As it relates to food waste, the Efficiency stage is characterized by technological efficiencies, but with attention to O’Brien (2013), excluding initiatives that reinforce capital relations and facilitate capitalist surplus management. Equally important, while this stage can address issues of consumer behaviour, it should do so in a way that does not blame individuals for what are wider structural phenomena.><
Better information on waste and resource inefficiencies
With less than five percent of agricultural research funding allocated to post-harvest systems and loss (Parfitt et al., 2010), additional funding from agencies such as the Natural Sciences and Engineering Research Council of Canada and Social Sciences and Humanities Research Council would potentially enhance our understanding of food waste. In addition, definitions of food waste and standards for measurement are required to promote consistency and useful comparisons across studies. Reliable waste estimates and an understanding of the causes are needed to identify where food waste can be efficiently minimized. Policy makers (and private businesses) need reliable information to conduct cost-benefit analyses of specific waste-reducing initiatives (Buzby & Hyman, 2012).
Improved research on food waste permits better goal setting and targeting of initiatives at multiple levels in the policy system.
In the European Union (EU), the single biggest transition in waste and waste policy is the 1999 Landfill Directive (1999/3/EC); a policy that set out to reduce the negative effects of sending waste to landfill in relation to the environment and human health. This document set legally binding targets to which member states are to adhere.... The targets are exceptionally ambitious – not least the obligation to reduce biodegradable waste (the category to which food waste belongs) to 35 per cent of 1995 levels by 2016, or by 2020 for some countries (including the U.K.) (Evans et al., 2013, p. 17) .
In the U.K., the existence of this directive produced the Waste and Resources Action Programme (WRAP), an independent non-profit organization with an international reputation for its research, expertise, and advice in a number of areas including food waste reduction. WRAP U.K. sets out to minimize resource use and divert valuable waste from going to landfill. They work in partnership with a number of retailers and manufacturers to help achieve these goals. Being funded by government bodies such as the Department of the Environment, Food and Rural Affairs (DEFRA) allows them to build evidence on food waste and the necessary measures to reduce it.
Both the E.U. and the U.S. have 50% food waste reduction targets, Europe by 2020 and the U.S. by 2030 (National Zero Waste Council, 2016). As yet, Canada has no national targets, but the National Zero Waste Council (NZWC) has called for a Canadian target in line with that of the U.S. (NZWC, 2016). Several regions have modest targets. For example, Metro Vancouver’s objective, working in collaboration with WRAP U.K., is to reduce household food waste by 10% by 2018 (Cech, 2016).
In Ontario, supermarkets, restaurants and manufacturers (among other businesses) must conduct a waste audit and create a waste-reduction work plan, and update that audit every year under Regulation 102/94 of the Environmental Protection Act. Smaller operations are exempt. The Recycling Council of Ontario (RCO) and the Ontario Ministry of the Environment and Climate Change (MOECC) give businesses advice and information on how to implement a waste diversion program. Although the MOECC clearly identifies that a successful waste reduction programme has multiple dimensions, the Regulations do not require businesses to include all streams of waste in their action plan, so food waste is often left out of companies’ diversion programmes. The MOECC should set specific reduction and diversion targets (see discussion below regarding the Waste-free Ontario Act) for each stream, including organic waste. Opportunely, the supermarket chains have voluntarily included food waste in their diversion programs for various reasons discussed below. Unfortunately, the lack of transparency from these waste audits makes it difficult for those outside the retail sector to ascertain whether these companies are meeting any of their commitments.
Regarding processing, as some processing marketing boards have regulated contracts (e.g., the Ontario Vegetable Processing Marketing Board), waste reduction could become a priority of contract execution with sectoral targets and product specifications so as to reduce waste.
Edible food for direct human consumption at minimum resource expenditure
Educational campaigns are often a preferred strategy because they can easily be implemented by the private or public sector and may increase consumer knowledge and awareness of food waste. They are politically acceptable because of their low-cost and accommodation of current food business models. Agri-food corporations may even benefit by promoting positive images of their commitment to consumer cost-savings, sustainability, and feeding the hungry. Overall, educational campaigns act as a step towards changing long-term consumer attitudes and behaviours regarding food waste.
Part of the challenge is the complex array of household characteristics, beliefs, attitudes and behaviours that influence food waste, some of which appear to be counter-intuitive (cf. Parizeau et al., 2015). Awareness does not always lead to greater understanding of how eaters contribute to the problem and what they can do to reduce waste (Guelph Food Waste Project, 2014). A survey of U.S. households found that 63% of consumers felt food waste was a problem, yet only 34% believed that their household contributed to it (Watson, 2014). Similarly, when respondents from Guelph, Ontario were asked what they could do to reduce waste, almost 40% could not think of anything (GFWP, 2014). Some studies show that once people are aware of the value of their losses, then there is more commitment to handling food more effectively (Hodges et al., 2011). Metro Vancouver appears to be banking on this in their food waste campaign, estimating that food waste is costing the average household $700/yr (Metro Vancouver, n.d.). Parizeau put forth a similar national estimate from her work, $760/yr/household (Tobin, 2016). Campaigns can also help consumers improve food purchasing skills, meal planning, leftover use, gauge what is safe to eat, and interpret date labeling. Additionally, interventions can help consumers develop a certain waste tolerance, for example, to accept a package of strawberries, even if one strawberry is damaged or spoiled (Terry, Mena, Williams, Jenney, & Whitehead, 2011).
Education campaign architects must understand the motivations that drive consumers to waste and how consumers frame this issue. Many households do not perceive food waste to be a significant environmental problem; rather, it is often viewed first and foremost as a social issue (Parizeau et al., 2015). Watson and Meah (2013) suggest environmental campaigns will not be very effective unless the ethic of thrift is linked directly via environmentalism. As such, educational campaigns may more effectively shape consumer behaviour by framing them with social impacts, rather than strictly environmental or economic ones . According to this thinking, food waste reduction campaigns should use guilt generated from throwing out edible food when many others go hungry.
There are several approaches and tools available to implement educational campaigns. One is to provide proper storage and handling instructions, near the product display, on small take-away cards. Another example is mobile phone applications that provide educational materials and tools to assist consumers with reducing their waste. In addition to Facebook and Twitter, WRAP U.K. introduced the Love Food Hate Waste App at no charge to communicate with consumers. In the WRAP U.K. partnership with Metro Vancouver, such campaign strategies are being attempted in the Canadian setting (Goodwin, 2014). A third example could be radio, television, or print public service announcements, such as the food waste commercial commissioned by the Scottish government in 2014 . Provinces may have existing legislative frameworks to support this, for example, Ontario’s Environmental Protection Act provides the means to finance educational campaigns.
Another common approach is to create “Days”. On March 5 2014, a New Democratic Party (NDP) MP tabled a motion in the federal House of Commons:
That, in the opinion of the House, the Government should: (a) declare October 20th of each year National Day Against Food Waste; (b) develop a comprehensive pan-Canadian plan to reduce food waste by (i) educating Canadians about food waste through a national campaign, (ii) facilitating the donation of safe, unsold food from the private sector to community organizations and food banks; (iii) putting in place various other measures to reduce the environmental impact resulting from the production of unused food (NDP, 2014, para. 6).
The motion also called for national targets and a national food waste reduction strategy but failed to pass.
Food label changes
For other changes to food labeling, see Goal 1, Consumer information.
Another efficiency stage measure involves changes to food date labels. A variety of date labels are used on foods, including “sell by”, “use by”, best before” and “expiration” dates. In Canada, best before dates are required for pre-packaged foods that will keep fresh for 90 days or less; “use by” labels apply only to pre-packaged fresh yeast; and “expiration” dates are required for select products like infant formula (Canadian Food Inspection Agency, 2014). Of the various food date labels, best before dates cause the most confusion for consumers. They describe the anticipated amount of time that an unopened food product, when stored under appropriate conditions, will retain its freshness, taste, nutritional value, or any other qualities claimed by the manufacturer. Therefore, best before dates do not indicate food safety, as food is still consumable after the best before date has passed (CFIA, 2014). Unfortunately, many consumers are unaware that food recently past its best before dates is usually still edible and waste is the result. According to Gooch et al. (2019), date codes contribute significantly to meat/poultry and grain product waste.
The confusion over best before dates, and the subsequent fear of unsafe food, also drives waste at food retail. It has been documented in the U.S. that stores remove items in advance of these dates in order to maintain their image of carrying only fresh products (Gunders, 2012), and presumably the same occurs in Canadian retail outlets.
Although federal regulations dictate how dates are declared (CFIA, 2014), they do not guide how they are calculated. There are some specific guidelines for certain foods and bacteria (e.g., Listeria in ready to eat foods). Other jurisdictions, however, provide more guidance, including New South Wales (NSW) Australia (NSW Food Authority, 2010), New Zealand (New Zealand Government, 2012), and the U.K. (U.K. Food Safety Agency, 2011). To ensure greater consistency, as part of pre-market clearance, companies with products covered by Best Before and Expiry date regulations should identify the method of determining durability and a summary of the data that supports the dates they propose. Since the Food and Drugs Act permits the Minister to prevent the sale of products with misleading labels, a regulatory amendment to the effect that the Minister can advise a firm to make changes to its Best Before dates, would then allow for adjustments should the Minister determine the dates to be inaccurate. Major food corporations have signed on to a call for action, with the objective of standardizing best before dates worldwide by 2020, but it is not clear how they and governments will actually address these problems.
An additional initiative would be to post “freeze before” date marks on packaging in combination with best before marks for certain foods (WRAP U.K., 2012). This would require only minor amendments to Food and Drug Regulations B.01.007 (1.1)(c) for prepackaged product having a durable life of 90 days or less and packaged on the retail premises from which it is sold. A comparable amendment would be required to B.01.007(1.1)(b) for a prepackaged product having a durable life of 90 days or less and packaged at a place other than the retail premises where it would be sold. In a similar vein, a French co-op, Les Gueules Cassées, successfully created a “close to date” expiry label for their range of products. Food retailers buy the stamps and add them on any product they think should be discounted up to 50%, including vegetables, yogurt, cheese, deli meats, packaged sandwiches, and hummus (Perreault, 2015). Les Gueules Cassées also has consumer education materials and makes donations to NGOs working on food waste. Such approaches could be explored in the Canadian context.
Improving food donation
Gooch et al. (2019) estimated that 86% of excess edible food is not donated, with larger distributors and retailers the most likely to donate to food rescue. Once measures are put in place to reduce waste generation (see below, plus Substitution ad Redesign), this number would significantly fall, but it speaks to inefficacies in the system. Their study highlighted a lack of coordination and communication across the supply chain as a major factor, plus significant reluctance to donate based on lack of infrastructure, the costs and complexities of donation, and worries about undermining the brand, and legal liability, even though each province has a Good Samaritan Act. Vendor supply agreements can also specify that excess be destroyed rather than donated. Food rescue organizations are typically under-resourced and rely extensively on volunteers.
There are two key pieces of Ontario provincial legislation that facilitate the redistribution of food for donation. As part of the Local Food Act, 2013, the Taxation Act, 2007 has been amended, providing farmers with a tax credit of up to 25% of the market value for donated produce, in addition to the existing charitable donation tax credit. Other provinces have comparable donation tax credits, including British Columbia, Quebec and Nova Scotia. Additionally, the Donation of Food Act, 1994 protects donors from liability for any risks associated with food donated in good faith. While these pieces of legislation are encouraging, their effectiveness for increasing food donations remains uncertain. First, potential benefits may not be realized if neither the benefactor nor community food organizations have supporting infrastructure. In a survey of comparable U.S. food manufacturers, retailers, and wholesalers, half of respondents cited insufficient storage and refrigeration at food banks and a lack of refrigerated trucks and drivers as barriers to donating food (Business for Social Responsibility, 2013). In order to facilitate food donation and to bolster the effectiveness of the tax credit, capital grants should be provided to improve transportation and storage infrastructure. Second, despite the protections provided by the Donation of Food Act, many companies choose not to donate food out of concern for potential liability issues and negative publicity. These fears are unfounded, since the legislation is designed to protect donors except in cases of serious omission and gross negligence. Outreach and education to the private sector by the government and private charities may assist in overcoming this limitation.
Another approach to facilitate food donations is fostering linkages between volunteers and charitable organizations and producers, food retailers, and food service outlets. For example, governments and businesses should encourage innovation in online solutions, such as Ample Harvest, that quickly connect potential donors with community organizations (Gunders, 2012). Coordinating volunteer gleaners from charitable organizations can assist in overcoming high labour costs that deter farmers from harvesting excess or left over fruits and vegetables. Ontario Gleaners provides this service. France (Chrisafis, 2016) and Italy (Samuel, 2016) have now banned edibles from being thrown out by supermarkets. Instead, they have to be donated. This could be considered in Canada in the future.
Reducing shrink throughout the food supply chain has been possible with technology changes to cold chain management (e.g., making sure all the products and their storage areas, including the truck, are properly temperature controlled), GPS tracking to know where the food is in the distribution chain, and improved packaging. At the store level, technology has improved maintenance of correct storage temperatures, moisture removal (hot air in plant tissue holds more moisture), and prevention of over ripening with ethylene scrubbers and bacteria and mould reduction (e.g., with blue light radiation) (Director, Produce Operations, regional retail chain, personal communication, March 25, 2011). Such technology changes have occurred without significant state regulatory change, but if the state creates performance targets for critical technology systems, then such technology improvements might be accelerated. For example, most motors in cooling systems are old (Garnett, 2006). If the state progressively requires improvements in cooling motors and related cooling equipment, and companies replace older technology with new equipment, then more rapid system wide improvements would result (for more, see Goal 5, Energy Efficiency).
For many perishables (e.g., strawberries), packaging has not changed substantially in recent years, but there are examples of promising improvements. U.K. grocer Marks and Spencer’s extended the shelf life of strawberries by two days in their stores by inserting small ethylene absorbing strips in packages. It reduced waste by four percent (Business Green, 2012). Another technological advance is heat-sealed lids that considerably reduce pack weight while still maintaining product protection (Terry et al., 2011). To promote the use of more protective or innovative packaging by Ontario producers and retailers, producer and retailer organizations can disseminate information to their members on the potential of packaging improvement to reduce waste. Consumers can also be informed through the use of educational campaigns, as discussed previously. A fuller treatment of packaging issues is provided under Goal 4.
Size and portion changes, sales and returns
Packaging sizes are also problematic, with many too large for small households and serving sizes in restaurants too large for many eaters. Smaller size options are desirable to reduce waste (Gooch et al. 2010).
Such measures can be facilitated by regulatory change. For example, modifications to the Canadian Consumer Packaging and Labelling Act (CCPLA), could widen state authority for food waste reduction. Comparable changes would also be required to provincial regulations, such as the Ontario Farm Products Sales and Grades Act . The associated regulations could be altered to forbid “buy one get one free” (BOGOF) sales for products and only permit “buy one get one free later” (BOGOF-L) sales (for example, a Tesco U.K. programme allows the free item to be picked up within 2 weeks). The Minister could also modify regulation 7 to restrict the ability of buyers to make last minute reductions to orders. As highlighted above, this often leaves the supplier literally holding the bag, with nowhere else to sell product and it goes to waste.
Regarding restaurant portions, as discussed above, the dominant approach generates considerable plate waste and contributes to overeating and associated health problems. Most food premises regulation is implemented at the provincial and municipal levels, but focuses primarily on food safety and does not serve well the changes proposed here. Federal and provincial food labeling regulations address primarily food retail establishments. However, a broad coalition of health advocates, first spearheaded by the Centre for Science in the Public Interest Canada (CSPI), has been calling for restaurant labelling. One formal response is Ontario Bill 45, Making Healthier Choices Act, 2015, that amended the Health Protection and Promotion Act. Although requiring calorie labeling on menus (into effect on January 1, 2017), it could be further amended to include a provision that meals exceeding 800 calories provide a reduced serving size option that is at least 33% lower in calories. This could be accomplished by reducing the serving size to meet that objective, either by removing certain items from the meal, or by reducing portions of all meal components. This approach does not require menu and ingredient reformulation, though some restaurants may choose to reformulate meals to bring them under the 800 calorie threshold. Restaurants without standard plate sizes – buffets, tapas, sushi and dim sum – would probably have to be exempted for logistical reasons. Bloom (2010) provides the example of T.G.I. Friday’s, a chain eatery in the United States, that launched a “Right portion, right price menu” in 2007, where they served about two-thirds of an entrée for two-thirds the regular price. Bloom (2010, p. 130) states that this programme “proved so profitable that the chain made the promotion permanent a year later”.
Expanding Suitable Feeds
The federal Feeds Act and Regulations permit many kinds of plant, fish and animal processing by-products as animal feed (see schedule IV and V of the Feeds Regulations), and there is a relatively well established infrastructure (from farm, processing and rendering facilities) for using such materials as feeds. Some of them (e.g., some animal by-products) will need to be progressively de-listed to meet the conditions of the environmental protocols (See Goal 5). Consumption will decline with animal population shifts and changes in the human diet, which will cause perturbations in the processing by-products markets.
The situation is more complex for plate waste from restaurants, institutions and households. Such materials are not named directly in the Feeds Regulations as they focus on single ingredient feeds and constituents. Plate waste is banned as a ruminant feed in Canada over fears of Bovine Spongiform Encephalopathy (BSE) or mad cow disease. Such feeds are typically only given to pigs, and only as a part of their diet. Belonging to the broad category of Recycled Food Products (RFPs), their use is now highly constrained. If sold, they must meet the conditions of the Feeds Regulations, highly unlikely because the regulations only grant minor variances in composition of the kind that plate waste cannot generally meet. They may be exempt from some of the regulations if they are donated to a single individual who uses them directly and does not redistribute. They must, however, be handled in a sanitary manner, which typically means refrigeration and then steaming to avoid disease spread. The rules effectively do not permit donation of plate waste from kitchens that also prepare meat, unless they are registered as feeds (CFIA, 2014a), a highly unlikely outcome given other conditions. Given the rules, and the infrastructure required to use plate waste on a widespread basis, opportunities as animal feed in the short-term are highly limited. Should Canada be sufficiently free of BSE in the medium term, some of the restrictions might be relaxed.
Nova Scotia has been conducting research on new feed products from organic waste diversion programs (Meikle, 2018).
Human and animal inedibles directed to compost and industrial applications
About 624,000 tonnes of food processing, slaughter, and rendering by-products produced industrial bioproducts such as biofuels, biochemicals, and biomaterials (AAFC, 2017). The challenge is to ensure that such uses were appropriate given the food waste hierarchy proposed here, and to augment where appropriate.
Compost – backyard, mid-scale community, curbside
Given our hierarchy, food waste should first be composted in backyards, on-site at multi–unit residential buildings (MURBs) and at specific activity areas, such as farmers’ markets and regular event locations. If this is not feasible, either because of the absence of facilities or the challenges of composting certain inedibles (e.g., bones and meat scraps in the presence of rodent and raccoon populations), then community (neighbourhood) composting is preferred, followed finally by residential and business pick up systems for centralized composting. Backyard composting requires the least infrastructure and transport. Sites at MURBs and event locations are more complex to manage. Community composting requires more infrastructure and time to execute, and curbside pickup and centralized systems are the most expensive, involving the highest infrastructure costs and the most complex distribution. With anaerobic digestion in centralized collection systems, however, facilities have the greatest potential for methane capture which is part of their appeal for the dominant system in an environment of surplus accumulation (see O’Brien, 2013). However, all composting systems can generate poor quality product and high emissions, thereby making utilization problematic.
Numerous municipal programmes provide access to backyard composters and information, but are highly variable in the quality and effectiveness of other programmes, especially on-site composting in MURBs and event locations. In Ontario, municipalities were not required under the 2002 Waste Diversion Act (now replaced by the Waste-free Ontario Act, see below) to collect food waste although most large municipalities do. The City of Toronto’s Green Bin Program (GBP) is one of the largest organic waste diversion programmes in North America but until recently did not have the capacity to make compost from all its organic waste. Unfortunately, the procedure for building supporting organic waste processing facilities is long-term and cost prohibitive for many municipalities and businesses (Gooch et al., 2010). If actual diversion is lower than projected due to prevention and reuse resulting from measures proposed here, the current infrastructure may be adequate.
Unfortunately, most of the composted material in Toronto’s programme is of such poor quality that it cannot be used for growing food (Seccombe, 2013). Equally significant, after the programme was put in place, the City reduced resources devoted to backyard composting (Vidoni, 2011) which, in our framework, is highly counterproductive. In contrast,
the City of Edmonton has taken a unique approach to both solid waste and biosolids management at its composting facility, where 200,000 tonnes of organic municipal solid waste and 100,000 tonnes of biosolids are processed together to produce a compost that is sold to the agricultural, landscaping and land reclamation industries (Forkes, 2011, p. 65).
This suggests it is possible to design a curbside collection programme that can produce high quality compost.
In Ontario and other Canadian jurisdictions, community and mid-scale composting are essentially blocked by existing regulations. Community composting facilities would have to meet the regulatory and structural conditions set out for compost facility approval (OMOE, 2012) and obtain a certificate of approval as a waste disposal site. In Canada, this situation occurs because composting is still viewed primarily through the lens of waste diversion, rather than as an essential part of the nutrient cycle. In contrast, the five boroughs of New York City have some 200 sites, facilitated by the New York City Department of Sanitation’s (DSNY) Bureau of Waste Prevention, Reuse, and Recycling (BWPRR) (Goldstein, 2013). There are many proposals to take a new approach, with one being considered at an urban farm in NW Toronto, but it is not yet clear what this will produce.
In the Ontario system, community composting sites should be exempted under the Environmental Protection Act, if they met the following conditions:
- The facility only receives residential food scraps and yard waste (with potentially very select addition of nitrogenous or carbonaceous material to obtain proper C:N ratios for composting quality). Québec allows up to 150m3 of off-site waste to community sites at any time provided it does not contain any problematic material (e.g., meat, industrial waste) (Vidoni, 2011).
- Aerobic composting only.
- The operation composts less than 14 tonnes per week.
- In urban areas, minimum distances of 10 m exist to the nearest property line, water body, road or pedestrian walkway.
- A leachate mitigation plan is in place.
- The facility meets the “A” compost quality standards.
Curbside programmes would also need significant modification to create useable compost. Although participation rates are high, there is debate about how much household organic waste is actually put in the bins, so improving that rate is important. By some accounts, one-third of current garbage is still organic waste (Alfred, 2013). There are a number of issues associated with the current programme in Toronto. The use of plastic bags increases participation but decreases quality. The bins are poorly designed to prevent raccoons. Some percentage of the collected material does not get composted at all, in part because of a lack of processing facilities. Much of the composting is anaerobic which generally reduces nutrient quality in the residue that is subsequently aerobically composted in windrows. Efforts continue to use the methane generated for electricity production. Given the new provincial categorization scheme (OMOE, 2012a), Toronto compost should at least meet “A” compost requirements.
Increase tipping fees
“From a retailer’s perspective, if you could get your dumpster to get hauled for half the price to go to landfill than to a compost facility, it’s an easy choice. Their business is food, they need to make money to keep their costs down.” (Policy analyst, Environmental Commissioner of Ontario, personal communication, February 25, 2011)
Municipalities can use by-laws to set user and tipping fees. There is some debate about the level at which such fees would encourage alternative behaviour and the question is affected by the degree to which alternative approaches exist, with suitable infrastructure and support. As part of a long-term transition strategy, increasing fees is a first step to more significant changes down the road. Some evidence from local Canadian jurisdictions suggests fees over $100/tonne are required to get significant diversion (Anderson, 2014). See Substitution for analysis of landfill bans, the next stage after fee increases.
Implementing food waste provisions of the Waste-free Ontario Act
Compared to the 2002 Waste Diversion Act, the new Waste-free Ontario Act places greater emphasis on resource recovery, the circular economy, waste reduction and producer responsibility for waste. Up to this point under the 2002 Act, organic waste did not receive substantial attention, although many municipalities have been running green bin programmes. However, the government has developed the Waste-Free Ontario: Building the Circular Economy (2017) strategy, with goals and reporting on implementation. One of the four goals is to increase waste reduction and resource productivity, which includes implementing an action plan to reduce the volume of food and organic waste going to landfills. The Food and Organic Waste Action Plan identifies a suite of regulatory and non-regulatory strategies, “that seek to prevent and reduce food and organic waste, rescue surplus food, collect and recover food and organic waste, and support beneficial uses” (MOECC, 2018a, p.10).
The Strategy would also consider disposal bans. While encouraging, implementation is at early stages and ensuring that the details of the regulations support the initiatives set out here is the challenge. For more on disposal bans, see Substitution.
Improving deadstock handling
In natural systems, dead animals become food for scavenger and decomposer organisms, representing a more closed nutrient loop than exists on many modern farm operations. Admittedly, recreating such conditions is difficult on large farms with high animal densities and smaller farms proximate to settled areas, though perhaps still feasible in extensive rangeland scenarios.
Deadstock is regulated provincially and the rules have shifted significantly since the BSE crisis of the early 2000s. In Ontario, the Nutrient Management Act (2002) and regulations largely govern disposal of animals that die on-farm. The shift was designed to provide greater environmental protection and separation of dead from live animals. For animals that die off-farm, the regulations of the Food Quality and Safety Act (FQSA), 2001 are in effect. They are designed to ensure that deadstock does not end up in the food chain[
On-farm, there are numerous disposal options, including:
“burial, incineration, composting, disposal vessels, collection by a licensed collector, anaerobic digestion, delivery to a waste disposal site approved under the Environmental Protection Act, delivery to a disposal facility as defined under the FSQA, delivery to a licensed veterinarian for post mortem and disposal.” (Ontario deadstock regulations)
From an agroecological perspective, composting on-site is the most desirable option if there is a suitable land base for cycling the nutrients, followed by on-site anaerobic digestion if the digester collects methane and the residue can be properly distributed as nutrients. Admittedly, there are challenges for on-site composting though OMAFRA believes it is a very viable option and does provide guidance. Licensed collectors can also transport to centralized composting sites, though this is less favoured because of the transport and the challenges with redistribution of compost. They may also take deadstock to rendering facilities, though opportunities for re-using material from ruminants have declined significantly since BSE. In an emergency situation (e.g., barn fire, natural disaster), the regulations may be waived and other options approved. On-site composting has only been permitted since 1996, so it is probably not the favoured option, and if a farm does not already have a suitable composting system, the installation costs can be significant. But fees charged by firms for deadstock disposal have increased (from first paying a fee to the farmer, to free pickup, to a government subsidized fee for certain stock, to a significant fee without subsidy, see Sun Media, 2009), perhaps encouraging more on-site burial, but not necessarily composting (Crosby, 2009). Canadian renderers report a 50% decline in deadstock material picked up since the implementation of service charges (Koch, 2009), but some environmental organizations are opposed to on-site composting for fear of negative water quality impacts (Vandusen, 2010).
For animals that die off-farm, on-site composting at other locations in the supply chain is not permitted.
The FSQA regulation provides for centralized composting of deadstock. It sets out the application, siting, facility and operational standards and requirements for those centralized deadstock composting facilities. The facility and operational requirements provide for various composting and curing methods as well as for composting pads made of different materials. The regulation establishes turning, temperature and substrate standards. Compost that is derived from deadstock and that has been composted in accordance with the regulation may only be sold if it meets all of the prescribed standards for finished compost. Material that fails to meet the requirements may be re-composted or disposed of at an approved waste disposal site depending on the regulatory defect(s). The deadstock regulation specifies who may transport material, other than finished compost, from a composting facility.
The current policy approach, as with many aspects of agriculture, is to present a buffet of options from which private landowners can choose. The state does not necessarily encourage the most desirable options. From a nutrient cycling perspective, this is sub-optimal. The priorities should be on-site composting for farmers wherever feasible and centralized composting facilities for other segments of the food chain. For farmers, a big problem is assessing the hazards of composting on their farms, and then designing and paying for the right kind of composting approach. Providing extension and consulting services to design and executive an optimal strategy is paramount. Regarding centralized facilities, many regions of Canada do not have them, or enough disposal and rendering companies to support a facility or handle BSE or PED hazardous material for landfilling. The provincial governments should create funding pools for deadstock infrastructure that are analogous to the programmes that partly subsidize human waste management.
Easing transitions of the rendering industry
Given how much of an animal is not edible for humans, and the challenges of deadstock, the rendering industry plays a critical role in a food waste hierarchy. The sector has been challenged since the discovery of BSE in Canada in 2003, partly by the expense of new regulations to minimize the spread, and partly by shifts in markets. But equally significant, the sector has a major interest in high levels of animal product consumption and high animal densities, both conditions that have to shift for reasons of sustainability and health (see Goal 2, Demand - supply coordination). So, the challenge is locating an appropriate and viable place for the sector as wider shifts in consumption and production take place.
The federal government should finance a third party assessment of transition options for the rendering industry, consistent with this paper, under Growing Forward III contribution agreements.
 The MOECC states there should be a minimum of 100m between all buildings, processing and storage areas, access roads, the nearest residence, school, place of worship, hospital, and any other public institution, bodies of water. Such distances are not viable in urban areas.
 Two OMAFRA factsheets on different approaches to on-farm composting can be found at: http://www.omafra.gov.on.ca/english/engineer/facts/10-063.htm, and http://www.omafra.gov.on.ca/english/engineer/facts/09-031.htm
 Those parts of the animal deemed at risk of carrying BSE must be removed and most of that is landfilled. The volumes have increased since the enhanced feed ban went into effect in 2007 (Koch, 2009)