By Bill Prokop
Prokop Enviro Consulting
Federal, state, and local regulatory agencies have had a significant impact on the rendering industry regarding environmental issues during the past 30 years.
The initial impetus of environmental regulation began in 1971 when the U.S. Environmental Protection Agency (EPA) was formed with William Ruckelshaus as the administrator. The agency’s primary purpose was to regulate emissions and discharges to the air, water, and land that were harmful to health and the environment. In the same year, the U.S. Occupational Safety and Health Administration (OSHA) was likewise formed with Walter Guenther as the administrator. OSHA’s primary purpose was to develop standards and practices designed to protect the health and safety of workers in industrial plants.
Initially, the EPA in 1971 proposed odor regulations and stack limits for the rendering industry. The National Renderers Association (NRA) opposed these regulations on the basis that the resolution of odor complaints should be left up to the local agencies. Since then, state (provincial), regional, and municipal air pollution control authorities have promulgated and enforced various odor regulations. During the past years, NRA has been active in opposing those proposed state regulations that were considered to be particularly damaging to the rendering industry and to prevent their adoption by neighboring jurisdictions.
Environmentally, odor regulations are the most difficult to deal with because of the subjective issue, “what is an objectionable odor.” NRA, through the Fats and Proteins Research Foundation, funded a project in the 1970s to develop an odor measurement known as the Triangle, Forced-Choice, Dynamic Dilution Olfactometer. This method has been used successfully to quantify odor levels in rendering plant emissions. This method, together with proven odor control technology to treat hi-intensity process odors separate from those in the plant ventilating air, has generally been successful. However, the real proof is being able to satisfy the surrounding community. The most successful renderers have adopted a pro-active approach in dealing with their neighbors.
In 1975, the EPA proposed effluent guideline limits for the rendering industry for plants discharging to navigable streams. As a minimum wastewater treatment technology, the use of the more expensive activated sludge process for secondary treatment was required. NRA opposed these effluent guidelines and after a court review, the EPA was required to adjust upward the effluent limits to allow the use of less expensive lagoons.
Since then, individual state water pollution control agencies regulate these discharges to navigable streams by issuing National Pollutant Discharge Elimination System permits with specific effluent limits. Often, the wastewater control technology required is based upon the specific stream usage(s) and associated water quality criteria. In some cases, these water quality requirements have been overly stringent, forcing the closure of rendering plants.
Rendering plant wastewater discharges to municipal sewers usually have required compliance with an oil and grease limit. This limit is dependent upon the definition of “oil” as it applies to “animal fats,” which are more biodegradable than petroleum oil. In a few cases, the city has restricted discharges of total suspended solids (TSS), biochemical oxygen demand (BOD), and ammonia. Cities recover their treatment costs by assessing surcharges based on daily flow in gallons per day and pounds of TSS and BOD discharged.
Regarding federal OSHA, they initially promulgated a voluminous set of standards and practices that were difficult to comply with. Often, citations were issued and fines were assessed by OSHA inspectors for relatively minor infractions. Since then, OSHA has adopted a more cooperative approach with industry, with an emphasis on reducing accidents in the workplace instead of assessing fines.
Probably the most significant OSHA regulations ever promulgated have dealt with confined spaces. There are multiple categories of confined spaces in rendering plants. In the 1980s, OSHA was developing standards and practices that regulated entry into, the presence in, and exit from confined spaces. NRA had the opportunity to work with OSHA in this effort and was basically successful in reasonable regulations being adopted for confined spaces.
In the future, there seems to be little doubt that regulations affecting the rendering industry will tend to become more stringent. As water and other resources become more scarce, as perceived environmental issues such as global warming grab the public’s attention, it will be difficult to stem the tide of over-regulation. It will be even more important that renderers tell their “story” to the public and others on how their service benefits mankind and the environment.
June 2001 Render