Written Evidence submitted by the Chartered Institution of Wastes Management (CIWM)(SH0092)

CIWM is the leading professional body for the resource and waste management sector with a purpose to move the world beyond waste. Representing over 5,600 individuals in the UK, Ireland and overseas, CIWM has a mission to unite, equip and mobilise its professional community to lead, influence and deliver the science, strategies, businesses and policies for the sustainable management of resources and waste.

CIWM is recognised as the foremost professional body representing the complete spectrum of the waste and resources sector.  This gives the Institution the widest possible view and, perhaps more pertinently, an objective rather than partial view, given that our goal is for improvement in the management of all wastes and resources.

Why is bio-organics an important consideration?

CIWM strongly believes that to achieve the Government’s desire in the Circular Economy there must be good, reliable data on all waste arisings and effective environmental regulation of treatment and use of quality materials to land.

WRAP estimated 9.65 million tonnes of food waste[1] leaving farms is thrown away, each year, across the UK.  Only 1.9 million tonnes were recycled.  Food waste from the home contributes around 50% of the total food waste arising[2].  Data from Defra shows that around 6.1 million tonnes of biodegradable municipal waste (BMW)[3] was sent to landfill, around 48% of the total MSW that was landfilled in 2020.  Data for commercial & industrial waste arisings, along with agricultural wastes are not as detailed and this issued should be addressed with the Digital Waste Tracking project.

CIWM saw the benefit of including bioresources to its workstream through the introduction of Biological Treatment special interest group (SIG) which gathered experts in the field of organics treatment and use to discuss the optimum processes, methods and techniques to produce quality organic material for land, from food and green waste collections.

The SIG were vocal in the support of the EU Soil Thematic Strategy during 2002 and believed that the UK should have signed up and been an active part of improving agricultural and degraded soils to be more sustainable and productive.  CIWM was pleased to see the 2009 Safeguarding Our Soils – A Strategy for England but as with most things in the environment there are interactions across boundaries and soil in England should not be considered in isolation to the rest of the UK.

CIWM believes the resources and waste sector has a key role to play in providing suitable organic material for land and the Government needs to engage on all fronts to improve soil health, capture carbon and benefit the environment.

1. How can the Government measure progress towards its goal of making all soils sustainably managed by 2030? What are the challenges in gathering data to measure soil health how can these barriers be overcome?

AHDB issued principles to improve soil health https://ahdb.org.uk/knowledge-library/principles-improve-soil-health-physical as well as an action plan for soil testing https://ahdb.org.uk/knowledge-library/soil-assessments/action-plan-for-soil-testing, so that farms can set five-year plans on sound baseline data.  Due consideration should also be given to the developing approach to soil health across the European Union following the recent revision to the Soil Strategy.  This is being supported by a very large research investment under the EU Mission: A Soil Deal for Europe.  Linkage to these projects, e.g., via UK participants or via advisory boards, should be pursued with urgency.

These imply that a plan to monitor reduced tillage systems; increased use of quality, certified[4] composts, green manures and cover-crops; reintroduction of livestock or incorporation of crop residues can all be used to give a picture of soil on the farm.

Targets, including those set on reducing inorganic fertiliser and pesticide use, alongside the increased use of composts, etc will give an indication of the direction of travel.  Compost and anaerobic digestate contain recycled nutrients. These can be used to offset the manufacture and extraction of inorganic fertilisers, so reducing the impact on climate change as well as providing security benefits in resources.  The added slow release of nitrogen from compost helps increase soil fertility and acts as food for soil biota, not just crops.

Bio-organic material applied to land enables the soil structure to absorb and hold water.  The number of times that water abstractions are applied for and used will give an indication of sustainable use of water, and processes in place to reduce the need for excess watering.  These will have to be taken alongside the impact on yields and weather patterns.

Consistency in data collection is important and perhaps this should be carried out independently by the likes of AHDB.  The cost to the farm is another factor that will determine consistency as well as the information being gathered in the first instance.

CIWM is aware from long term field trials (including those carried out by the Waste and Resources Action Programme (WRAP)) that annual applications of compost to soil increases soil organic matter levels and therefore soil productivity and wider ecosystem services.  Although not a metric for soil health, CIWM suggests a measurement of compost to soil should be determined.  An holistic, systems-based approach is required to link Government’s resources and waste strategy with soil protection and enhancement; hence, indicators (or targets) to use recycled bio-wastes (compost and digestate) on agricultural arable soils.

Soil health is not just an issue for agricultural land, but also for amenity land, urban land and contaminated sites management.  A new Soils Mission project[5] due to be launched in May 2023 will explicitly link soil functionality / soil health with source-pathway-receptor risk assessment to provide an approach to objectively setting environmental quality criteria for soil.  This project can be accessed via CIWM.

2. Do current regulations ensure that all landowners/land managers maintain and/or improve soil health? If not, how should they be improved?

No, current environmental quality criteria in the BSI PAS 100 / PAS 110 specifications, sewage sludge to land regulations and, multiple other guidance are not based on impacts on soil health or functionality, and potentially no risk assessment basis.  Agricultural waste to land is largely unregulated, although a code of practice for soils in agriculture exists.  The Environment Agency has published soil quality values for ecological risk assessment.  CIWM suggests these be revisited to develop a consistent approach to soil quality objectives that is evidentially linked to soil health / functionality across all materials to land applications.

Urgent action is needed to assess emerging soil health threats, including from PFAS/PFOS, microplastics, antibiotics, hormone and personal care product residues, and persistent disinfectants.  These are widely present in sewage sludge and other materials to land.  This assessment needs to be carefully balanced against the benefits of soil carbon return and the re-use of plant nutrients, to ensure that a balanced approach is taken to ensure a net gain in sustainability, rather than as a one-sided approach.  Although these are ubiquitous in our environment (including our homes) and whilst the resources and waste sector doesn't wish to contaminate soil, the benefits of adding quality organic amendments to soil, far outweigh the potential disbenefits of potential traces of these substances.  This needs to be considered in Government policy.

Consideration is also urgently needed about the selection and proliferation of antibiotic resistance plasmids and other transposable genetic material in soil, and their potential to reach human and animal pathogens.  These plasmids may be directly present in materials of faecal origin, or selected for by antibiotic residues in some wastes.

CIWM also feels consideration should be given to the ‘exportation’ of soil health impacts.  For example, the importation from abroad of meat from herds where antibiotics are used as growth factors, or where genetic manipulation is used to generate herbicide resistant crops, are both potential remote hazards that may adversely impact soil biota and health.

3. Will the standards under Environmental Land Management schemes have sufficient ambition and flexibility to restore soils across different types of agricultural land? What are the threats and opportunities for soil health as ELMs are introduced?

The policy paper of 6 January 2022 indicated that the Environment Land Management schemes will be voluntary.  CIWM suggests there must be a balance in creating and maintaining woodland, hedgerow planting, etc. against the need to produce crops so that there is benefit in utilising organic resources that can help mitigate the impact on soils and changes in climate.  The UK now has wetter winters than it used to and, as seen in 2021 and 2022, drier summers.  Organic resources will help increase organic matter levels which will improving soils resilience to withstand extreme weather events.

https://www.gov.uk/government/publications/environmental-land-management-schemes-overview/environmental-land-management-scheme-overview

https://www.gov.uk/government/publications/environmental-land-management-schemes-outcomes/environmental-land-management-schemes-outcomes

4. What changes do we need to see in the wider food and agriculture sector to encourage better soil management and how can the Government support this transition?

CIWM believes there must be a systems-based approach in the use of recycled carbon and nutrients, and the setting of soil environmental quality standards, so that sustainability gains in one domain do not result in a sustainability loss in another.  Difficult trade-offs may need to be made, for example soil levels of micro-plastics versus soil carbon management.  This needs a multi-actor and cross sectoral approach both within and outside of government.  These problems should not rely on just one sector to solve.  Moreover, single-issue interest groups should not dictate unacceptable sustainability losses elsewhere.  It is apparent from the summary of the state of the environment: soil report that organic material from the resources and waste sector were not a prime consideration; there is no mention in the main findings about the amount of composted material that has successfully be utilised over several years.

WRAP’s report (2021) - Anaerobic digestion and composting: Latest industry survey report, new summaries of technology, and impacts showed that the grossed estimated compost produced was 2.7 million tonnes in 2018. About two thirds (66%) of the compost produced was sold to users off-site.  Moreover, the International Solid Waste Association’s working group on biological treatment produced four reports under its two-year Soils Project – Global Assessment of Municipal Organic Waste Production and Recycling; Benefits of Compost and Anaerobic Digestate When Applied to Soil; Summary of the State of Soils in Five Countries; Quantifying the Benefits to Soil of Applying Quality Compost.  These highlighted the potential the resources and waste sector has in playing a key role in improving soil sustainability; for example, research has shown that over a 4-to-12-year period between 11% to 45% of organic carbon applied as compost remained as soil organic carbon and this can be increased by 50 – 70 kg carbon/per hectare/year/tonne of dry solids.  This demonstrates that there is a very important carbon sequestration potential from the resources and waste sector.

A research report from FAO Compost from organic bio solids – Production, socioeconomics and impact on the soil productivity was published to provide “…a brief scientific overview and guidance to the government and researchers on the positive results of composting, recommending that they adopt a policy that encourages composting from organic waste, and demonstrating that the expected impact of compost production and its use in agriculture can be viewed from different angles.”

Over the past 27 years in the UK, in the region of 100 million tonnes of organic waste processing have produced 30 million tonnes of compost dry matter, this is the equivalent of 1.5 million tonnes of soil organic carbon sequestrated, or 5.5 million tonnes of carbon dioxide equivalents with a trading value of £385 million, a value that needs to be taken account of in ‘Carbon Farming’.

5. What does UK Government need to do to tackle other stressors on soil health such as soil contamination?

CIWM accepts plastics in soil are a big issue that needs to be tackled, especially in agriculture.  The Environment Agency have been working on a project looking at plastics and microplastics from separate food and garden waste collections, especially from households, to eliminate their route, via organic material to land but more is needed in relation to organic waste collections.  The public easily understood the impact of plastic in the marine environment (pictures of turtles and plastic bags are very evocative) but to get them to understand the need to keep plastic out of food and green waste collections is difficult.

The public are not plastic experts; they do not understand the difference between biodegradable, compostable and conventional non-biodegradable and non-compostable – it is just seen as plastic.  This is perhaps the reason for not exempting compostable materials certified to the European Standard BS EN 13432[6] from the plastic tax – making a material already slightly more expensive, more costly.

Agriculture uses plastics in mulch films to warm soil, to allow for earlier planting and reduce weed growth, but little control is put on its use – most of the mulch films are single use, non-biodegradable, although they disintegrate in situ eventually, increasing the levels of (micro)plastic contamination in soil.  To prevent the use of conventional, non-biodegradable (‘contaminating’) plastic, CIWM suggests there needs to be mandatory extended producer responsibility (EPR) for mulch films provided to the agricultural sector that will encourage their collection and recycling[7].  Government should also support the transition to biodegradable mulch films that have been independently certified to BS EN 17033:2018.

The FAO report Assessment of Agriculture Plastics and their Sustainability summarised the need aptly.  “Ultimately, tackling agricultural plastic pollution is paramount to achieving more efficient, inclusive, resilient and sustainable agrifood systems for better production, better nutrition, a better environment, and a better life, leaving no one behind”.

There is much work by Contaminated Land: Applications in Real Environments (CL:AIRE) in relation to contaminated and regeneration of brownfield land that should not be forgotten.

CIWM is aware of extensive work with all relevant stakeholders on organics to land through the Quality Protocol regime, review of Standard Rules permits and WRAP’s Organics Roadmap.  Both the Standard Rules permits and Organics Roadmap look towards as near to zero plastic spread to land, a positive move the resources and waste sector supports but needs assistance from other quarters to achieve, including householders.  Government should support local authorities in providing quality feedstock for the resources and waste sector to collect, handle and process.

CIWM suggests:

• Accurate data on bio-organics arising from commercial & industrial as well as agricultural sectors – this will enable the resources and waste sector to sustainably manage these wastes and provide legal, circular economy treatment routes.
• Continued support for End of Waste criteria for quality compost and digestate materials to land – this will continue to encourage the manufacture and use of quality assured products on soil and reduce the regulatory burden to business.
• Fully resourced environmental regulators for organics – environmental regulators need to enforce regulations that ensure organics treatment processes do not impact on the climate (due to inappropriate releases of ammonia, for example), contaminate land from illegal deposits and ensure standards are upheld.
• Communication budgets for local authorities to encourage residents to put food and green waste out without contamination, especially by conventional plastics – this should reduce waste disposal and increase the efficiency and economy of organics recycling practices.
• Consider practices in other European countries and beyond, in relation to organics outputs efficiency and optimisation of nutrients – this will enable organics strategies and technologies that are already in play to be learnt from and developed further for the UK market.
• Promptly introduce mandatory food waste collection from household and business premises – this will ensure all organic waste that is available is captured, effectively and reduce greenhouse gas emissions from inappropriately treated organics and reduce food waste.

February 2023