Guidance on Complying with Regulations

Classification of Manure as a Waste

In April 2008, Environmental Permitting (EP) Regulations 2007 came into force. The EP Regulations combine the Waste Management Licensing (WML) Regulations 1994 (as amended) and the Pollution, Prevention and Control (PPC) Regulations.

The Low Risk Position on horse manure has been withdrawn. Consequently, manure that is used as a fertiliser to benefit land is no longer treated as a waste and as such, is not subject to the EP Regulations 2007.

Manure is however classified as a controlled waste if it is discarded, i.e. disposed of by burning, tipping or burial. Horse manure will also become a controlled waste if it is mixed with other wastes (e.g. green garden waste), whether it is mixed on the premises or elsewhere. For example, manure that is disposed of via a commercial composting site, where it is mixed with other waste will be classed as controlled waste, and as such a registered carrier should be used and a waste transfer note obtained. The keeping, treatment or disposal of manure classified as a controlled waste is subject to the Environmental Permitting Regulations 2007. The producer and anyone else involved in managing the manure has a Duty of Care to ensure it is stored and disposed of in accordance with all appropriate legislation. In England and Wales this is regulated by the Environment Agency (EA) through a system of permits. For more information, please visit the Defra Defra waste management licensing pages or Environment Agency environmental permitting pages.

The treating, keeping and disposing of controlled waste without an appropriate permit or exemption is an offence. The discharge of effluent or polluting matter to controlled waters without consent is also an offence. The Environment Agency may take action when an offence has been committed.

The following information is intended to provide people who store, handle, transport or utilise horse manure as a fertiliser with some basic information on how to prevent pollution.

The Animal By-Products Regulation (EC 1774/2002) defines a 'farmed animal' as 'any animal that is kept, fattened or bred by humans and used for the production of food (including meat, milk and eggs) wool, fur, feathers, skins or any other product of animal origin'. Horses kept for leisure or agriculture therefore do not fall within this definition so their manure is not controlled by the Regulation.

Storage and Composting

Please refer to the Manure storage and disposal advice page for recommendations on the responsible storage of manure and the below Guidance on storing and composting manure.

• A permit or exemption under the EP Regulations is not required to store manure used as a fertiliser at the premises where it was produced, or at another premises (e.g. an allotment site).
• The storage of manure classified as a controlled waste is subject to regulation and all aspects of Duty of Care must be complied with.
• The open burning of manure is an offence under the Environmental Protection Act 1990 and Clean Air Act, 1993.
• Effluent leaching from large manure piles can have serious pollution implications, also prosecutable under the Environmental Protection Act, 1990, the Groundwater Regulations 1998 and the Water Resources Act 1991 section 85.

Run-off from manure heaps, water used to wash down rubber matting in stables, and water used to soak hay should be directed to an impermeable lagoon, a sealed effluent tank or – if consent has been sought - a foul sewer. The liquid can either be removed by a contractor or if appropriate, may be spread on pasture or farmland in accordance with the Defra Codes of Good Agricultural Practice and Nitrate Vulnerable Zone Regulations.

Handling

Manure must be kept separate from normal household waste, which is subject to different legislation. Even manure produced within the curtilage of a dwelling house should not be mixed with general household waste.

Transporting

Neither a waste transfer note nor a waste carrier registration is required for the movement of manure that is to be used as a fertiliser.

However, movements of manure classed as a controlled waste must be in accordance with the EP Regulations and a waste carrier who is paid to transport waste manure must be registered with the EA. Registered waste carriers must issue a waste transfer note detailing:

• The waste type and quantity;
• The container used;
• The place, date and time of transfer;
• Names and addresses of both people involved in the transfer;
• Information indicating whether the person transporting the waste is the importer or producer of the waste;
• The registered waste carrier's certificate number and the name of the issuing EA;
• If applicable the Environmental Permit number and name of the issuing EA and reasons for any exemption from the requirement to register or have a permit.

The note must be filled in, signed and kept for two years by both persons involved in the transfer. If manure is transferred between the same parties throughout the year, an annual note may be written in advance to cover the whole year. Please refer to your telephone directory to find a local haulier.

People transporting manure without the need for an EA registration are advised to keep similar records to those described above as evidence of correct manure handling and use.

Whenever manure is transported, the producer must ensure that manure is adequately contained or packaged to prevent any waste (including liquid run-off) escaping from control during transportation.

Land Application

When manure is spread on farmland the Nitrate Vulnerable Zone Regulations and Defra Protecting our water, soil and air: a code of good agricultural practice for farmers, growers and land managers should be followed. In any circumstances when manure is applied to land, a few sensible precautions should be taken, for example:

• Application rates should be in accordance with soil requirements for crop production;
• A ten-metre margin should be left around watercourses and ditches and a fifty-meter margin left around springs, wells or boreholes. In any event, the use/deposit should not be allowed to cause pollution;
• Manure should not be applied to hedgerows;
• Weather and ground conditions must be correct to avoid pollution.

Horse manure should only be spread on the land for the benefit of agriculture or ecological improvement. The disposal of properly composted manure through allotments, garden societies, farmers etc, is an acceptable practice which the Horse Pasture Management Project is encouraging.

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Guidance on Storing and Composting Horse Manure

Manure can be used as an organic fertiliser after composting, or removed from the site for use as a compost additive by a central facility. Both good storage and composting require active management if this is not to become a pollution hazard, and the planning of manure management needs to be given as much consideration as other aspects of running stables. Larger scale businesses are more likely to require regular removal from the site, whilst composting may be a useful option for smaller ones, or where a local market exists. In all cases, the storage facility must be on hand, designed to meet the stable's particular requirements of handling the quantity of manure, the need for vehicle access must be considered and pollution avoided.

Guidelines follow on storing the manure for collection, and the further step of controlling the decomposition process to produce a rich and stable organic fertiliser. This information has been written to build upon the advice provided by the Manure storage and disposal page.

Volume

The expected volume of manure should be calculated according to the number of horses being kept and the length of time that it will be stored for. The choice of bedding will have an impact on the quantity of material. Straw produces more bulk than wood chips or shavings but composts faster. If the planning reckons with two cubic feet of manure and soiled bedding per animal per day, this will act as a good guide.

The time it will be stored for will vary from, for example, a fortnightly removal by a recognised manure transport company, to several months if the composting process is being managed on-site.Sites often have two manure storage areas, allowing for one heap of manure to be composted, whilst the other is being built up.

Access

The management of the storage facility implies a choice about vehicle access. Many stables muck out on a daily basis although some stables may operate a deep litter system, where droppings are removed daily and new layers of dry bedding are added with the whole bed being removed at less frequent intervals.

If removal of manure from the site is the preferred option, then the storage area will have to allow for vehicle access. If a haulier is removing manure, the surrounding surface will need to allow for the turning and operation of a grab lorry or for the delivery and removal of a skip or container used for collecting the manure. Smaller-scale removal by gardeners/allotment holders etc will still require a suitable hard-standing to allow year-round access for collection. Even when manure is composted for use on-site, a hard surface allowing tractor access and ease of use throughout the year is desirable.

The location of the heap should be convenient for access from the stables, but not so close as to cause horses a nuisance from flies or respiratory problems.

Pollution

Run-off from poorly managed manure heaps is both a loss of fertility and potentially a serious pollution hazard. Maximising the nutrient value of the manure is consistent with minimising the environmental impact.

It is important therefore that the storage area is level, possibly with concreted or hard standing underneath. If the site is by necessity sloping, then the provision must be made to keep rainwater away from the manure piles and to collect any run-off into sealed tanks for collection. It is essential, and a legal requirement, that no run off should find its way into watercourses either directly or through the drainage system.

If field storage is an option being considered, there is the danger throughout much of the year of manure piles becoming too wet, as well as vehicle access being limited. The manure storage site needs to be carefully chosen.

To avoid pollution, the manure heap should be kept as dry as possible. This could be achieved by having a roofed storage, provided that this does not conflict with the need for adequate vehicle access. Alternatively, the heaps should be kept covered, using, for example, agricultural grade black plastic held down by tyres and bricks, which is easily removed and reused. Woven textile fabrics such as Toptex also exclude light and shed water and offer a longer lasting solution, though at a higher cost, but are invaluable if composting or field storage is being attempted. They also avoid the problems of disposing of the plastic. If composting on site is being attempted, control of the moisture content of the heaps is an essential element. The visual appearance of coverings should be considered and all attempts made to ensure a visual eye-sore is not created. This can be achieved by selecting a fabric with a dark colour which will blend in with the surrounding area, and by locating the muckheap in an area which isn't highly visible. A native hedgerow of British provenance will help provide a screen, if necessary but should not be planted directly by a heap, where it could suffer from the nutrient enrichment.

Consideration should also be give to odour pollution when siting storage areas. Where is the prevailing wind? Who might be inconvenienced by the smell?

Composting

Horse manure is potentially a good organic source of nitrogen, phosphate and potash. It is dynamic and unstable in its raw form, however, making it quite unsuitable for returning directly to the land, where it may rob the soil whilst breaking down or constitute a pollution hazard. It needs to be composted, which is the management of the process of decomposition of the manure, so it becomes stable without losing its valuable nutrients. When it is properly controlled, the parasites, eggs and larvae, which could find their way back to the horses via the land, are destroyed. The process takes a number of months, longer in the autumn and winter than in the warmer times of year.

Composting on site may be an attractive option for the smaller scale stable, where there is a local market amongst gardeners and farmers, or the intention is to return some of the manure to land. There are many ways of composting, and the description that follows is a scenario with a minimum input. If heaps are larger than described, they will need frequent turning to allow air in - to prevent the pile becoming anaerobic and smelling - and specialist compost turning equipment may need to be purchased or hired.

• Manure and bedding need to be gathered into heaps of ideally up to 2.5 meters wide and 2 metres high, although the actual heap size will be influenced by the number of horses kept. As with storage, the site should be level, or have a slight slope towards the back to reduce the likelihood of any liquid escaping. A covering of woven textile fabric such as Toptex {Imported into England by Polyfelt} helps by excluding light, but allows air and a small amount of water to pass. If other green waste is available, such as grass cuttings (but not woody materials), this can be incorporated and improves the process but bear in mind the implications this will have on manure becoming a controlled waste. Soil can also be included, up to 10% of the total volume, which stabilises the decomposition process.
• The heap will need to be damp for decomposition to occur- some watering may be necessary when the heap is being built - but should not be wet and there should never be run-off.
• The pile will heat up rapidly, reduce in volume and then cool after perhaps three weeks, varying with the time of year. At this point the heap should be turned, to allow more air into the pile and to mix the ingredients. If it is dry, it may need watering to ensure that it is evenly damp.
• The covered heap can now stand for a couple of months and undergo a cooler process of decomposition. It can be helpful if at this stage the manure is in contact with the ground, which allows in the worms and micro-organisms that bring about this transformation, so in a dry spring or in summer, the heap could be moved to an appropriate field location when it is turned. This must be at least 10 meters from a watercourse and 50 meters from a well, spring or borehole. There is again a reduction in volume, though less than before. This stage may take 6-8 weeks in summer, or 3-4 months over winter. The manure should be altered in texture, smell and colour; if the bedding is poorly broken down, another turning will be necessary.
• The compost should be used or sold once ready. It can be stored under cover, or in sacks, but there is no gain in keeping it longer.

The quality of the compost will vary according to the bedding. To maximize the nutrient value of the compost, it is best to have the horses bedded on straw, and it is certainly helpful if soil or other green matter is mixed in. The lignin in wood shavings or chips or sawdust use up far more of the nitrogen in the manure during decomposition, and though the result is a good soil conditioner, it is poorer in nutrients.

A deep litter system, giving regular large quantities of material, suits the composting model, though care has to be taken not to leave too long between mucking out as damp bedding and ammonia gases can be harmful to the horses. Otherwise the manure and soiled bedding will have to be accumulated gradually in heaps and extra turning may be necessary to mix the older and newer material. The length of time the manure is kept on site and the regular turnings that are required will mean that a careful calculation of the space is necessary.

If manure is being returned to land, a calculation has to be made about how much the land can healthily take. Advice will have to be sought for each specific case, but the rule is that the nitrogen applied in the composted manure needs to be equal to the nitrogen of the crop that is harvested. So a pasture yielding an 8 tone/ha grass crop can take the annual manure production of about five horses; if the fields are more productive, they can take more manure.

Marketing of Compost

Unless you have access to suitable bagging equipment, your compost will have to be sold loose. This can be achieved in a number of ways:

• On a 'do-it-yourself' basis, where individual people load bags or trailers;
• In bulk to landscape gardeners and parks maintenance departments and contractors. In these cases the purchaser will usually be able to cart the compost themselves, although they may expect you to have a bucket tractor or similar for loading their wagons;
• Delivered to allotment gardens, garden centres and landscape contractors.

In order to help horse-keepers to dispose of manure by reuse, the Horse Pasture Management Project operates a Manure Wanted and Available webpage, where adverts can be placed by horse-keepers with manure available, and by individuals or allotments searching for a supply of manure.

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