CIWM’s technical manager Tina Benfield says working proactively with the regulator can deliver practicable solutions – pointing to a recent example where CIWM worked with the National Sheep Association.
It is good to know that working together on a problem can deliver a practicable solution. CIWM was approached by the National Sheep Association (NSA) in relation to a change in practice for control of sheep scab. Now I can hear many of you asking what this has got to do with CIWM, we are not agricultural agents!
To control sheep scab, farmers have to dip sheep in organophosphate based sheep dip or use an injectable treatment. Injectables are not reliable, resistance is being seen in the sheep industry so having reliable and cost-effective dipping is essential for sheep welfare.
Sheep organophosphate is a hazardous solution which is diluted to a specific ratio. The NSA asked if CIWM could assist in finding a workable solution for spent sheep dip. Many farmers use mobile dippers and there is the option to spread the spent dip on farm land, under a permit. Current permitting regulations cost of permits under the Environment Agency review shows some dippers have been looking at around £10,000 for a bespoke permit.
After some liaison with Rob Walker at SafetyKleen, as CIWM was not fully aware of the status of spent dip, it was determined after following WM3 that spent sheep dip was non-hazardous. With this knowledge CIWM lead for permitting, Howard Leberman, which opened up a dialogue on the options available for dealing with spent dip.
Taking the WM3 outcome and how mobile dippers operate Howard worked with colleagues to set out a couple of options along with what that might cost the farming sector.
At a meeting arranged by Defra to understand the situation with sheep farming, due to sheep scab increasing, the Environment Agency presented its option for mobile dippers and farmers using organophosphate dip. A low risk position has been taken for mobile dippers.
Publication will follow in the LRP annex A
The low risk position effectively replaces charges for bespoke permits for the storage of non-hazardous waste – £7,930 (Table 1.16.10 of EA charges – transfer station taking non-biodegradable wastes), annual subsistence charges – £1,920, transfer of non-hazardous waste, less than 25,000 tonnes a year (Table 2.16.8 of EA charges).
CIWM believes that working proactively with the regulator can deliver practicable solutions and this example shows that understanding the situation from all sides can bring benefits.