Feedback on changes to our application forms and guidance for permits to dispose of sheep dip.

Overview

We’re planning to update our application form and guidance for environmental permits to dispose of waste sheep dip to land in Wales.  These set out the limits for the disposal of waste sheep dip to land.

This will not affect the dipping of sheep. We recognise that dipping plays an important role in controlling parasites. Our consultation only applies to the waste disposal of used sheep dip which requires an environmental permit.

What limits are we proposing?

We have a statutory responsibility to protect the environment as well as ensuring that activities are permitted in accordance with the relevant legislation. The limits for the disposal of waste sheep dip to land in Wales will be:

1. The total volume of working strength used dip disposed of to land per annum is 5 cubic metres or less. This is the volume prior to any dilution with slurry or water to facilitate spreading onto land

Explanation: We believe that 5 cubic metres is an appropriate threshold which balances the needs of our customers against our statutory responsibility to protect the environment as well as ensuring that activities are permitted in accordance with the relevant legislation.

The volume of used sheep dip created depends on the size of the flock being treated and the capacity of the dip bath used. Farmers in Wales typically generate between 0.5 – 2 cubic metres of used dip per dipping session, and typically dip sheep 1-2 times a year. This means they need to dispose of less than 5 cubic metres of undiluted dip, infrequently, each year. We consider that the waste disposal that arises from this activity is of a sufficiently low degree of intensity that it would not be considered as ‘landfilling’ of liquid waste, which is prohibited by the Landfill Directive (Council Directive 1999/31/EC).

Commercial mobile dippers, who produce and collect used sheep dip from numerous farms and transport it back to their own premises for disposal to land, must dispose of larger volumes of waste and at a higher degree of intensity and on that basis are likely to be considered as ‘landfilling’ of liquid waste.

Spreading higher volumes to land also increases the risk of pollution occurring and to minimise this risk it is more appropriate to make use of registered waste carriers to dispose of larger volumes waste sheep dip at waste treatment facilities. This is in line with disposal routes for all other liquid wastes in Wales which are not permitted to be applied to land.  To support this we have issued Regulatory Decision 061 which allows up to 20 cubic metres of used sheep dip to be securely stored for up to 3 months without a waste permit, prior to its collection for disposal at a waste treatment facility.

2. The total area is authorised for use not more than once a year; or any individual plots within this wider area are authorised for use no more than once per year.

Explanation: The frequency of disposal is limited to ensure we comply with the requirements the Landfill Directive (Council Directive 1999/31/EC) which prohibits the disposal of liquid waste to landfill. ‘One-off’ disposals to a plot of land means the site is unlikely to be considered as a landfill.

3. A maximum of 3 disposals per annum takes place across the wider site/ farm holding

Explanation: This has been derived from the advice in the existing DEFRA/Environment Agency ‘Joint Policy/Process Advisory Note’ (2004) that “unplanned and one-off or sporadic disposal of waste is insufficient to engage the definition of a 'waste disposal site”. We consider that most farmers in Wales who dispose of their used sheep dip 1-2 times a year would be considered as sporadic disposers of waste.

This also aligns with our Horizontal Guidance H1 - Annex J1 ‘Prior examination for discharges to land of waste sheep dip’ which states “the discharge of waste sheep dip must not be undertaken more frequently than once per year on any individual area of land, although areas may be used in rotation, to allow a maximum of 3 discharges per year within the disposal site as a whole.”

4. The land must be in general agricultural use. Land which is utilised for disposal purposes only, would be considered a landfill.

The Landfill Directive (Council Directive 1999/31/EC) prohibits the disposal of liquid waste to landfill. We must therefore be confident that the land being used for the disposal of sheep dip is not considered as a landfill.
Land which is in general agricultural use and which is only used occasionally for the disposal of waste sheep dip is unlikely to be considered as a landfill.
Land which is only ever used for disposal of waste sheep dip, or is used frequently for the disposal of waste sheep dip is likely to be considered as a landfill.

5. The area of land available is sufficient so that the spreading of waste sheep dip can be kept to a safe minimum This equates to 5 m3/ha/day if the used dip is at working strength, rising to 20m3/ha/day used dip that has been further diluted by slurry or water to dispose via vacuum tanker.

Explanation: The rate of disposal of sheep dip over an area will determine the hydraulic loading and, dependent on the soil and time of year, how quickly contaminants move through the soil zone. Excessive rates of spreading have the potential to overwhelm the infiltration capacity of soil and lead to runoff, or saturated or bypass vertical flow within the soil. This significantly increases the risk of pollution to the environment.

Waste sheep dip is usually disposed of by spreading over an area of land using either a sprayer or from a slurry/vacuum tanker. Rates of spreading are usually expressed in terms of m3/ha/day. As set out in our Horizontal Guidance H1 - Annex J1 ‘Prior examination for discharges to land of waste sheep dip’ to minimise the risk of pollution working strength waste sheep dip should not be spread at rates greater than 5m3/ha/day.

Most vacuum tankers have a rate of application fixed at approximately 20m3/ha. This is 4 times the recommend rate for safe spreading. In order to ensure that the working strength dip is spread at the recommended 5m3 /ha rate, the dip must be diluted with at least three parts slurry or water.

Waste pesticides and other liquid wastes to land

We will no longer accept environmental permit applications for the disposal of waste pesticides or other liquid wastes to land.  The option to apply for these has been removed from our application forms. Waste pesticide spray and washings can be:

• Collected for disposal off-site by a registered waste carrier
• Disposed of ‘in crop’ whereby the sprayer is emptied and cleaned in the field being treated using the minimum amount of water necessary and ensuring that the maximum dose is not exceeded. This does not require an Environmental Permit
• Discharged into a lined biobed. This may be eligible for a T32 waste exemption.

Disposal of washwaters in exceptional circumstances

One-off landspreading of washwaters containing disinfectant is permitted in exceptional circumstances such as during the outbreak of a notifiable exotic disease in animals (Foot and Mouth, Avia Flu etc) once all other disposal options had been exhausted. This is in line with our existing policies and guidance available on our website.

How will this affect those applying for new permits?

Customers can use the guidance to check, before they apply for a permit, if their proposed disposal activity meets the limits for the disposal of waste sheep dip to land in Wales.

We will not be able to accept applications from customers who cannot meet these requirements. Any applications received will not be duly made and will be returned to the applicant. Applications that meet these requirements will then be determined in accordance with our standard procedures to ensure we protect the environment.

If customers are unable to meet the criteria, they should seek alternative routes for disposing of their used dip via registered waste carriers.

This proposed change will only affect a very small number of customers, as most permit applications we receive are to dispose of small volumes of used sheep dip, one or twice a year.

Fees and charges for permits remain unchanged, as set out in our Charging Scheme which is available on our website. For most customers this means an application fee of £390 and an annual subsistence charge of £153.90.

How will this affect those with existing permits?

Dipping of sheep can continue as normal as we recognise that dipping plays an important role in controlling parasites across Wales.

A very small number of existing disposal permits may not meet the limits set out in our updated guidance. We will work with these permit holders to modify their waste disposal operations and try and reduce the volume of waste being applied to land.

Tell us what you think

If you have time to share your feedback with us, we’d love to hear from you.

Here is a draft copy of the updated application form and guidance.

Why your views matter

What happens next

The information from the survey will be used to help us to identify areas for improvements in our application forms and guidance so we can ensure our communications are as effective as possible.