-  Positions

SURVEY OF WASTE SPREAD ON LAND: CIAA COMMENTS

Brussels, 31 January 2001

1. As a general comment, the CIAA would like to recall that all the products spread on land should not be considered as "waste". The classification of a product as "waste" depends on many factors:
- material produced intentionally to meet specification
- existence of a market
- respect of specifications
- submission to quality control
- …

In addition, although there is a European definition of "waste", there is no agreed method to distinguish "products" from "waste". In order to avoid any misinterpretation, we would ask to use the word "waste" very carefully, and to replace it for example by "co-product" or "by-product" from cattle breeding, food processing, industry, … The best way to preserve the spreading of various products from industry is not to call all of them "waste". It is definitely more adequate to call the product by its proper name.

2. In the light of this study, the CIAA would like to stress the importance of collecting comparable and reliable data. Some measures can be expressed concerning the figures produced in the study:

In Table 3.1 (page 8), the quantities mentioned do not make sense as the products concerned are not indicated. In addition, the figures do not seem to be consistent with regard to the respective sugar production of each country. Finally, for France, it is difficult to imagine that the quantities of products from the sugar processing are more than 1000 time higher than that for the "food and drink preparation".

Some data need also to be specified. The agricultural spreading of food and drink processing industry waste refers to data without unit indications.

As regards Table 3.1, we also question the grouping operated: sugar processing and abattoirs could be shown as specific sectors of the food industry, but not as different sectors from the food industry.

3. Sugar producers, page 15:
The last sentence of the paragraph "Sludge produced by the industry consists mainly of waste lime and pulp residues" is misleading. The sugar factory lime is used as a soil improver and the pulp is used as an animal feed. Both products must meet specifications and are subject to quality controls. This sentence should be deleted.

4. 4.3.4. Potential problems, page 15:
The last sentence of 2nd paragraph concerns Rhizomania. It should be noted that the extension of this beet disease is studied in depth by many agricultural research centres. The studies shows that the spreading of the mixture of soil and water on land do not contribute to the extension of the disease. As a general comment, we believe that any information mentioned should be justified with reliable scientific references.

Many comments can also be made on the structure and the form of the document:
- The numbering of tables should be clarified (see p. 11, 12 and 13).
- The use of some titles in paragraphs 4.3.2 and 4.3.3 is confusing.
- Paragraph 4.3.6 concerning stabilisation of food and drink processing industry waste should also be clarified. Indeed, this study mixes primary treatment as anaerobic digestion and secondary treatment as liming and composting.

The CIAA has many reservations concerning the results of this study. The lack of data and the reference to doubtful figures does not make the study representative of the current situation in this area.