Memorandum by The Federation of British
Cremation Authorities and The Cremation Society of Great Britain
ENVIRONMENTAL PROTECTION ACT 1990 CURRENT
REVIEW OF SECRETARY OF STATE'S GUIDANCE NOTESCREMATORIA
As you may know, the Environmental Protection
Act 1990 was responsible for the introduction of a new and much
needed integrated pollution control regime. The cremation process,
which involves an emission to air, has specified performance standards
defined in Guidelines issued by the Secretary of State. Results
of continuous flue gas monitoring and annual sampling of emissions
provide the local Environmental Health Officer and indeed the
general public with the confidence that the current standards
of operation are being met in each establishment.
The new standards introduced in the first Guidelines
in 1992 required that all British crematoria renew or replace
their equipment by 1 April 1998. This was achieved, despite the
need in many cases to carry out extensive building works, within
the defined time scale. The total cost of this refurbishment programme
across the industry was between £125 million and £150
million. It should be noted that the vast majority of British
crematoria (85 per cent) are owned and operated by local authoritiesso,
much of the huge expense has been borne by local taxpayers.
The latest four yearly review of the Guidance
Notes, currently being undertaken by the DETR Air Quality Division,
has indicated that crematoria may now be required to undergo further
major industry changes involving the introduction of flue gas
cleaning equipment. This, in part, is in response to an initiative
from a few European countries for a "reduction in background
emissions of mercury".
However, despite repeated requests for information,
the DETR has not produced any evidence that mercury is being emitted
in any significant quantitycertainly not enough to justify
a massive refurbishment programme. Indeed, research undertaken
at a Midlands crematorium over a prolonged period indicates that
the level of mercury in the ambient air was even below the limit
of scientific detection.
It is clear from our extensive survey among
cremation authorities that the introduction of this new equipment
Impose a further substantial burden
on cremation authorities (estimated at a further £150 million).
Result in the closure of 23 per cent
of the 242 crematoria in Britain.
Herald fundamental changes to the
cremation service in Britain.
Virtually all cremation authorities have indicted
that they have insufficient space to accommodate the new equipment
and 25 per cent are unable to extend their buildings for this
purpose. Closure of a local crematorium will certainly result
in inconvenience and distress to grieving families in this the
most sensitive of public services. The estimated capital costs
involved are likely to produce an increase in cremation fees of
between £70 and £100 per funeral.
In the absence of adequate factual evidence
or information, the Federation of British Cremation Authorities
and The Cremation Society of Great Britain have commissioned an
urgent major research programme to investigate all the issues
relating to emissions, including mercury, their presence and effect
on air quality. The research will also consider the ability of
crematoria to maintain their service if abatement plant was proved
to be necessary. The DETR has been advised of this initiative
in anticipation that the new Guidance Notes, to be issued shortly,
will permit the comprehensive investigation to be concluded and
made public before any potentially damaging social changes can
be imposed upon the British people.
We have taken this opportunity to write to you
and your parliamentary colleagues to advise you of the relevant
circumstances and request your active support in avoiding the
possibility of unjustified crematorium closures with the public
outrage that this may engender.