Guidance note on the requirements for plant handling and storing

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Requirements for plants handling and storing and derived
products
Contents
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What are ABP handling and storage plants?
What are ABP handling plants allowed to do?
What are ABP storage plants allowed to do?
What conditions must Handling and Storage plants satisfy?
How do I become approved?
Conditions in more detail
What is a covered space?
Must all operations be carried out within the covered space?
Separation of Category 1 and Category 2 material from Category 3 material
Products of animal origin which are intended for human consumption
Labeling of products of animal origin intended for human consumption
Transport of products of animal origin intended for human consumption
What are ABP handling and storage plants?
Previous legislation referred to these plants as either intermediate plants, where the material
concerned was unprocessed raw animal by-product (ABP), or as storage plants, when the
material was fully processed. The new (EC) legislation has altered the terminology and now
refers to:
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the handling (and storage) of ABP where raw material is concerned
the storage of derived products.
The new legislation is:
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Regulation 1069/2009 hereafter referred to as the “Control Regulation”.
Implementing Regulation 142/2011 hereafter referred to as the “Implementing
Regulation”.
What are ABP handling plants allowed to do?
Handling plants can engage in the activities listed in Annex IX chapter II of the EU
Implementing Regulation, that is:
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sorting, cutting, chilling, freezing, salting, removal of hides and skins, removal of
specified risk material, post mortem examination and taking of samples, pasteurisation of
ABPs prior to their use in AD or Composting plants located elsewhere, sieving.
Further approval as a storage plant is not required.
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What are ABP storage plants allowed to do?
Article 24, point (j) of the EU Control Regulation, permits storage of derived products intended
to be:
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disposed of by landfill or incineration or intended to be recovered or disposed of by coincineration
used as a fuel for combustion
used as a feed, excluding establishments or plants approved or registered in accordance
with Regulation (EC) No 183/2005
used as organic fertilisers and soil improvers, excluding storage at a place of direct
application.
What conditions must Handling and Storage plants satisfy?
In general the material must be handled and/or stored in a safe manner with no risk of disease
spread to either man or animals.
This is achieved by the need to comply with the specific requirements detailed in the EU Control
Regulation.
The requirements for plants that handle unprocessed ABP and store material, as outlined
above, are set down in Annex IX, Chapter II of the EU Implementing Regulation.
The requirements for plants that store ABP derived products, as outlined above, are set down
in Annex IX, Chapter III of the EU Implementing Regulation.
Plants must be:
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Approved to receive animal by-products as required by Article 24 of the EU Control
Regulation
Comply with the general and hygiene requirements as detailed in Annex IX, Chapter II,
Section 1 and Section 2 or Chapter III, Section 1 of the EU Implementing Regulation.
and
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Where a plant stores/handles more than one category of ABP it must have a hazard
analysis and critical control points (HACCP) plan as detailed at Article 29 of the EU
Control Regulation.
Do buildings used to store fully bagged material have to be approved?
Buildings, such as warehouses, that are used to store bags of derived products such as
compost and manure that has been manufactured into a products for sale to the public, have to
be approved. This includes the first storage plant of imported manufactured manure. It is only
subsequent premises where the material is in retail packaging, such as garden centres, that do
not require approval.
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Do food waste transfer stations require approval?
Waste transfer stations receiving catering waste destined for composting or biogas plants must
be approved as either a handling plant, if the material is sorted or shredded to a required
particle size, or storage plant if the material is only stored. There is exception to this in Northern
Ireland where food waste transfer stations receiving catering waste from domestic
establishments only (ie not commercial food waste for example from hotels) do not require
approval under the Animal By-Products Regulations as the controls operated by the
Environment Agency gives sufficient protection.
Waste transfer stations handling catering waste that is going directly for land fill do not have to
be approved.
How do I become approved?
Applications are available on the DARD website or can be completed on line via this Link. You
can also obtain an application form by contacting Veterinary Service on 028 905 25275 or
applications.aiabp@dardni.gov.uk.
This form must be completed and returned to allow an approval inspection to be arranged.
Detailed conditions will need to be complied with and you will need to satisfy the inspecting
officer that you are able to operate the facility in compliance with the legislation. If satisfied,
DARD Veterinary Service will issue an approval document that will allow you to operate.
Once approved you will be subject to routine inspections, the frequency of which will be based
on the risk posed by the operation and how compliant you are in its operation. Currently there
are no charges for these approval or routine inspections.
Conditions in more detail
ABP handling and storage plants (formerly known as intermediate plants)
EU Implementing Regulation, Annex IX, Chapter II, Section 1, requires such plants to:
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be adequately separated from thoroughfares through which contamination may be
spread
have a covered space to receive ABP
be constructed in such a way that it is easy to clean and disinfect, and have floors that
are laid down in such a way as to facilitate the draining of liquids
have appropriate arrangements for protection against pests such as insects, rodents and
birds
have adequate facilities including lavatories, changing rooms and washbasins for staff
where necessary have appropriate means to control the temperature of the stored
material
have adequate facilities to allow for the cleansing and disinfection of vehicles and
containers in which animal by-products are transported.
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EU Implementing Regulation, Annex IX, Chapter II, Section 2 also has the following hygiene
requirements:
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sorting of ABPs is carried out in a manner to avoid any risk of disease propagation
during storage they are handled and stored separately from other goods
they shall be stored properly under appropriate temperature conditions, until redispatched.
ABP derived products storage
EU Implementing Regulation, Annex IX, Chapter III, Section 1 requires that:
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premises that store category 3 derived materials must not be on the same site as
premises that store category 2 and 1 derived material unless cross contamination is
prevented by way of layout and management of the premises, such as by the use of a
completely separate building
have a covered space to receive animal by-products
be constructed in such a way that it is easy to clean and disinfect, and have floors that
are laid down in such a way as to facilitate the draining of liquids
have adequate facilities including lavatories, changing rooms and washbasins for staff
have appropriate arrangements for protection against pests such as insects, rodents and
birds
have adequate facilities to allow for the cleansing and disinfection of vehicles and
containers in which animal by-products are transported
the ABP derived products shall be stored properly until re-dispatched.
What is a covered space?
To comply with the combination of these requirements it is necessary for a plant to have a roof,
walls and a floor and to be a permanent, weather-proof, vermin-proof structure. Thus it should
be of solid construction, built and operated in a way to prevent the entry of birds, rats, mice and
flies.
Standard reefer boxes and shipping containers do not meet these requirements so should be
located within a building if they are to be used to hold animal by-products. However, if
containers can be constructed and operated in such a way that they meet the requirements,
they could be located outside. Such a container would need to comply with the following
requirements:
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the container(s) must be of a suitable size to cope with the quantity of ABP the plant
receives
all ABP must be received directly into the container
ABP must be kept securely within the container (so that birds and vermin cannot have
access to them and they are protected from the elements)
cleansing and disinfection of the container must be possible. Spillages and the washings
from cleansing and disinfection must be contained and collected within the container or
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drained away from the container in a controlled manner, in the same way as would be
expected for a building. Draining out of the container onto the ground surrounding the
container is not acceptable.
Must all operations be carried out within the covered space?
All ABP plants shall have a covered space to receive and dispatch ABP, (Annex IX, Chapter II,
Section 1, point 1 (b) of the EU Implementing Regulation plus Chapter III, Section 1, point 2 (a)).
The covered space must be large enough to permit this except where the ABP are discharged
through installations which prevent the spreading of risks to public and animal health. Ideally,
all other operations at the handling or storage plant should also be carried out in the covered
space.
Where unloading or loading is a major hazard (e.g. the tipping of slaughterhouse waste), then it
must be undertaken within the covered space. However, where the inspecting officer is
satisfied that the unloading or loading is not a major hazard (e.g. transfer of whole carcases at
“skin and bin” plants), the officer may agree to either unloading or loading taking place outside,
in limited and tightly controlled circumstances. In such cases, suitable procedures must be in
place to ensure that it can be done without significant risk to public or animal health, and DARD
Veterinary Service guidance on unloading and loading procedures must be followed.
In the above circumstances safe handling and storage of the ABP would need to be addressed
in the written Standard Operating Procedures and HACCP plan in place at the plant. It would
also need to take into account the operation of the individual plant, including the ability of the
operator to routinely follow the agreed procedures.
Further guidance on the storage of manure
The EU legislation on storage of ABPs also applies to the storage of manure, including poultry
litter, at premises other than the place of production or use. It does not apply to the temporary
storage of manure on farmland prior to its application to that farmland.
It is a principle of the Regulation that controls should be proportionate to the risk. In the case of
manure and poultry litter storage in outdoor controlled conditions presents a low risk and is
permitted subject to conditions. There must be
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Separation from direct or indirect access from farm animals.
Separation from feed destined for farm animals.
Tracing of product is maintained.
Environmental controls are adhered to.
Access to poultry litter by livestock can cause botulism, so it is particularly important to avoid
cattle or sheep gaining direct access to stored heaps or material applied to land. Botulism can
also be transferred through animal feed.
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If the manure is going to be manufactured in some way then approval as a handling plant is
required.
What are the requirements for storage of poultry litter or manure?
i) The material must be received in packaging or in leak proof containers or means of
transport.
ii) The material may be stored outside or under cover, where storage does not pose
unacceptable risks.
Examples of unacceptable risk include:
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Farm animals having direct access to or poultry litter (or leachate from stored heaps);
There being risk of transfer of material from these stores directly to farm animals through
clothing, equipment;
Risk of contamination of feed intended for farm animals.
These means there must be adequate fencing, where appropriate or other means of separate to
ensure these risks are controlled.
iii) Floors must be constructed in a way that cleansing and disinfection can take place
appropriate to the risk. Any leached liquid that could be accessed by farmed animals
must be contained. In any case the EA must be consulted due to the above risks and
to prevent contamination of watercourses.
iv) Adequate facilities for staff should be available. This may mean staff facilities such as
lavatories are provided off site.
v) Pestcontrol arrangements need to be individually tailored to the perceived risks on site.
vi) Facilities for cleansing and disinfecting the delivery vehicles need to be provided, but
may be provided off site where appropriate.
vii) Full records and commercial documents must be kept of incoming material and for all
outgoing loads of material, as per requirements in the ABP Legislation. These would
not be required from retailers supplying within UK to final users, other than business
operators.
Separation of Category 1 and Category 2 material from Category 3 material
Article 28 of the EU Control Regulation requires that operators put in place, implement and
maintain their own checks to ensure compliance with the regulation. Article 29 further requires
that if a handling/ storage plant handles or stores more than one category of animal by-product
or derived product they must implement and maintain a permanent written procedure or
procedures based on the HACCP to ensure strict separation and prevent the risk of disease
spread to animals and man.
Annex IX Chapter II Section 1, point 1(a) of the EU Implementing Regulation requires the layout
of handling and storage plants to ensure total separation of category 1 and category 2 material
from category 3 material from reception until dispatch.
The structure and operation of the plant should ensure the necessary separation is achieved
and the HACCP plan should address the hazards and risks associated with the operation. The
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exact requirements will depend on the individual operation and the type of material handled, but
in general we would expect the level of separation described below:
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Category 1 and 2 plants may be located on the same site and, subject to adequate
controls, could be in different parts of the same building.
They could be adequately separated within a building by a dividing wall from floor to
ceiling or by dividing partitions.
The operations must remain separate and there must be no access from one operation
to another.
There must be no possible seepage, splash or spray drift (from washing) from one side
to the other.
Alternatively, categories 1 and 2 could be mixed, and everything classified as category 1.
The material from a category 3 storage plant will usually be consigned to a category 3 rendering
plant or to another permitted destination for category 3 material where there will be no category
1 or 2 material. Thus category 3 plants should, preferably:
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be located on a separate site or at least in a separate building from plants handling
category 1 or 2 material.
However, if a category 3 handling or storage plant is to occupy part of a divided building
handling more than one category of material, that part of the building should be
structurally and functionally equivalent to a separate building.
Products of animal origin which are intended for human consumption
Although not desirable, it is possible for raw material of animal origin which is intended for the
manufacture of products for human consumption (“food material“) to be consigned to a site on
which an ABP handling or storage plant is situated, before being consigned to the
manufacturing premises, but strict conditions apply. These include:
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the handling or storage plant and the food plant must be demonstrably separate
food material cannot under any circumstances be taken into the handling or storage plant
the food plant must be approved and operate under Regulations (EC) 852/2004 and
853/2004 and in particular the requirements in Annex III of Regulation (EC) 853/2004
approval of these premises can only occur after the hygiene authorities have had an
opportunity to comment on the application.
Labeling of products of animal origin intended for human consumption
Products of animal origin that are to go into the food chain should not be labeled as ABP. If so
labeled they will be treated as ABP for enforcement purposes. Products of animal origin
become ABP when they are no longer intended for human consumption. If material is labeled as
ABP that is clear evidence of intention.
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Transport of products of animal origin intended for human consumption
If ABP and food material are transported in the same vehicle, they must be kept separate and
identifiable during transport. ABP must be transported in sealed new packaging or covered leak
proof containers. The food material must be transported under satisfactory hygiene conditions
and at the temperature required under the food hygiene legislation. Category 3 ABP destined
for the production of animal feed or petfood must also be transported chilled or frozen unless
processed within 24 hours of departure.
Supermarket and manufacturing returns depots
For information on handling plants that receive supermarket and manufacturing returns please
see the Guidance
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