AMDEA Response to DOENI Consultation on the restriction of landfilling food waste

02 December 2013

All of our members are fully committed to waste prevention and encouraging recycling but we have some member companies with a particular interest in food waste management and restricting the landfilling of food waste, as they manufacture domestic food waste disposers (FWDs). The members of our FWD Group include the world's leading producer that has manufactured food waste disposers for over 70 years and markets these appliances in over 80 countries. As food waste and sewer management are core issues for this group, we have accumulated a formidable evidence base of scientific research conducted by recognised experts and academics.

On behalf of these members, we welcome this opportunity to share this scientific knowledge and practical experience, as we are deeply concerned that statements repeated in both the DOENI Regulatory Impact Assessment and the Consultation Paper relating to food waste disposers contradict robust, peer-reviewed, scientific evidence. These serious misapprehensions threaten to flaw gravely DOENI policy and limit its future ambitions. Regrettably the statements published reflect a position which the Environment Agency retracted in November 2010, on consideration of the substantive body of evidence which we would also like to make available to the DOENI.

Since 2010 the evidence has continued to grow with recent studies published from countries at the forefront of sound environmental management, such as Denmark and Sweden. In England, in November 2012 the Local Government Association embarked on a programme of pilot studies installing food waste disposers in new-build properties, to deepen the proven knowledge base.

The Republic of Ireland has recently reversed a ban on domestic food waste disposers. Even countries that have long experience in separate collections are experiencing barriers to further achievement. Despite a highly disciplined and environmentally aware population there is a significant proportion of the German population who cannot or does not effectively separate their food waste. According to a very recent German report, “Ecologically Sustainable Recovery of Biowaste,” published in July 2013 by the German Federal Environment Ministry, only 67.5 million of the German population have separate collection services and of these 56% do not use the facility. This means 44 million or half of the German population do not have or use a separate food waste collection facility. Germany aspires to separate collection of food waste for treatment at AD centres and is committed “in principle” to establish closed loop recycling by 2015. However it is much further from achieving this target than might be supposed.

Denmark implemented its ban on food waste to landfill over 16 years ago. Denmark has moved away from separate collection of food waste for processing at centralised AD facilities because of the problem of physical contaminants and because it had extensive incineration capacity connected to district heating. However, the net calorific value of food waste is low because of the high water content. It is now re-evaluating the use of FWD as a means of increasing biogas production by delivering substrate free of physical contaminants to its wastewater treatment works and AD, this will reduce its dependency on coal for baseload generation. Measures to restrict the use of FWD in Northern Ireland would be out of step with informed contemporary practices in other jurisdictions. Article 2f of the proposed regulation for Northern Ireland represents a de facto ban on FWDs.

Summary of Key Points

  • Food waste disposers provide a sustainable means of effectively diverting food waste from landfill and do not contravene the Waste Hierarchy (as suggested on page 3 of the RIA).
  • Food waste disposers grind practically all food waste to minute particles (98% are less than 2mm) that are easily carried in the wastewater collection system2. They do not increase the risk of sewer blockage3 (as suggested on page 13 of the RIA).
  • Ground food waste is 70% water, its specific gravity is similar to faecal waste, which the sewers are designed to transport. A study from the New York City Department of Environmental Protection concluded that the impact of FWDs on the sewer system was insignificant.