The ABP Regs are, on first impression, are a neccesary framework for the disposal of waste and the prevention of animal diseases. However, the way in which they have been interpreted and implemented are good example of 'gold plating', analogous to the way in which health and safety has become the by word for ridiculous, over cautious regs.

The ABP regs as they are applied to retail outlets has incurred massive cost for no benefit whatsoever. The idea that a piece of raw meat becomes worthy of a regulation over and above that already covered by all the other waste regulations just because it has not been sold, defies common sense. This is further compounded by the equally illogical alternative outcome, that if the piece of meat is purchased and subsequently disposed of by a householder  (or indeed a ;catering establishment), regardless of how rotten, maggot infested or disease ridden, no special conditions are applied.

It also serves to discourage investment in processing plants (COMPOSTING/GASIFICATION ETC) as a large amount of potential feedstock is not segregated and is being landfilled.

If the purpose of such 'overkill' is to reduce waste, then structure regulations that encourage this. There is no need to pretend that there is a huge risk of disease to justify a reduction in waste. All businesses should endeavour to reduce waste, from purely commercial considerations but spending millions of pounds to establish separate storage, carriage and disposal routes just diverts money from other opportunites for investment that may actually achieve some real benefits. It also discourages disposers of waste of tackling the real issue of waste.

When, as a representative over one of the UK's largest retailers, I had meetings about whether smoked salmon was cooked or raw, or received government guidance on the disposal of honey, it was clear how ridiculous and wasteful these regulations had become.

In summary – exclude retailers from ABPR, whilst encouraging alternative disposal.

Why is this idea important?

It would financially benefit industry and would free up money to invest in alternative solutions that could have a real impact at local level. 

It would also remove the false differentiation of wastes just because they are produced by various classes of  producers. Its a cosmetic difference which causes the waste industry, both operationally and in terms of perception to be fractured into local authority / private suppliers rather than allowing a more efficient, 'holistic' future industry to develop.

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