30 WASTE MANAGEMENT – Food and Drink – Good Manufacturing Practice, 7th Edition



In the Introduction, the intention was made clear to limit this Guide to matters having a direct bearing on the scientific, technological and organisational aspects affecting the quality, legality and safety of products. For this reason, detailed consideration has not been given to the impact of the manufacturing unit and its operations on the external environment. It is, however, acknowledged here that the management of any food manufacturing operation has general responsibility and, in most countries, legal obligations (with which it must be familiar) for these aspects, including the management of waste.


30.1 EU Regulation No. 852/2004 on the hygiene of foodstuffs and Regulation No. 853/2004 laying down specific hygiene rules for food of animal origin came into force in all Member States on 1 January 2006. They are enforced by the Food Safety and Hygiene (England) Regulations 2013 in England and by similar legislations in Scotland and Wales as amended. These require that:

  1. food waste, non‐edible by‐products and other refuse are to be removed from rooms where food is present as quickly as possible to avoid their accumulation;
  2. food waste, non‐edible by‐products and other refuse are to be deposited in closeable containers, unless food business operators can demonstrate to the competent authority that other types of containers or evacuation systems used are appropriate. These containers are to be of an appropriate construction, kept in sound condition and be easy to clean and, where necessary, disinfect;
  3. adequate provision is to be made for the storage and disposal of food waste, non‐edible by‐products and other refuse. Refuse stores are to be designed and managed in such a way as to enable them to be kept clean and, where necessary, free of animals and pests; and
  4. all waste is to be eliminated in a hygienic and environmentally friendly way in accordance with the community legislation applicable to that effect, and is not to constitute a direct or indirect source of contamination.

30.2 The treatment/disposal of unwanted by‐products (waste materials) must be controlled and comply with all the appropriate environmental legislation in the country concerned (see Chapter 41). In the UK, waste disposal should meet all relevant national and EC legislation. Where necessary, waste should be removed by licensed contractors. If the waste includes trademarked materials, the waste contractor should provide records of material destruction or disposal.

30.3 The EC Directive on Packaging Waste (94/62/EC) aims to reduce the volume of packaging waste going to landfill sites by setting targets for the recovery and recycling of packaging waste. The UK legislation that implements the EC Directive is the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 as amended and 2016 amendments1 (first came into effect in 1997), which cover aspects of recycling and recovery. Guidance on current requirements and obligations can be found at https://www.gov.uk/guidance/packaging‐producer‐responsibilities.

The Packaging (Essential Requirements) Regulations 20152 (first came into effect in 2003) consolidates and revokes all earlier Regulations that relate to the essential requirements for packaging and ensuring packaging material complies with standards set for heavy metal concentration (see 24.11 for more details).

30.4 Waste management procedures should address the requirements for waste minimisation, reusing the material wherever possible, waste recycling using approved contractors and waste disposal. The frequency of emptying of waste containers should be defined, and verification activities should be undertaken to ensure that the timescales are complied with.

30.5 Where licensed contractors are required by legislation for the carriage and disposal of waste from the manufacturing site, all appropriate documentation should be maintained.

30.6 External waste areas should be maintained in an appropriate hygienic state. Internal and external waste containers should be clearly identified, for example with labels or colour coding for different types of waste, and designed and maintained so that they are fully enclosed, are effective in use and afford effective cleaning and, where required, disinfection (see Chapter 21). Consideration should also be given to effective infestation control (see Chapter 22).

Waste Minimisation Audit

30.7 Waste minimisation audits should identify ways to prevent waste being produced in the manufacturing unit. They should address the following areas as appropriate:

  • raw material use and actual versus expected yield;
  • level of non‐conforming/rejected product;
  • level of waste by‐products produced per unit of production;
  • potable water consumption and the volume of waste water produced per unit of production;
  • energy consumption per unit of production;
  • packaging usage and volume of packaging waste produced per unit of production;
  • chemical usage; and
  • sundry and consumable items.

30.8 Waste minimisation audits should be documented with actions identified, responsibility for the action defined and timescales for completion. Verification of the corrective or preventive action required should be completed (see 28.15).