The county is moving forward with its proposal to site slaughterhouses and rendering plants on agricultural land, although such facilities are already allowed in industrial zones. The council will be discussing this matter during a Special Committee of the Whole meeting on November 7, 2012, and could approve the ordinance that evening.
The proposal will allow slaughter facilities, which are defined to include “incidental edible rendering,” as a permitted use where a facility is no larger than 15,000 square feet, employs 20 or fewer employees, and processes at least 50% of agricultural products produced in Whatcom County. Larger facilities are treated as a conditional use, which requires approval from the development-friendly County Hearings Examiner. The proposal will allow slaughter and rendering facilities as a primary use, i.e., a use that is independent of a farm operation.
Previously, I posted concerns about siting slaughterhouses on farm land, but I did not address rendering facilities. Rendering involves processing dead animals into ingredients for a wide range of industrial and consumer goods, such as pet food, soaps, candles, pharmaceuticals, personal care products, and tallow and lard consumed by humans. Because rendering facilities are currently a conditional use, and this proposal will make “small” rendering facilities a permitted use, it is a deregulation.
After attending the council’s October 9, 2012 Planning Committee, I do not believe council has sufficient understanding of the rendering industry to deregulate rendering facilities. Council did not know the approximate size of a “small scale” facility, and determined it was under 15,000 square foot based on the applicant’s self-serving testimony and the size of the county’s sole slaughter facility. Ditto for the number of permitted employees. The proposed definition of rendering fails to reflect a multitude of rendering byproducts.
Although the council did not understand exactly what rendering plants did, or how they operated, they ignored objections by the Northwest Clean Air Agency regarding odor and air quality impacts. They deemed it sufficient to restrict rendering operations to edible byproducts, which produce less odor and pollution than inedible rendering byproducts. Again, they relied upon the applicant for important information.
The rendering industry recognizes two classifications of processing plants: integrated and independent. An integrated rendering plant is generally operated in conjunction with a meat packing plant, and is located on site and works in tandem with either a slaughterhouse or a poultry processing plant. Integrated rendering plants can produce both edible and inedible byproducts in the same facility, although the processes are separated.
Independent rendering plants operate separately from a slaughter facility and collect and process “4D” animals (dead, diseased, dying or disabled,) from a variety of sources such as farms, slaughterhouses, zoos, shelters, veterinary clinics, grocery stores, and road kill. Independent rendering plants only process inedible byproducts.
Because the county ordinance restricts rendering facilities to edible byproducts, (i.e, an integrated processing plant,) the rendering plant will likely be associated with a slaughterhouse. It does not appear that council understood this nuance. It is unclear if the limitations on facility size and number of employees applies to the entire integrated rendering facility/slaughterhouse, or if this permits two 15,000 square foot buildings and 40 employees per operation/site.
The county continues to ignore the environmental impacts of slaughter and rendering facilities, treating this as a matter that is magically resolved elsewhere in the permitting process. This is an important issue that needs to be understood and addressed before new regulations are enacted.
The sheer volume of waste produced by the slaughter industry is daunting. Rendering plants collect approximately 100 million pounds of dead or dying animal remains EVERY DAY. Because the county will not be rendering “inedible” byproducts, how will these remains be disposed of? State disposal methods are confusing and vary depending on the type of animal and the circumstances surrounding death, but can include burial, composting, rendering, landfill, incineration, or natural decomposition. The complexity and importance of dealing with animal disposal is reflected in a 2004 letter from the Washington State Department of Agriculture to the FDA regarding safety protocols for mad cow disease. http://www.fda.gov/OHRMS/DOCKETS/dockets/02n0273/02n-0273-c000487-vol40.pdf
For off-site disposal, considerations include increases in traffic and road infrastructure necessary for daily removal of large volumes of waste. For on-site disposal, council should review potential land and water contamination issues, infectious disease and public safety concerns, and the ability of rural septic systems to handle high volumes of slaughter industry waste.
Given the problems created by this proposal, I again urge the county council to consider the use of mobile slaughtering units as an alternative to slaughter and rendering facilities on natural resource land.