A Regulatory and Enforcement Perspective on Food

Processing Waste

Patrick Byrne

Senior Manager

Environmental Licensing Programme

Office of Climate, Licensing, Resources and Research

Overview

• EPA Regulated Activities

• Waste

• Waste Hierarchy

• BAT

• By-Product/End of Waste

• EPA supports to business

EPA Regulated Activities

Class 7 of the First Schedule of EPA Acts

Processing of milk

Brewing

Distilling

Malting

Slaughterhouses

Manufacture of fish meal

Rendering of animal carcasses

Treatment and processing of animal or vegetable raw materials for

production of food and feed

Waste

Definition of ‘Waste’:

means any substance or object which the holder discards or

intends or is required to discard

European Court of Justice judgements

EU Commission paper 2007 ’waste and by-products’

Types of processing waste:

Out of date product

Contaminated product

Packaging

Washing effluents

WWTP sludges

Etc…..

Food Waste in Ireland

450,000

380,000

300,000

Tonnes

Production

Commerce

Households

Waste Hierarchy

The following waste hierarchy shall apply as a priority order

in waste prevention and management legislation and policy:

(a) prevention;

(b) preparing for re-use;

(c) recycling;

(d) other recovery (including energy recovery); and

(e) disposal.

Best Available Techniques (BAT)

BREF – BAT Reference Documents

Food Drink and Milk

Slaughtering

Emissions from Storage

Energy Efficiency

Key Environmental Issues, include:

Waste water

Solid waste

Water/energy

BAT Conclusions relating to waste:

Identify options for minimising waste production

Implement programme to minimise waste production

On going monitoring of waste production levels

Sectoral benchmarking

Re-use water (sterilisation may be necessary)

Requirements

Follow waste hierarchy – reuse, cycle, recover

Store appropriately on site in designated areas

Waste monitoring/analysis

Waste recording

EWC code/type of waste

Quantity exported

Names of agent/carrier, collection permit details

Final destination for recovery/disposal, permit/licence

Confirmation of acceptance

Rejected consignments etc

By-Product/End of Waste

Article 27 and Article 28 of European Communities (Waste

Directive) Regulations, 2011

Concept:

A substance or object can be a by-product (and not a waste)

under certain conditions.

Certain specified waste shall cease to be waste when it has

undergone recovery, including recycling, and meets certain

conditions.

If regulatory controls under waste legislation are needed to

protect the environment and human health, waste status should

remain.

Product (primary aim of

the production

process)

Production

process

1. Use is certain

2. No further processing required

3. Produced as integral part of production

process

4. Further use is lawful and will not cause

environmental pollution

(Art 27, Waste Directive Regulations 2011)

By-Product (not the primary

aim of the

production

process)

Waste Recovery

or recycling

process

by-product

if…

1. Commonly used for specified purpose

2. Market or demand exists

3. Fulfils technical requirements and

meets legislation and standards

4. Will not cause environmental pollution

(Art 28, Waste Directive Regulations 2011)

end-of-waste if compliant

with criteria that

demonstrate…

Green Business

Greenbusines.ie

Support for SMEs

Funded by EPA

Delivered by Clean Technology Centre

Partnered by Enterprise Ireland, SEAI, Repak, Bord Bia

Case Studies:

ABP, water consumption

Dairygold Feed Mill, energy

Ballon Meats, energy

Pig Processor, water consumption and energy

Financing and Funding Opportunities for Greening your

Business

Stop Food Waste

Thank You