controlled by water companies under the Water Industry Act (1991).” He continued: “Funeral directors or embalmers fall into a large grey area. After all, the Water Industry Act defines trade effluent as any effluent produced by a business. There is an exception for domestic sewage, but this is not clearly defined. In our view the waste produced by funeral directors falls under this category and the volume of waste they produce is not big enough to justify issuing a consent.”

In terms of the distinction between funeral directors and abattoirs, the questtion is again one of scale. Abattoirs in the UK pay for a trade effluent licence which takes into account the cost of treating high-BOD waste. Many meat processing firms now have their own wastewater treatment plants to avoid paying a high tariff for sewer discharge. The volume of waste produced by funeral directors is comparatively small, and unlikely to have an impact on the operation of an STW. For this reason water companies have not seen any need to treat embalming wastes as anything other than domestic sewage. If the law is changed, as in France, then funeral directors could find themselves paying their local authority for the disposal of clinical waste.

Discharges to surface water

There is an environmental quality standard (EQS) for formaldehyde. There should be no more than 5µg/l in fresh and marine waters as an annual average concentration. The maximum admissible concentration (MAC) for any one sample is 50µg/l. Although not mandatory, the EA sets discharge consents with a view to achieving these standards under its broad remit of protecting the environment.

According to Isobel Austin of the Environment Agency’s (EA’s), toxicology and hazardous substances laboratory: “There are no discharges from funeral directors we know of that go direct to a river. They all go to sewer, so it’s up to water companies to decide how they should deal with this kind of effluent.”

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