Regulations for using recycled manure solids as a cattle bedding material

Livestock manure is classified as a Category 2 animal by-product under the EU Animal By-Products (ABP) regulation (EU 1069/2009).  

These regulations do not directly permit the use of manure as bedding. However, there are provisions which permit animal by-products and derived products to be used technically, provided they do not pose an unacceptable risk to public or animal health.  

Defra, the Welsh Government and the Scottish Government permit the use of RMS for cattle bedding in accordance with prescribed conditions, as there will be no unacceptable risks to public and animal health.   

If at any point unacceptable risks emerge that cannot be sufficiently mitigated through changes in practices or management, Defra and the devolved administrations may no longer permit the use of RMS as bedding. This fail-safe is essential to ensure the good reputation of the dairy industry and consumer confidence are maintained.  

The requirements in this section must always be followed to ensure that action will not be taken against you under the Animal By-Products and Animal Welfare regulations.  

Requirements are either based on the need to mitigate risks to an acceptable level, as required under regulation, or a consensus agreement by industry stakeholders about good management practice. 

1. RMS is produced using raw cattle manure/slurry from housing and/or yards. Manure from other livestock species must not be included to avoid introducing external pathogens which may affect cattle health.
2. It is used as bedding for cattle which are in the same epidemiological unit as those cattle from which it is generated to minimise the risk of disease transfer.
   • RMS must only be produced on the unit on which it is to be used and only from slurry originating from that unit. Slurry or manure must not be moved between units either before or after separation. An epidemiological unit comprises animals which come into contact with each other directly or indirectly (e.g. shared facilities or personnel) as part of the same farm business. They may not necessarily be housed on the same site or premises
3. RMS is produced from a slurry separator unit, designed for the purpose, which produces manure solids of at least 34% dry matter. If the material is too wet (below 34%), it is unsuitable for use as bedding.
4. It is only used as bedding for housed cattle over twelve months old.
   • Regulations on calf health and welfare (Council Directive 2008/119/EC and the Welfare of Farmed Animals Regulations 2007) state that calves must have access to a lying area which is ‘clean, comfortable and adequately drained and which does not adversely affect the calves’
   • Youngstock are particularly susceptible to disease and if infected may be highly contaminating themselves. Risks of disease transmission will be minimised by preventing calves less than twelve months old from having contact with faeces and slurry from adult cattle. Any calves that are inadvertently born in areas bedded on RMS must be removed as soon as possible from the area, to a location where suitable alternative bedding is provided
5. Only use RMS on cubicle beds, either as a layer on top of mattresses or as a cubicle bed up to 15 cm in depth. It shouldn’t be used as a deep bed in pens or yards, and not in calving areas, due to the susceptibility of newborn calves to Johne’s disease or other pathogens. 
6. Milk from herds using RMS is pasteurised. Bedding materials are potential sources of contamination since microorganisms and their spores can get on to the teat from the bedding and through the milking process and end up in the milk bulk tank. Unpasteurised milk or milk products must not be consumed (this includes consumption by farmers, farmer families and farm workers).
7. There is no shared equipment for the handling and processing of feed and RMS to prevent cross-contamination of feed or forage.
8. RMS must be used within 12 hours of its production to avoid composting or anaerobic digestion of the material and significant change to its nature and microbiological composition.

1. Material that has been composted or digested must not be used in RMS. 
   • The spores of certain bacteria, particularly those that are heat-resistant, may be encouraged by composting. Too high a concentration of spores can lead to losses during the manufacture of cheese and reduce the shelf life of pasteurised milk
   • Putting manure through a digester will also increase temperatures, which can affect pathogen load. Until further information is available, use of RMS produced from the output of a digester is not permitted
   • Digestate which contains feedstock from non-farm sources could cause an additional unacceptable risk and must not be used
2. RMS must not be produced from manure/slurry of herds which are subject to official restriction for notifiable diseases, (see below for TB specific conditions). The main notifiable disease of concern is foot-and-mouth disease, as the infective agent can occur in faeces and urine up to four days before clinical signs appear.
3. RMS may only be made and used in herds that are officially tuberculosis free (OTF) for bovine TB. RMS made from manure/slurry originating during a period of non-OTF status is potentially contaminated and must not be used after OTF status is regained. 
   • Manure from TB inconclusive reactors and TB reactors must be excluded from the use of RMS, unless TB is advanced in an animal, as there are unlikely to be large numbers of organisms shed in faeces  
   • The specific risk of TB spread though manure/slurry has not been quantified. With regular testing, the chances of reaching this stage of infectivity are much reduced. However, if TB were present in slurry, it is not likely to be reduced by physical separation  
4. RMS must not be produced from slurry/manure of cattle that are undergoing treatment for disease with antibiotics or dry cow therapy.   
   • There are concerns about an increased risk of antibiotic resistance developing in manure being recycled for bedding. Every effort should be made to take the slurry to be processed for RMS from groups where no, or minimal numbers of, cows are currently being treated with antibiotics
   • You may want to consider putting a protocol in place to ensure slurry/manure from cows under treatment or withdrawal can be kept separate from the rest of the herd, e.g. using a quarantine/isolation pen. If all cattle, or a significant proportion of the herd, are being treated with antimicrobials, then their slurry/manure should not be used to produce RMS during the treatment and withdrawal period 
5. RMS must not be produced from manure/slurry produced in quarantine pens. Bought-in cattle are likely to have different faecal flora and also immune status, so they could introduce new pathogens and also be more susceptible to those endemic in the herd. 
6. Manure from aborted cattle under brucellosis investigation must be excluded from use as RMS. Rigorous biosecurity is even more important in relation to suspected brucellosis cases as it is a zoonosis.  
7. Other materials, such as birthing fluids and placental material, manure from calving areas, and waste milk, must not be added to manure/slurry going for RMS. 
   • Afterbirth and other fluid materials are a potential risk for disease transmission. Waste milk, subject to withdrawal period, must not be added to the slurry pool, as there is an increased risk of developing antibiotic resistance and increased risk for MAP. Anecdotally, inclusion of waste milk in material used for bedding has been associated with increased cell count/mastitis problems
8. RMS must not be produced from the faeces of cattle that have been brought into the herd from elsewhere, for a period of one month after their introduction.

1. The production and use of RMS must be suspended if animals on farm show clinical signs of infection or have tested positive for enteric pathogens or outbreaks of clinical disease (e.g. salmonella, VTEC, etc). 
2. Excellent pre-milking teat preparation must be conducted, which must include a pre-milking teat disinfection as it rapidly reduces the number of bacteria that are present on the skin of the teats and is associated with lower total bacterial counts in bulk milk. 
3. Thoroughly clean and disinfect separation equipment when moving between different epidemiological units. In mainland Europe, movement of contaminated equipment has been linked to transfer of pathogens from one farm to another.  
4. Farms using RMS must notify APHA and Red Tractor. In addition to the requirement to notify Red Tractor, farmers must also notify APHA if they wish to use RMS. Complete the form “Notification of registration of farmers using recycled manure solids as dairy cattle bedding” and submit to APHA either by email or by post.