Carcass Management of Non-Diseased Animals

This document is intended to help producers and facilities with non-diseased carcass management during significant public health incidents, such as pandemics. During these times, animal production and processing facilities may encounter challenges associated with certain livestock and poultry processing plant closures due to workforce and staffing issues related to an outbreak at those plants. As a result of these shutdowns, and other factors, some animal production facilities may need to depopulate by euthanizing animals. Unlike mortalities at normal rates, large-scale mortalities present challenges that are not part of the typical operation of these facilities. Operators are typically advised to have plans for emergency large-scale mortalities; for example, due to extreme weather, disease, or epidemics and pandemics.

The resulting animal carcasses will need to be managed in a manner that protects public health and the environment. The safest, most timely, environmentally responsible, and cost-effective methods available for carcass management should be used. Improper carcass management could lead to the need for environmental cleanups, as well as public concerns and the potential for future legal liability.

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Who Oversees Carcass Management?

The Animal and Plant Health Inspection Service (APHIS) of the U.S. Department of Agriculture (USDA) is the lead federal agency for responding to large-scale foreign animal disease outbreaks, including depopulation and disposal. USDA APHIS assists with disposal of non-foreign animal disease-infected or exposed animal carcasses when assigned an Emergency Support Function (ESF) #11 mission assignment by FEMA, as part of a Stafford Act emergency declaration. However, USDA APHIS does not always receive authority or funding to conduct large-scale depopulation or disposal of non-diseased animals during public health incidents. EPA recommends visiting APHIS’s FAD PReP (Foreign Animal Disease Preparedness and Response Plan) and Carcass Management Dashboard websites for more information on carcass management.

EPA provides technical assistance and support for decontamination, including the registration of disinfectant pesticides for use in decontamination, and the interpretation of waste management requirements. State environmental agencies are critical partners, as they make many of the waste management decisions, including the permitting of some waste management facilities that may be utilized for carcass management.

State and local governments make decisions about the management of carcasses and other wastes specific to that situation. To protect public health and the environment and to provide consistent information to the public, state and local agriculture and environmental agencies should closely coordinate on the development and distribution of information or guidance.

What Are Livestock Carcass Management Options for Non-Diseased Animals?

Because of the potential for a large number of animal carcasses and the resulting potential public health impacts during significant events like a pandemic, EPA recommends that facilities, producers, and growers, as well as state and local authorities, develop pre-incident waste management plans that cover the management, treatment, and disposal of the wastes that may be generated. Planning helps ensure that the parties involved have evaluated issues (including, but not limited to, health and safety, transportation, and ultimate treatment and disposal of the wastes) and potential management options. Pre-incident planning facilitates rapid response if an event occurs.

Entities who are faced with the need to treat and dispose of large quantities of non-diseased animal carcasses have multiple options. In a widespread event, multiple means of carcass management will be required, and the optimal combination of technologies chosen will be site-specific. The table below describes the advantages and disadvantages of available options. (The data in the table are adapted from US EPA, Exposure Assessment of Livestock Carcass Management Options During Natural Disasters; EPA/600/R-17/027; February 2017; and Lori Miller (USDA), “Swine Disposal Presentation” Presentation for Pork Producer Webinar, April 2020.)

Livestock Carcass Management Options for Non-Diseased Animals
Tier 1 Ranking	Management Options	Controls and Limits to Environmental Releases	Pros	Cons
Rank 1: Negligible to minimal exposure— releases regulated to levels safe for human health and the environment	Alkaline Hydrolysis	Tightly contained, using hot sodium hydroxide Significant reduction of solids volume	Relatively fast destruction of carcasses	Extremely limited capacity for mass mortality situations Not widely available Creates aqueous waste stream with very high oxygen demand – problematic for many publicly owned treatment works (POTWs)
	Incineration in a Fixed Facility	Air emissions regulated under the Clean Air Act (CAA); pollution control equipment can include scrubbers, fabric filters; residuals (i.e., ash) managed under the Resource Conservation and Recovery Act (RCRA); discharges of wastewater to waters of the United States managed under the Clean Water Act (CWA)	Tightly regulated facilities Safe Reduces volume Efficient Readily implemented	Limited local capacity depending on location, difficult to process large, whole animals, size reduction may be needed Offsite (non-hazmat) transport Limited availability Limited throughput Requires packaging
	Landfilling	Landfill design and operation regulated under RCRA, controls include leachate collection and management and methane recovery; municipal solid waste (MSW) landfill air emissions regulated under CAA, requirements include gas collection and control system installation and operation	Tightly regulated facilities, leachate control Safe Readily available High capacity Quickly and readily implemented Efficient	Potential capacity issues for animal carcasses Potential permit issues related to accepting large quantities of carcasses Offsite (non-hazmat) transport Denial of use by facilities
	Rendering	Releases to air and discharges to waters of the United States regulated under the CAA and CWA, respectively	Recycling into food product Safe Reduces volume High throughput Efficient Readily implemented Already permitted for carcass management	Limited surge capacity Offsite (non-hazmat) transport
Rank 2: Higher exposure potential— uncontained releases to the environment	Above Ground Burial	Partially controlled releases burial (minor leaching, runoff, and gas release to air); may have a low spot when carcass has decomposed	If implemented correctly, likely safe On farm Quickly and readily implemented Efficient Less impact to groundwater than below-grade conventional burial	Scavengers may unearth carcasses Need bed and capping material such as wood chips Potential public health risk Not sustainable for ongoing large volume disposal Regulatory limitations on use May limit future land use Potential future clean up liability May be amenable to carcass size reduction
	Air-curtain Burning	Air emissions regulated under the CAA, possible releases from combustion ash if managed on-site	Significantly reduced air emissions compared to Open Burning On farm Reduces volume	Requires significant quantities of solid fuel; ash management requirements Potential risk to human health Not sustainable for ongoing large volume disposal Potential for public opposition Inefficient Requires skilled operator Regulatory limitations on use
	Below Grade, Conventional Burial	Uncontrolled leaching from unlined burial; slow gas release to air	Cheapest option On farm Easy to implement	Potential for groundwater contamination from leachate May limit future land use Potential public health risk Not sustainable for ongoing large volume disposal Regulatory limitations on use Potential future clean up liability
	Composting	Partially controlled releases from compost windrow (minor leaching, runoff, and gas release to air); where finished compost is tilled into soils, potential runoff and erosion from amended soil	If implemented correctly, minimal leachate runoff, minimal odor; compost can be used as soil amendment Safe On farm Quickly and readily implemented	Requires significant quantities of carbon source (e.g., wood chips, corn stover) Significant space requirements Needs size reduction for maximum effectiveness for large animals Needs on-site supervision by certified subject matter expert for maximum effectiveness and minimal environmental impact Temporarily restricts land use Takes months to complete unless carcasses are small or safely ground first
	Open Burning (Pyres)	Uncontrolled and unregulated combustion emissions, although state and local ordinances and regulations can limit the amount and frequency of open burning that can occur; possible releases from combustion ash if managed on-site	Relatively simple logistics to implement On farm Reduces volume	Requires significant quantities of solid fuel (coal, wood) Potentially significant visible air emissions Ash management requirements Potential risk to human health Not sustainable for ongoing large volume disposal Potential for public opposition Inefficient Difficult to operate Regulatory limitations on use

What Possible Environmental Concerns Arise from Carcass Management?

Carcasses, in sufficient numbers, can present a potential environmental and public health risk. As carcasses begin to degrade, bodily fluids, chemical and biological leachate components (liquid that results from the decomposition of the biomass, which includes bodily fluids that leak from the dead animal, even if the animal carried no disease), and odor and hazardous gases (e.g., ammonia (NH₃), hydrogen sulfide (H₂S) , methane (CH₄) and other air pollutants) can be released into the environment, including into the air, surface water, and groundwater. These releases can potentially impact the health and safety of surrounding humans, livestock, and wildlife. Vectors that feed on carcasses, such as birds, flies, and mosquitos, may also cause health and safety concerns by spreading biological leachate components. The method of euthanasia (e.g., gases, such as carbon dioxide (CO₂); pharmaceuticals) may cause additional environmental impacts during and separate from carcass management, which would need to be minimized. The method of euthanasia may also affect how the carcasses can be managed.

When deciding upon a carcass management strategy, it is important to minimize the impact that carcass management can have on air and water quality. In no instance should carcasses be disposed of in a manner that results in discharges into waters of the United States that are not authorized under the CWA, nor into any waterbody or groundwater where such discharges are prohibited under state law. Entities should consider potential environmental issues associated with each management option, such as the release of particulate air pollution from incineration or the potential contamination of surface water and groundwater from unlined burial or composting. The carcass management options table above summarizes which methods are effective at reducing air emissions and discharges to surface water and groundwater as a result of treating and disposing of animal carcasses. For more information, please see EPA’s and USDA’s Agricultural Air Quality Conservation Measures: Reference Guide for Poultry and Livestock Production Systems, which outlines best practices for reducing air emissions from a variety of activities at livestock facilities, including carcass management, and Section 5.4 of EPA’s NPDES Permit Writers' Manual for Concentrated Animal Feeding Operations (AFOs), which discusses carcass management options that producers may wish to implement and various environmental considerations associated with each.

EPA recommends the long-term monitoring of releases from such management options to ensure the proper protection of human health and the environment. Because incident and site-specific decisions about carcass management are made at the state and local level, and since each state has its own statutes and authorities on animal disposal, it is important to consult with appropriate state environmental regulatory agencies about permits for potential sites before initiating operations.

Where Are Facilities That Can Help with Carcass Management?

EPA’s Disaster Debris Recovery Tool (DDRT) is an interactive dataset that maps recyclers and landfills for the planning, response, and recovery of wastes, including animal carcasses. This tool provides information and locations of over 20,000 facilities capable of managing different materials which may be found in disaster debris. The tool was created in EPA Region 5 in 2010 and has expanded to include data for all 50 states, Puerto Rico and US Virgin Islands. This tool can assist entities with carcass management by finding landfills and compost facilities. To access the DDRT, visit https://www.epa.gov/large-scale-residential-demolition/disaster-debris-recovery-tool. EPA’s I-WASTE tool (https://iwaste.epa.gov/) also has facility databases for landfills, incinerators, and rendering facilities, however, the landfill data in the DDRT are more up-to-date.