The Ontario Independent Meat…

The Ontario Independent Meat Processors association is a non-profit industry organization representing 147 meat processing plants throughout Ontario. We are pleased to provide comments regarding the Environmental Registry posting 010-1436. There are many positive attributes in the proposed Framework for the Management of Non -Agricultural Source Materials and we applaud the MOE and OMAFRA for the work performed so far on this initiative. This is a great opportunity to make the standards simple and easy to understand so operators can easily follow the rules. Three main areas that we feel are beneficial and will move waste management practices forward are: Minimum beneficial quality standards for NASM Sampling and analysis standards according to NASM classification and risk level Streamlining regulatory overlap The following is a list of concerns, unanswered questions and recommendations: There are some grey areas that directly affect meat plant operators. Some abattoir operators supply their abattoirs solely from their own feed lots. While the land the abattoir is on may be non-contiguous, the waste from the abattoir is returned to the farm of origin. Is the waste returned considered NASM or ASM? How does this compare to an abattoir/feedlot on contiguous land? We recommend that non-contiguous operations be given the same consideration as contiguous operations. Blood from abattoir operations is a component of waste that is often mixed with waste water during processing operations. Blood has a highly beneficial volatile nitrogen content and is an effective soil amendment ingredient. This is a main part of an abattoir waste stream. Is there a category for this waste component in the proposal? We recommend that blood be assigned a NASM category that reflects the usefulness of this waste as a soil amendment. Is manure from abattoir barns considered a NASM while manure from a feed lot considered an ASM? If this is in fact the case then reconsideration of abattoir manure is needed as this manure is clearly of farm origin. Many meat processing plants including most abattoirs will fall into the category of a NASM generator. The need to have a certified person prepare the nutrient management strategy will add to the operator’s costs of doing business and we question the value of the plan preparation when compared to existing practices. Making the process too burdensome on operators may drive the process of waste management underground. We recommend a more user friendly approach that places accountability on the owner of the NASM generator to prepare a nutrient management strategy based on a template provided by government. Field management proposals at the farm level will have the same effect on costs. The onus should be placed on the farm operator to produce a nutrient strategy or plan based on a template prepared by government. Is the definition of a field on a farm a fenced off area or does the definition of a field encompass like soil characteristics and topographical attributes? If the later is the case then a field could include the largest possible area for a Field Nutrient management Plan and at the same time address the need for setback standards, soil depth standards and application rates. This will lead to reduced registration or approval costs. Field storage requirements in the proposal are too restrictive in terms of the time frames allowed for both permanent and temporary storage. Further consultation with farm operators should be initiated to develop standards for storage times that are workable and will still protect the integrity of applying stored materials in a timely manner. Consider 240 days the maximum storage time for permanent storage to allow for periods in winter where it may not be possible to spread NASM because of snow or wet soil conditions.

[Original Comment ID: 104737]