Environmental Planning Regulations 16 128 Appendix 1 Land Based Discharge of Mortuary Wastewater Feasibility Report

Appendix 1
Separation and land

based treatment of
mortuary and funeral
home fluid wastes
Prepared for the Gisborne District

Council
November 2015
Nga Mahi Te Taiao

Contents
Section Page
Executive summary 3
Discussion and recommendations 5
Background 7
Relevance to iwi Maori o Turanganui a Kiwa
Commentary 8
Tangata whenua and the Gisborne Turanganui wastewater project 10
Proposed separation and treatment system for mortuary and funeral home fluid
wastes: process description
On site separation 11
Collection, transport, and delivery to treatment station 12
Septic tank 13
Other potential contaminants 15
Separation of leach field leachate from ground and surface water 15
Septage 17
Example of proposed in-situ tank system and leach field 19
Guidelines and statutory context
Background 21
HSNO Act 1996 21
Proposed Regional Freshwater Plan, the Regional Plan for Discharges to
Land, Water, Waste Management and Hazardous substances, RMA1991 21
Managing Health and Safety Risks in New Zealand Mortuaries: Guidelines
to Promote Safe Working Conditions 27
Gisborne Trade Waste Bylaw 2015 28
NZ Standard: Management of Healthcare Waste NZS4304:2002 (some
relevant excerpts) 29
Guidelines for On-site Wastewater Management GDC 2015 32
References and bibliography 35
Figures
1 Determination of holding and treatment tank/s and leach field capacity
and design 14
2 Typical septic tank and raised leach field (GDC, 2012) 18
3 Buffer/holding tank 18
4 Typical soakage bed profile (GDC, 2012) 19
5 Elevated Wisconsin Mound in construction (GDC, 2012) 19
1
6 Funeral home and mortuary holding tanks 19
7 Discharge holding tank and leach field venue 20
8 Standard leach field being lain (GDC, 2015) 20
9 Wisconsin Mound design for sloping site (Iowa Department of Natural
Resources) 20
Table
1 Plants for Soakage Areas (Guidelines, GDC 2012) 33
2 Some other NZ approaches to managing mortuary and funeral home
liquid wastes 34
This report was prepared by Murray Palmer of Nga Mahi Te Taiao. Valuable input was
also received from Sarah Pohatu, Gordon Jackman, Robson Timbs, David Wilson, Bruce
Duncan and AmyRose Hardy.
79 Paraone Rd Gisborne
Te Turanganui a Kiwa
Phone 068687133
Email murray@nmtt.co.nz
Web www.nmtt.co.nz
2
Separation and land based treatment of mortuary and funeral home fluid wastes
Executive summary
A key component in the development of a sustainable, cost effective and
environmentally and culturally acceptable wastewater management program for the
Gisborne Turanganui a Kiwa district involves the development of a land based
treatment system, with beneficial reuse of the treated effluent. In order for such
reuse options to be acceptable, wastewater derived from mortuary and funeral
home activities will need to be treated and discharged separately from that of the
main sewerage treatment system.
Research indicates that the main biological and chemical contaminants of the typical
wastewater stream from funeral homes can be successfully treated in a standard
septic tank and leach field system such that they would pose little, if any, threat to
people or the environment when sited on appropriate soils and at a sufficient
distance from watercourses. In order to establish an effective separate treatment
process for these wastewaters, a decentralised system utilising a holding and
discharge for transport tank will be sited at each mortuary or funeral home. The
wastewater will then be removed at appropriate intervals for complete septic tank
treatment at a GDC facility situated at the Taruheru Cemetery, prior to ultimate
discharge via sub-surface irrigation to an adjacent elevated Wisconsin Mound leach
field.
The relevant local authority plans and guidelines include the Hazardous Substances
and New Organisms Act 2008, the Health Act 1956, the Human Tissues Act 2008, the
Resource Management Act 1991, the Proposed Gisborne Freshwater Plan, the
policies and objectives of the Regional Discharges Plan, the Gisborne Trade Waste
Bylaw (GDC 2015), the Guidelines for Onsite Wastewater Management (GDC 2012),
the New Zealand Standard NZS4303:2002 ‘Management of Healthcare Waste’ and
‘Managing health and Safety risks in New Zealand mortuaries: Guidelines to promote
safe working conditions 2000’.
Given the strong tangata whenua concerns around the treatment and disposal of
wastewaters associated with death, it is recommended that these wastewaters
should be classified as Controlled wastes (NZS4303:2002). That is:
Healthcare waste that is recognisable as coming from a healthcare facility
(see Appendix A for examples), which:
a) May be contaminated or soiled with potentially infectious human or
animal body fluids which shall not be expressible under compaction;
or
b) Is not infectious but may be considered culturally or aesthetically
offensive.
Although the NZS4304 identify the disposal of bodily and embalming fluids to the
municipal sewer system as an accepted discharge point, the classification as
Controlled Wastes should trigger a change to the Trade Waste Bylaw 2015. That is,
wastewater from funeral homes would become a Conditional discharge, rather than
3
a Permitted one. This would bring such wastewater into the same category as the
discharges from mortuaries, and better reflect the level of tangata whenua concern
for the correct management of such wastes.
Generally, the proposed decentralised treatment and discharge system for
mortuaries and funeral homes in the Tairawhiti Gisborne region, as it involves the
treatment and discharge of wastes at a property other than where these originated
from and is of material classified as trade waste, will be a Discretionary Activity
requiring resource consent. The separation and on site storage of the wastewaters
from mortuaries and funeral homes prior to collection for transport to the treatment
and discharge site should be, however, a Permitted Activity and no resource consent
will be required if the relevant conditions are met.
The proposed in-situ treatment of mortuary and funeral home wastewaters and
their discharge to land will provide for the acceptable reuse of Gisborne Turanganui
a Kiwa treated wastewater. This factor, and the removal of these materials from the
current discharge directly into to Te Moana o Turanganui a Kiwa (the Bay), will
provide for the relationship of tangata whenua and their culture and traditions with
their ancestral lands, water, sites, waahi tapu, and other taonga (RMA1991 s6e).
Similarly, it will support the exercise of kaitiakitanga (s7a), and give effect to the
principles of Te Tiriti o Waitangi (s8). The proposed separation and discharge also
aligns with the Purpose of the RMA1991, the standards of NZS4303:2002, and the
requirement of the 2009 wastewater resource consent to improve the mauri and
water quality of Turanganui a Kiwa (Clauses 18 and 19).
Available research indicates the effectiveness of on-site septic wastewater systems
in treating the biological and chemical contaminants in mortuary and funeral home
wastewaters, although none currently derives from a NZ situation. Further
information relating to these, the leach field discharge systems, and the ongoing
combined system effectiveness, will provide valuable information around the use of
such systems in both national and international contexts. Thus the establishment of
a robust monitoring program to assess the characteristics of the wastewaters, and
the efficiency of the proposed system in treating the entrained contaminants,
comprises a recommendation of this report.
4
Discussion and recommendations

Epidemic, disaster and emergency situations
The potential for markedly increased volumes of mortuary and funeral home
wastewaters during periods of major disaster (earthquakes, tsunami, flooding),
epidemic, or other emergency states (e.g. serious multi-vehicle accidents) has been
considered, and it is evident that current public health practice contains systems to
address these (pers. Comm. Dr Bruce Duncan).
Treatment and discharge system design and operational management

Appropriate design and management of the treatment system and leach field will be
vital to ensure the ongoing success of the separation of mortuary and funeral home
materials from the main sewer flow. This is a typical consideration for all on-site
systems. Such considerations include:
 What are the anticipated usual and maximum (high death rate periods apart
from emergency situations) wastewater flow volumes to be managed?
 Will two on-site tanks be necessary to produce an effluent quality similar to
that reported on by LaKind and Bouwer (2003) i.e. initial embalming waste
treatment in one tank, followed by mixing and retention in a second septic
tank? Or will this outcome be achieved by combining a 24hr minimum
retention period in the proposed on site holding tank at the funeral home or
mortuary, prior to discharge into the septic system at the cemetery
treatment site?
 Whether dose loading of the septic (or similar) system with suitable
acclimated biodegrading microorganisms and appropriate feedstock (i.e.
organic material) will also be necessary to emulate the type of effluent
produced by the two tank mixed system described by LaKInd and Bouwer
2003.
 Is there is any evidence of other potential chemical contaminants in the
mortuary or funeral home wastewaters, and if so, are these within NZ4304
levels?
 Will there be any changes required to treatment management should
significantly reduced levels of embalming occur?
 Attention to tank and leach field temperature.
 Leach field soil porosity and potential effects of the development of microbial
clogging (microbial slime).
 Migration of wastewaters from the leach field.
5
Communication with hospitals and funeral homes

While wastewater flow volumes and contaminant characteristics derived from
mortuaries and funeral homes is available from United States sources, there is a lack
of published information relating to these in Aotearoa NZ. Communication will need
to be established and maintained with hospital and funeral home personnel in order
to ascertain this information, and determine any monitoring programs or
management changes that may be necessary should there be significant variations
between the USA and NZ wastewaters.
Guidelines.
In collaboration with the Public Health Unit, tangata whenua, local hospitals and
funeral directors, GDC will produce a set of guidelines for the management, storage,
transportation, treatment and discharge of mortuary and funeral home waste
waters (body fluids, wash water, and cleaning and embalming agents). These
guidelines will be made available to those involved in this work, including
contractors utilised to transport the stored liquid materials from mortuaries and
funeral homes for septic tank treatment and discharge at the Taruheru Cemetery.
Monitoring
The use of septic tanks for wastewater treatment is common world-wide, and a
considerable body of information is available about their efficacy in treating
domestic sanitary wastes. Although existing research is positive, there is limited
information relating to the wide range of organisms and other materials possibly
present in mortuary and funeral home wastewaters. For this reason, and to ensure
contamination of soil and water in the vicinity of the leach-field will not occur over
an extended time frame, a monitoring program should be established sampling for
indicators of potentially harmful components in the waste stream. Modelling of
‘worst case’ conditions for the presence of such materials (e.g. at low temperatures
and short retention times) may provide a focussed context for such monitoring. The
outcomes of this work could be of significant value nationally, should other regions
adopt in-situ treatment and land-based discharge (e.g. to address cultural concerns)
and internationally, adding to the global body of information relating to
decentralised treatment of mortuary and potentially infectious wastes.
6
Background
In December 1964, an outfall pipe was installed transporting Gisborne City’s
untreated wastewater 1800 metres out into the coastal embayment, Te Moana o
Turanganui a Kiwa (Te Moana, the Bay). Apart from the introduction of a milli‐
screening plant in 1990, this system of wastewater disposal, despite being the
subject of significant debate and challenge, was to continue for 45 years until early
January 2011.
In June 2009, consents were finally granted for the development of a new
wastewater treatment plant for Gisborne city’s municipal sewage. A major driver for
the new system was to provide for tangata whenua and the wider community’s
values and interests in the coastal environment of the Bay. The independent
commissioners hearing the consent applications by Gisborne District Council (GDC)
made clear:
The effects on tangata whenua from the existing wastewater arrangements
at Gisborne and the upgrade proposals has been a paramount consideration.
It has been made very clear at all times, and over many years now, that the
continued discharge of untreated wastewater to the waters of Poverty Bay
violates Maori tikanga and is a major effect on the cultural and spiritual
sensitivities of tangata whenua. A key component of the on‐going action to
implement an improved wastewater treatment scheme is the input from
tangata whenua, in partnership with the other interested parties (Watson et
al, 2009, p27).
While a biological trickling filter (BTF) wastewater treatment plant has been
established as an initial treatment process, the view of Turanganui a Kiwa tangata
whenua and others is that the continuing ocean discharge remains culturally
offensive and of potential health and environmental concern, including that
mortuary and funeral process waste products (bodily and embalming fluids)
continue to be disposed of via the sewage system into the Bay.
A further system involving a series of constructed wetlands providing secondary and
tertiary treatment for the city’s municipal effluent is planned to be established by
2020. This aims to ensure that the post-BTF effluent will be of a standard suitable for
land-based beneficial reuse options (irrigation, non-potable industrial use,
biodiversity wetland development). Turanganui a Kiwa tangata whenua have made it
evident that the presence in such treated wastewater of the highly tapu mortuary
and funeral wastes will mitigate against the opportunity for beneficial reuse options
(FILENOTE: Removal of mortuary waste from the Wastewater system, GDC 2015,
Appendix 1).
.
7
The Wastewater Technical Advisory Group (WTAG) and Wastewater Management

Committee1 accepts the tangata whenua position as regards the management of
critically sensitive materials such as mortuary and funeral wastes. WTAG thus
considers the development of an alternative treatment and management system for
these materials to be a necessary requirement for the establishment of the land
based, wetland treatment system, and for any potential reuse of the treated
wastewater. WTAG also believes that the ongoing relationships that have been
developed across community sectors will assist with addressing these matters, while
acknowledging that this will also involve a solid evidence, policy, and regulatory
framework to be successful and meet the needs of all concerned (pers comm Sarah
Pohatu, GDC). This report comprises an outline of a proposed separation and
treatment system for these mortuary and funeral related liquid wastes, the statutory
and planning context, an assessment of the socio-cultural, economic and
environmental effects anticipated, and recommendations relating to the
implementation of the proposal.
Relevance to Iwi Maori o Te Turanganui a Kiwa

Commentary
In Aotearoa New Zealand, tangata whenua are recognised as Treaty of Waitangi
partners with the Crown as represented by the NZ Government, in the nation’s
founding document, Te Tiriti o Waitangi, and throughout NZ legislation. The
relationship of Maori and their culture and traditions with their ancestral lands,
water, sites, waahi tapu, and other taonga is considered a matter of national
importance (RMA1991 s6e) and the perspectives of the tangata whenua in relation
to the management of these is a further matter to be considered (RMA1991 s7a).
In particular, genuine participation in decision-making regarding infrastructure such
as water supply, stormwater and wastewater has been identified as an area that is of
critical importance to tangata whenua cultural, social, and economic wellbeing. Such
participation is also recognised as being relevant to the overall sustainability of
infrastructure development in these and other areas of environmental management
(Morgan, 2012). Nevertheless, problems frequently stem from the juxtaposed
paradigms of municipal engineering on one hand and the tangata whenua values and
beliefs on the other. Those promoting continued water-based transport, treatment,
and disposal of human effluent frequently do so from an industrial paradigm of
relative ease of system design and receiving environment capacity. However, water
and water bodies such as rivers, lakes, wetlands and the coastal environment have
their own mauri which is important for tangata whenua to protect from pollution,
degradation and damage. Such waterbodies are also key elements in the identity,
1
A standing committee of GDC comprised of four councillors and four tangata whenua representatives, tasked
with governance of the wastewater project.
8
whakapapa and mana of the relevant whanau, hapu and iwi, and considered great
treasures, taonga tuku iho, by them.
Mauri has been described as the binding force, an invisible but felt energy uniting
the tinana (physical being) and wairua (spiritual being) (Royal et al, 1995). It is a
particular characteristic found in all animate and inanimate nature, although the
state of mauri can vary, being stronger, weaker, or totally exhausted, depending on
the circumstances impacting upon it at that time. It is this variation in the state of
mauri that is observed and assessed from the indigenous viewpoint, the impact upon
the mauri being the measure used to determine the relative sustainability of various
options when choices are to be made (Morgan, 2012).
Several commentators have informed a local Turanganui a Kiwa tangata whenua
perspective on water and waste management:
Maori waste management was organised so that waste associated with
specific activities was handled and disposed of through a complex set of
rules. Separate disposal mechanisms and methods were required for each
article of waste. Waste from bodily material was managed separately from
the waste associated with customary food preparation, eating places and
human ablutions . . . Maori perceive the mixing of water as abhorrent
physically, culturally and spiritually. The level of effluent is irrelevant.
Scientifically the water may be ‘fine’ but it still remains abhorrent (Awatere
et al, 2000, p15).
Underpinning this, the traditional tangata whenua viewpoint associates water and its
management with the creation traditions of Maori. In addition, the environmental
management regimes established in the traditional protocols of tapu (sacred) and
noa (profane) ensure that the requirements of particular water status can be
observed effectively. Thus, the basic ‘traditional’ premise is that water, having been
used for whatever purpose, should be returned to Papatuanuku if the mauri of that
water is not suitable for ongoing use. Papatuanuku is recognised as the mother who
provides life for all living things through the waters in her womb. From her, life is
derived. To her, wastes which are devoid of life, have to be returned. The life giving
essence, water, must remain pure and unadulterated to provide life for those to
follow.
The disposal of body products into the waterways either from tupapaku
(people that have passed away), general public ablutions and hospitals was
found to be repugnant to all the interviewees. Body parts and body products
are considered extremely tapu. These were usually returned to the earth. ‘I
don’t know of any hapu or iwi who have had human waste that went into the
waterways. The waterways are like your veins; it is like infecting your veins.’
(ibid, p26)
While recycling is a concept recognised by the tangata whenua, the integrity of the
mauri of recycled water greatly influences how it can be used. Further, recycling
most of these waters in a culturally consistent manner can only be achieved by
returning the water to the ground or onto land. This aspect of such an analysis
9
should always be carried out by the tangata whenua. The range of connections,
considerations, interests, rights and responsibilities that impact on the mauri of the
environment, of the community, of the hapu, and of the whanau, will thus be
relevant in any assessment of the sustainability of a current or proposed activity.
It has been suggested that in a development context, that what is needed is a way of
placing the juxtaposed paradigms of conventional municipal engineering and the
tangata whenua on a level playing field, allowing identification of the issues that are
most contentious but also, and more importantly, identifying the issues upon which
the two paradigms are in agreement (Morgan, 2012). Such common ground is
sought as the basis for a positive relationship between the local authority and the
tangata whenua and reflects a major objective of the Gisborne Turanganui a Kiwa
wastewater management project, including the separation of mortuary and funeral
home wastes from the main wastewater treatment process and reuse options, while
satisfactorily managing the treatment of these wastes through an effective land
based system.
TROTAK, Ngati Oneone, Te Whanau a Kai, Ngariki Kaiputahi, and the Gisborne
Turanganui wastewater treatment project
The land that surrounds Te Moana o Turanganui a Kiwa (the Bay) is the
turangawaewae for the people of Ngai Tamanuhiri, Rongowhakaata, Te Whanau a
Kai, Ngariki Kaiputahi, Te Aitanga a Mahaaki, and Ngati Oneone. Te Runanga o
Turanganui a Kiwa (TROTAK) is the tribal runanga incorporating Ngai Tamanuhiri,
Rongowhakaata and Te Aitanga a Mahaaki iwi. As well as providing four of the eight
members of the Wastewater Management Committee (WMC), TROTAK and other
iwi and hapu representatives have been participants in the WTAG processes from
the group’s inception in 2010. Spokespersons for TROTAK and the other iwi and hapu
groups, have made it abundantly clear, and at several forums, that the discharge of
sewage to Te Moana is of great offence to the people of Te Turanganui a Kiwa, and
that land based treatment and discharge is necessary to support their cultural values
and restore the mana of the waters and the people.
For iwi Maori, death is the primary tapu state, embodying the demise of mauri and,
as observed through the process of tangihanga, has been described as the ultimate
form of Māori cultural expression (Nikora et al, 2010). Similarly, death in a specific
area will incur the imposition of rahui, a prohibition against the use of such places
for everyday activities such as food gathering and recreation. In such a context, the
discharge of wastes associated with death, including mortuary and funeral home
waste waters, is viewed as highly tapu, and seen as impacting on Te Moana o
Turanganui a Kiwa in both physical and spiritual ways. Inclusion of these materials in
land-based treatment and reuse options for the treated effluent, however, is
considered similarly unacceptable, and would place any persons utilising these
wastes (for irrigation or biodiversity enhancement, for instance) at physical and
spiritual risk (pers comm Ray Farmer). TROTAK and Ngati Oneone spokespersons
10
have also indicated that the separation of these wastes from the main effluent flow
and their subsequent ‘through land’ treatment apart from the main treatment
system, would provide an acceptable means of management, and would
simultaneously assist with the restoration of the waters of Te Moana for food
gathering and other cultural purposes (Appendix 1).
Proposed separation and treatment system for mortuary and funeral

home waste products: process description
On site separation
Currently, the waste products that derive from the treatment and embalmment of
deceased can be largely classified into two groups: the natural bodily fluids removed
during the processes of dissection and/or in preparation for embalmment, and any
materials such as pharmaceuticals entrained in these; and the associated washing
waters used, and embalming and associated treatment fluids.
It is anticipated that these materials will be combined at the mortuary or funeral
home and then discharged to on-site holding and loading tanks at these facilities,
where the wastes will be stored for a short period, prior to removal and ultimate
discharge to a septic tank system and dispersal leach field located on Gisborne
District Council property at the Taruheru cemetery. Currently, these materials are
treated as standard sanitary waste disposal products and discharged directly to the
sewage treatment system as either Permitted (funeral homes) or Conditional
(mortuary) Trade Waste. Research indicates the efficiency of septic (anaerobic)
systems in satisfactorily treating these materials, and it is considered that a standard
domestic septic tank system or similar will be sufficient to adequately treat these
wastes, prior to further treatment and discharge through a land-based aerobic leach
field (GDC 2015, GDC 2012, LaKind and Bouwer, 2003)5.
Management of these wastes to the point of collection remains the responsibility of
hospital staff or funeral directors, and will reflect the training and expertise of these
groups. Funeral services operate under a Code of Industry Conduct and the Funeral
Service Training Trust (FSTT) is the Industry Training Organisation (ITO) responsible
for:
 Developing industry training programmes
 Setting up national skill standards to be registered on the National
Qualifications Framework
 Arranging for the delivery of training (on and off the job)
5 Other non-reticulated systems (aerobic, double tank, etc) may also be considered. The mixing of microbial
and anti-microbial wastewater in the on-site holding tank is also anticipated to provide a level of pre-
treatment for both components where these materials are retained for 24 hours or longer (LaKind and
Bouwer, 2003).
11
 Developing arrangements for monitoring the training and assessment of

trainees (on and off the job).
Currently, the Wellington Institute of Technology (WelTech) is the national provider
of funeral service training in New Zealand, supplying the funeral industry with
fundamental theory and technical training in embalming and funeral directing. To
participate in the programmes available, for the National Diploma in Funeral
Directing (Level 5) a potential student must be at least 20 years of age, and have 12
months relevant funeral directing experience. For the National Diploma in
Embalming (Level 5) a potential student must be at least 20 years of age, with 12
months relevant embalming industry experience (WelTech, 2015).
Detailed guidelines for the management of health and safety and environmental
wellbeing in mortuaries are contained in ‘Managing health and safety risks in New
Zealand mortuaries: Guidelines to promote safe working conditions’ (OSH, 2000) and
the ‘New Zealand Standard: management of healthcare waste’ (NZ4304:2002).
Collection, transport, and delivery to treatment station

The handling of bodily fluids after death and any associated embalming waste
products have been identified as potential sources of risk for those handling these
materials, and for those who may be exposed to the products prior to treatment and
disposal. Further, specific cultural practices and requirements may determine the
ways in which such materials should be handled (NZS4304:2002; Human Tissue Act,
2008). The purpose of the The Human Tissue Act 2008 is to ensure that the
collection or use of human tissue:
(a) occurs only with proper recognition of, and respect for,—
(i) the autonomy and dignity of the individual whose tissue is, before
or after his or her death, collected or used; and
(ii) the cultural and spiritual needs, values, and beliefs of the
immediate family of that individual; and
(iii) the cultural, ethical, and spiritual implications of the collection or
use of human tissue; and
(iv) the public good associated with collection or use of human tissue
(whether for health practitioner education, the investigation of
offences, research, transplantation or other therapeutic purposes, or
for other lawful purposes); and
(b) does not endanger the health and safety of members of the public; and
(c) generally does not involve the requirement or acceptance, or the offering
or provision, of financial or other consideration for the tissue.
(Part 1, s3, Purpose)
It is anticipated that the waste liquids from the mortuaries and funeral homes will be
gathered from these venues and discharged at the appropriate discharge site via a
system of sealed connecting valves, and transported via a dedicated tank. Detailed
requirements for such handling and transportation are contained in NZS4304:2002
12
and outlined in Appendix 7. A training program will be developed with any GDC staff
or contractors engaged in transporting and delivering these wastes for treatment,
similar to that currently given to employees engaged in handling sewage waste
products, and may include precautionary safety measures such as vaccinations.
Septic tank
A septic tank acts as a settling chamber to separate the suspended solids from the
liquid in a wastewater stream, and to provide an opportunity for biodegradation and
mineralisation of the organic matter and contaminants6. Such biodegradation largely
occurs through the activity of anaerobic microorganisms. Depending on the
retention time, temperature, nature of the influent, and the microbial communities
within the tank, septic tanks provide an efficient method for the primary treatment
of domestic wastewater: domestic septic tanks typically removing greater than half
of all contaminants in raw wastewater (WERF, 2006). Septic tanks are, however, also
widely used for the treatment of waste from funeral services. In the USA, for
instance, approximately 22% of funeral parlours have septic tanks and their
associated leach fields as the sole source of wastewater treatment (Killiam
Associates, 1995).
The organic components of the waste stream from mortuaries and funeral facilities
will include blood and body fluids. The United States Centres for Disease Control and
Prevention (CDC) has determined that wastewater containing blood may be safely
discharged to septic tanks and that conventional on-site wastewater treatment will
satisfactorily inactivate blood-borne pathogens (Centres for Disease Control and
Prevention www.cdc.gov/ncidod/hip/enviro/envquidedraft-pdf 2002). The CDC
identify several factors that enhance the inactivation of blood borne pathogens in
wastewater disposal and treatment. These include dilution of the discharged
materials with water and inactivation due to exposure to the cleaning chemicals,
disinfectants, and other chemicals in the wastewater as a whole. According to the
United States National Funeral Directors Association (USNFDA), the standard
practice when an embalming is performed is to delay discharge of the wastewater
until bodily fluids have commingled with the embalming solution. This means that,
as embalming proceeds, but prior to discharge to the sewer or septic tank system,
the preservative and disinfecting compounds become thoroughly mixed with the
bodily fluids, effectively killing off the live microbial contents. Guideline levels for the
safe inactivation of potentially infectious bodily fluids have been developed by the
US Medical Wastes Guide 2014, and are provided as Appendix 6.
6
As in the earlier footnote, the use of a septic (anaerobic) system is described, however subsequent to
accurate definition of waste composition and volumes, other in-situ treatments may be preferred (GDC, 2012).
13
Formaldehyde and phenol are the two primary chemical constituents in embalming:
virtually all embalming products containing formaldehyde as a preservative and,
while phenol is used for this purpose, it is also widely used as a disinfectant and
antiseptic and for a further range of purposes commonly used at funeral homes,
including general cleaning (Killiam Associates, 1995, LaKind and Bouwer, 2003). A
further large group of chemical products is available to funeral directors today to
assure that an embalming produces desired results. These include arterial fluids and
cavity fluids, co-injection fluids, non-arterial preservative, supplementary products,
cosmetics, cleansers (sealants, antiseptics, disinfectants, deodorizers), and other
miscellaneous products (tissue builders, feature builders, and the like) (Killiam
Associates, 1995).
In terms of adverse environmental effects in such a context, the performance of the
septic tank and leach field system in biodegrading the antimicrobial components
derived from the disinfection and embalming process becomes critical. In 2003, Dr
J.S. Lakind and Dr E.J. Bouwer produced the Septic Study: Investigation of the
Removal of Formaldehyde and Phenol by Funeral Home Septic Systems for the
National Funeral Directors Association. This work included a literature review of
monitoring and research data relating to the treatment of mortuary and funeral
home wastes by a range of treatment systems, in order to create a model of
anticipated effects achieved by treating such wastes in a conventional septic tank
and leach-field system. The authors concluded that:
The model designed for this investigation, the Funeral Home Septic
Biodegradation7 Model, demonstrates that septic systems located at
funeral homes throughout the United States are capable of complete
removal of formaldehyde and phenol from wastewater discharges to septic
systems. In some instances, complete removal of the formaldehyde and
phenol will take place in the septic tank before the wastewater reaches the
leach field. However, for the formaldehyde and phenol that is not
biodegraded in the septic tank and is released to the leach field, the leach
field is capable of essentially complete removal of the remaining
formaldehyde and phenol from the wastewater. The model indicates that
optimal conditions for complete biodegradation of formaldehyde and
phenol in the septic system include warmer temperatures, more rapid
biodegradation rates, and longer residence times (LaKind and Bouwer, 2003,
pxii).
This model was then tested against the targeted monitoring of a functioning septic
system. The results of this monitoring program allowed the authors to conclude:
7 Biodegradation is the breakdown of chemicals by microorganisms. Biodegradation rates for Formaldehyde

and Phenol are as follows. Values selected for formaldehyde: half-lives between 0.25 and 2.0 days in the septic
tank and half-lives between 0.14 and 1.39 days in the leach field. Values selected for phenol: half-lives
between 0.5 and 2.5 days in the septic tank and half-lives between 0.14 and 1.39 days in the leach field. (A
half-life is the time needed for one-half of the compound to biodegrade.) La Kind and Bouwer, 2003.
14
Thus, the funeral home field study indicated low level concentration of
formaldehyde8 and no presence of phenol in the leach field. These results
demonstrate that septic systems can be effective at removing formaldehyde
and phenol from funeral home wastewater. For the conditions during the
sampling events (e-g., warm temperature, likely long leach field residence
time), the model predicts that any formaldehyde and phenol remaining in the
septic tank prior to discharge to the leach field can be effectively treated in
the leach field. Consequently, the field study results are consistent with the
model results. (LaKind and Bouwer, 2003, p24)
It should be noted that in this case, however, the liquid wastes from the funeral
home embalming process entered a separate chamber prior to being mixed with
sanitary wastes from the funeral home residence in the main septic tank.
The septic system at the funeral home has two septic tanks, a holding tank
(also referred to as a dosing tank, used to help equalize the flow to the leach
bed) and a leach bed. The first tank, 1,000 gal in size, receives only
embalming wastewater. The second tank, 1,500-gal in size, receives
embalming flow from the first tank and sanitary waste, with sanitary waste
comprising the majority of the flow from the funeral home and the residence
located on the premises. Discharges from the second tank flow into the
dosing tank. The dosing tank contains a sewage lift pump. Wastewater from
the dosing tank is periodically pumped to a 26 ft x 46 ft sand-lined gravel
leach bed (ibid, p19).
Other potential contaminants

The primary constituents of mortuary and funeral wastes have been determined as
bodily fluids deriving from the deceased, washing water used to cleanse the body,
and embalming or preservative agents used to lengthen the time between death and
burial or cremation. Other potential contaminants to be assessed are:
 Materials used to further facilitate the embalming process and enhance the
appearance of the deceased (Killiam Associates, 1995)
 Pharmaceuticals and environmental pollutants present entrained in the
bodily fluids of the deceased (pers. Comm. Gordon Jackman, WTAG).
Further information relating to likely levels and anticipated effects of these materials
will be available when work is completed by researchers undertaking an assessment
of pharmaceuticals and emerging contaminants in Gisborne Turanganui a Kiwa
domestic wastewater stream (Northcott, Jackman, et al).
8
The levels detected in the field sampling were below what typical laboratory analytical processes are able to
detect, and were at the levels modelled as an environmental contaminant for the pads used to gather the
effluent samples (LaKind and Bouwer, 2003).
15
Separation of leach-field leachate from ground and surface water

A key environmental concern relating to the in situ treatment and to-land discharge
of mortuary and funeral home wastewater is the potential for contamination of
ground or surface waters due to the migration of partially-treated effluent via the
leach field. Depending on final site selection, the proposed GDC leach-field site will
be approximately 270 metres from the nearest surface watercourse, the Taruheru
River, and is estimated to be one to three metres (depending on rainfall recharge
conditions) above the closest ground water source, the Te Hapara Sands Aquifer9.
Soils here are deep and free-draining (Sandy Brown Waiki_15) with very low
vulnerability to waterlogging (Landcare Research, Appendix 2 below).
Dr. LaKind and Dr. Bouwer determined that the extent of biodegradation of
formaldehyde and phenol in a septic system tank and the leach field is based upon
three key parameters: 1) detention time, which controls the time available for
microorganisms to biodegrade the organic material; 2) the biodegradation rate
constant, which determines the speed at which the microorganisms decompose the
organic material; and 3) temperature, which directly influences the biodegradation
rate constant.
Overall, for non-residential buildings, the USEPA (2002) recommends that tank
volume be 2-3 times the design flow and have recommended a minimum 24-hour
detention time in the tank for maximum solids accumulation. A review of the
literature describing septic system designs and pilot studies also indicates that the
minimum detention time in a septic tank should be one day, and that a standard
septic tank is likely to have an effective detention time between 1.5 and 2 days,
while the detention time for low wastewater flows and large tank sizes being likely
to range from 3 to 5 days. It is, however, the overall efficacy of the whole septic
system (the septic tank plus leach field) that is of interest, because these two
components operate together to treat the wastewater. The research to date
indicates that there is little likelihood of either microbial contaminants from bodily
fluids, or any formaldehyde and phenol embalming agents that might remain after
septic tank treatment, migrating beyond the leach-field boundaries (LaKind and
Mouwer, 2003).
9
Derived from closest bore log on the corner of Nelson and Cameron Roads, approximately 450 metres from
the proposed leach field.
16
Figure 1 Determination of holding and treatment tank/s and leach field capacity
and design
 Hospital/funeral home waste

flow details  Tank/s size and
 Retention time requirements dimensions
and high death rate capacity  Dosing rates
 Industry/engineering evaluation  Leach field dimensions
for disinfection and and retention time
biodegradation to occur 
In order to mitigate against any adverse environmental effects, a precautionary

approach should be adopted in the required capacity for the on-site holding tanks,
the septic treatment tank/s, dosing tank, and the construction of the leach field. The
average annual death rate is approximately 400 for the Gisborne Te Tairawhiti region
(pers. Comm. Dr Bruce Duncan, Tairawhiti Public Health Unit; Sarah Pohatu, GDC).
Thus, for a funeral home treating an estimated daily maximum of three deceased,
each providing approximately 454 litres of combined bodily fluids, wash-down water,
and embalming materials (Killiam Associates, 1995), a single on-site holding tank
coupled with a collection tank would need to have a combined capacity of
approximately 2700 litres, in order to ensure sufficient capacity should six deceased
occur over a two day period10.
Similarly, the capacity of the leach field, based on a maximum daily flow rate of 2700
litres and depending on the percolation characteristics of the final discharge
substrates and soils, would need to be within the range of 48sq.m. (gravel and sand)
and 540sq.m. (silts). Soils at the proposed discharge site are well drained, with a
rapid permeability even at the slowest soil horizon of >72mm/hr. Such permeability
would indicate the need for a relatively small leach field.
Septage
The term ‘septage’ refers to the solids remaining after the settling of septic tank
wastes, and is usually required to be removed from the tank on average every 2 to 3
years for normally operating domestic systems. Due to the very low amounts of solid
materials anticipated to enter the proposed mortuary and funeral home treatment
system, removal of these is expected to be infrequent and of small volumes. Details
of the situation and scale of the proposed septage discharge site are to be
determined.
10This figure is based on the 454 litre liquid waste/person assumption from US data. It is uncertain at present
whether this is correct for Te Tairawhiti.
17
Figure 2 Typical septic tank and raised leach field (GDC, 2012)
Figure 3 Buffer/holding tank
18
Figure 4 Typical soakage bed profile (GDC, 2012)
Figure 5 Elevated Wisconsin Mound in construction (GDC, 2012)
Example of proposed in-situ tank system and leach field

Figure 6 Funeral home and mortuary holding tanks
Inlet for mortuary

and funeral home
wastewater Outlet to truck for removal
to discharge and leach field
venue.
Lower outlet sealed
19
Figure 7 Discharge holding tank and leach field venue
Discharge point from truck

transporting mortuary and funeral
wastewater.
Figure 8 Standard leach field being lain (GDC, 2015)
Figure 9 Wisconsin Mound design for sloping site (Iowa Department of Natural
Resources)
20
Guidelines and statutory contexts

Background
The management, treatment, and discharge of mortuary and funeral home wastes
are controlled through a series of national and regional statutes, standards, plans,
guidelines, and by-laws. Those relating specifically to mortuary and funeral home
waste waters are identified below, and any relevant directives described. There
appears no overall specific or unilateral directive for the management of such wastes
in New Zealand, including the use of alternatives to the current discharges via sewer
mains for treatment and disposal.
HSNO Act 1996

The purpose of The HSNO Act is to ‘protect the environment, and the health and
safety of people and communities, by preventing or managing the adverse effects of
hazardous substances and new organisms.’ In the context of the Act, ‘hazardous
substance’ means: any substance ‘unless expressly provided otherwise by
regulations,
(a) with 1 or more of the following intrinsic properties:
(i) explosiveness:
(ii) flammability:
(iii) a capacity to oxidise:
(iv) corrosiveness:
(v) toxicity (including chronic toxicity):
(vi) ecotoxicity, with or without bioaccumulation; or
(b) which on contact with air or water (other than air or water where the
temperature or pressure has been artificially increased or decreased)
generates a substance with any 1 or more of the properties specified in
paragraph (a)’. (HSNO, 2008. Section 2, ‘Interpretation’).
The RMA1991, however, includes under the definition of hazardous wastes those
that are radioactive or environmentally damaging. Generally, mortuary and funeral
home wastes are not considered hazardous wastes, although when combined with
other chemicals may become so. Practitioners involved with the handling of these
wastes are alerted to this synergistic possibility as a component of their training, and
the combining of such materials is required to be avoided.
Proposed Regional Freshwater Plan, the Regional Plan for Discharges to Land,
Water, Waste Management and Hazardous Substances, and the RMA1991
Currently, the rules of the Regional Discharges Plan have been superseded by the
rules of the Proposed Freshwater Plan. However, the policies and objectives under
both the Discharges Plan and the Freshwater Plan are relevant to the proposed
activity (Appendix 4).
21
As the discharge of treated wastewater from mortuaries and funeral homes in the
Gisborne Tairawhiti district is not specifically referred to in the proposed Freshwater
Plan, Rules 5.1.14 and 5.6.14 will apply. That is:
Rule 5.1.14 (Discretionary Activity): The point source discharge of all liquids to
land or waterbodies and their margins where the discharge is:
a. Not provided for in another rule in this plan;
b. Not to Outstanding Waterbodies and Regionally
Significant Wetlands identified in Schedules 3 and 4;
c. Not a direct discharge to a waterbody or to land in a
way that directly enters water above a community
drinking water supply intake point;
d. Will not result in a water quality limit being exceeded.
Rule 5.6.14 (Discretionary Activity): The discharge of septage to land from a

property or properties where the septage did not originate.
If a proposed septic treatment tanks are to be sited in an areas where sewer
connections are available, as for instance if a treatment tank was installed at the
Gisborne Hospital or a funeral home within the reticulated city environment, or if
the alternative discharge venue at the Cemetery was in a reticulated area, then Rule
5.6.24 is relevant:
Rule 5.6.24 (Non-complying Activity): The discharge of wastewater from an
individual on-site wastewater system to land where a sewer network is
available (except greywater systems provided for in Rule 5.6.4).
Particular restrictions for Non-complying activities are outlined in RMA1991 s104D.
That is (despite any decision made for the purpose of section 95A(2)(a) in relation to
adverse effects) a consent authority may grant a resource consent for a non-
complying activity only if it is satisfied that either—(a) the adverse effects of the
activity on the environment (other than any effect to which section 104(3)(a)(ii)
applies) will be minor; or (b) the application is for an activity that will not be contrary
to the objectives and policies of—(i) the relevant plan, if there is a plan but no
proposed plan in respect of the activity; or (ii) the relevant proposed plan, if there is
a proposed plan but no relevant plan in respect of the activity; or (iii) both the
relevant plan and the relevant proposed plan, if there is both a plan and a proposed
plan in respect of the activity.
To avoid doubt, section 104(2) applies to the determination of an application for a
non-complying activity. That is, ‘When forming an opinion for the purposes of
subsection (1)(a), a consent authority may disregard an adverse effect of the activity
on the environment if a national environmental standard or the plan permits an
activity with that effect.’
The Discharges Plan provides an Explanation/Intent for a similar Rule in that Plan,
namely that it allows the Gisborne District Council to assess the environmental
effects of discharging sewage effluent from on-site sewage treatment systems in
areas serviced by a sewer network:
22
Properties that are serviced by a sewer network are typically small in size and
there is less likely to be adequate space to treat and dispose of wastewater
on-site. Reticulation is also the preferred option to avoid adverse effects
environmental and health and safety effects, particularly where there are
higher concentrations of the population living in close proximity (Discharges
Plan).
It is thus evident that the non-complying status of on-site wastewater discharge for
the reticulated Gisborne district has been aimed at minimising adverse effects in
built-up residential areas. The proposed use of a septic tank and leach field for
mortuary and funeral home wastes will occur on GDC owned land at the Taruheru
cemetery, in a peri-urban setting that is distanced from neighbouring properties.
Based on the available research, the discharge is anticipated to meet the test of
having only minor, if any, adverse effects on the environment (LaKind and Bouwer,
2003). Similarly, the discharge is consistent with the objectives and policies of the
Regional Discharges Plan (Appendix 4 below) and those of the Proposed Freshwater
Plan (outlined below).
If, however, the tank based at the hospital or urban funeral home site is primarily to
be used for storage of the wastewaters, then the Rule 5.6.9 will apply.
Rule 5.6.9 (Permitted Activity): The discharge of untreated or disinfected
wastewater to permanently established holding tanks for off-site disposal to
an authorised discharge point where:
a. The discharge originates from:
i. A permanently established building or public sanitary facility
connected to the holding tank which is on the same property or land
as the building or sanitary facility; or
ii. Campervans and mobile homes with foul water tanks.
b. The holding tank(s) are permanently established in or on the ground;
c. The discharge is human sewage and contains no other hazardous
substances;
d. The building or activity serviced by a holding tank(s) is used intermittently
and for short duration;
e. The holding tank is emptied at a frequency that avoids nuisance and
adverse environmental effects;
f. The land containing the holding tank is not likely to be subject to
inundation, slippage, subsidence or erosion;
g. The holding tank is not likely to induce inundation, slippage, subsidence or
erosion.
Conditions for the activity to be Permitted are:
a. The discharge originates from:
i. A permanently established building or public sanitary facility
connected to the holding tank which is on the same property or land
as the building or sanitary facility; or
ii. Campervans and mobile homes with foul water tanks; or
iii. Individual portable camping toilets;
23
iv. A temporary ablution building on the same property as the holding

tank; or
v. Temporary portable toilets on the same property as the holding
tank.
b. The discharge is human sewage and contains no other hazardous
substances;
c. The building or activity serviced by holding tanks(s) is used intermittently
and for short duration;
d. Any new holding tank:
i. Is permanently established in or on the ground;
ii. The tank is emptied at a frequency that avoids nuisance and
adverse environmental effects;
iii. The land containing the holding tank is not likely to be subject to
slippage, subsidence, erosion or inundation;
iv. The holding tank is not likely to induce slippage, subsidence,
erosion or inundation.
While the holding tank will contain primarily blood and other bodily fluids and
embalming agents, as distinct from ordinary human sewage, these materials are not
considered hazardous, and are currently disposed of via the reticulated Gisborne
sewerage system as ordinary sanitary wastes, either as a Permitted (funeral homes)
or Conditional (mortuaries) trade waste activities (GDC Trade Waste Bylaw 2015).
Relevant Objectives, Policies and Methods of the proposed Freshwater Plan include:
Policy 5.1.5
Encourage discharges to land or constructed wetlands prior to discharging to
water where:
a. Liquid wastes have high levels of organic waste or other
contaminants that are likely to be toxic to aquatic organisms; or
b. Where the effects of the discharge are either uncertain or likely to
result in the water quality limits for the receiving waterbody to be
exceeded. Provided that the discharge should not result in
contaminated sites being created or the contamination of
groundwater.
Policy 5.1.8
When considering applications to discharge contaminants directly to land or
water, assessment criteria are:
a. The total contaminant load of the discharge [composition/flow
rate] and how the water quality will be maintained within the limits
for the waterbody;
b. The proposed treatment methods and the likelihood of this being
the Best Practicable Option for the contaminants;
c. The need to provide for a high standard of pre-discharge treatment
for Scheduled waterbodies and where water quality limits for a
waterbody have been exceeded or are likely to be exceeded;
24
d. The actual or potential impact on any values of scheduled

waterbodies;
e. The assimilative capacity and an allowance for reasonable mixing in
the waterbody;
f. The need to safeguard the life-supporting capacity of the
waterbody;
g. The potential for bio-accumulative or synergistic effects;
h. The actual or potential risk to human and animal health from the
discharge;
i. The measures to reduce the quantity of contaminants to be
discharged;
j. The mauri of the receiving waterbody and any other values placed
on the site by tangata whenua;
k. The need to avoid exacerbation of flooding risk;
l. The need to avoid erosion of the banks or bed or land instability at
or downstream of the discharge point.
Policy 5.6.1
Manage the design, construction and maintenance of on-site wastewater
treatment and land application systems so that they are appropriate to the
site activities, system location, environmental characteristics and limitations
of the site. This includes:
a. Ensuring the inspection, cleaning, regular maintenance and
required upgrading and repair; and
b. Encouraging the use of effluent outlet filters and extensions on
existing systems.
Policy 5.6.3
To encourage the use of innovative solutions for wastewater treatment and
disposal where these have been assessed as meeting required environmental
standards.
Rule 5.6.1
Except where explicitly stated in a Rule, discharge activities must comply with
the following General Rules in addition to any relevant specific Rules in the
Plan:
9. The discharge shall be applied into land within the legal boundaries
of the property where the discharge originates from.
Method 5.1.3
The Council will continue to work with tangata whenua over waste disposal
options and give particular consideration to any relevant iwi management
plans or statements of tangata whenua views.
The proposed management of these wastes, including in-situ treatment and storage,
and their ultimate discharge (via elevated leach-field) is an important component of
the overall Gisborne wastewater management strategy which aims to improve the
25
water quality and mauri of the waters of Turanganui a Kiwa (Gisborne District)
(Clauses 18 and 19, Watson et al, 2009). In this context, the proposal can be
understood as giving direct effect to the Purpose of the RMA1991, that is:
1) The purpose of this Act is to promote the sustainable management of
natural and physical resources.
(2) In this Act, sustainable management means managing the use,
development, and protection of natural and physical resources in a way, or at
a rate, which enables people and communities to provide for their social,
economic, and cultural well-being and for their health and safety while—
(a) sustaining the potential of natural and physical resources
(excluding minerals) to meet the reasonably foreseeable needs of
future generations; and
(b) safeguarding the life-supporting capacity of air, water, soil, and
ecosystems; and
(c) avoiding, remedying, or mitigating any adverse effects of activities
on the environment.
Further, by removing a discharge of contaminants to the Bay that is of deep cultural
concern for tangata whenua of the area, the proposal directly provides for RMA1991
s6(e) ‘the relationship of Maori and their culture and traditions with their ancestral
lands, water, sites, waahi tapu, and other taonga’, and enables their role as kaitiaki
(RMA1991 s7(a)). Overall, the Gisborne Turanganui a Kiwa wastewater management
strategy including the separation and land based treatment of mortuary and funeral
home waste water takes into account, and indeed gives effect to, the principles of Te
Tiriti o Waitangi (RMA1991 s8).
26
Managing health and safety risks in New Zealand mortuaries. Guidelines to

promote safe working conditions.
Alongside detailed guidance for managing health and safety working conditions in
mortuaries, the Guidelines also provide recommendations relating to environmental
discharges. Overall, discharges from mortuaries are governed by the Resource
Management Act 1991. Discharges of contaminants or water into sewers are
covered by section 15(1), which only allows discharges if they comply with a
regulation, a rule or a resource consent. Similarly, discharges of contaminants to air
is covered by section 15(2), which ensures that any discharges comply with the
regional (or proposed regional) plan. However, in this part most mortuaries will be
allowed to continue under the ‘grandparenting’ provision of section 20A(2).
Mortuaries must comply with regional council or unitary authority rules concerning
environmental discharges, i.e:
a) There must be no visible discharge of any contaminant beyond the
boundary of the subject property .....
b) The discharge must not result in objectionable or offensive odour or
particulates beyond the boundary ....
c) There must be no harmful concentrations of contaminants beyond the
boundary of the subject property or into water.
Mortuary facilities must also comply with territorial authority requirements. The
Guidelines do, however, also recommend that all mortuaries should work gradually
towards the controlled disposal of waste material in an environmentally safe
manner. Two engineering options suggested to achieve this are:
1. Storage and treatment in a holding tank prior to pumping out and ultimate
disposal. Sumps and storage/treatment tanks need to be designed so that
treatment chemicals can be added automatically and maintenance
throughout the life of the facility does not pose risks to maintenance
workers.
2. Storage into absorbent waste in containers that can be removed and
disposed of off-site in an environmentally acceptable manner. Such
containers must not pose a health and safety risk to waste control staff.
The current proposal by GDC for separation of mortuary and funeral home waste
from the main sewerage flow, stored briefly, and then treated via a septic tank and
through-land leach field system, should be seen as an environmentally and culturally
acceptable method of managing these liquid wastes. Safety for transport and
maintenance workers will also be an important part of the system design (Ministry of
Transport, 2008).
27
Gisborne Trade Waste Bylaw 2015

Currently, the Gisborne Trade Waste Bylaw 2015 identifies Funeral Parlour
discharges as a Permitted Trade Waste, although Mortuary wastes are deemed
Conditional Trade Wastes. A Permitted Trade Waste Discharge may require that
GDC’s prior written consent be obtained before discharge to the sewer system
commences or continues, while for a Conditional Trade Waste Consent prior written
consent must be obtained from GDC. No consent will be granted for a Prohibited
Trade Waste Discharge. For both Permitted and Conditional consents, GDC may carry
out monitoring of the discharge and audit the consent conditions and/or
management plans (GDC, 2015; Appendix 5 below). Currently, GDC does not monitor
the discharges from the Gisborne Hospital mortuary or from the funeral parlours.
The proposed new management system for the treatment and discharge of
mortuary and funeral home wastes represents a notable departure from the current
direct discharge of these liquid materials to the main sewer. The goal of the new
system is to provide for community concerns and specifically Turanganui a Kiwa
tangata whenua cultural values. These values relate to the tapu nature of such
materials, whose discharge into the food gathering area of Te Moana o Turanganui a
Kiwa (the Bay) has been anathema to the tangata whenua and others for many
years, and which requires their removal from the planned new sewage treatment
system prior to reuse or recycling of the treated wastewater.
Clause 3.9.1 of the Trade Waste Bylaw sets out the process for changing a Permitted
trade waste discharge consent, including changing the trade waste management
procedures by amendment of the conditions provided for in Clause 3.8 (‘Any trade
waste consent to discharge may be granted subject to such conditions that the
Council may impose ..’), Conditions of Trade Waste Consent (Clause 3.9.1 (iv)).
Similarly, Clause 3.9.3 provides reasons for the review of conditions for a
(Conditional) trade waste consent. These are:
(a) The level of compliance with the conditions of the consent,
including any a cc idents including spills or process mish ap s.
(b) Considerations relating to the Council’s resource consents for the
sewerage system.
(c) Considerations relating to the Council’s environmental policies
and the intended objectives and outcomes.
(d) New control and treatment technologies and processes that are
implemented by the Council.
(e) Any of the consid erations outlined in clause 3.7 [Consideration
Criteria].
(f) Considerations relating to the Council’s legal obligations that
affect the conditions of a trade waste discharge consent.
The conditions for review both for Permitted and Conditional trade waste discharges
can thus be seen to provide for the proposed changes to the treatment and
discharge of mortuary and funeral home wastewaters.
28
NZ Standard: Management of Healthcare Waste NZS4303:2002 (some relevant

excerpts)
Risk Management:
The organisation or individual generating healthcare waste (particularly hazardous
components) is responsible for ensuring the safe management of such waste
through to final disposal. Each generating organisation should therefore have a
waste management policy that encompasses the objectives in this Standard. The
policy should be discussed with the local authority, who has responsibility to liaise
with local communities regarding waste disposal processes.
Waste Minimisation:
A fundamental principle of any waste management strategy is minimising waste
generation. This has important long-term benefits both to public health and the
environment…
Longer-term strategies for waste minimisation will require a review of healthcare
practices and purchasing policies. This will include life cycle analysis of products used
in clinical practice, such as switching to more environmentally friendly
technologies/products, consideration/implementation of reuse/reusables, recycling
and other waste minimisation techniques.
Objectives:
The objectives of this Standard are to protect people, property and the environment,
by:
a) Identifying and correctly categorising waste generated from human and
animal healthcare services to ensure safe and proper waste segregation from
source to disposal;
b) Facilitating compliance with regulatory requirements and best practice in the
management of healthcare waste; and
c) Minimising waste generation and the environmental impact of healthcare
waste generation, treatment and disposal; while
d) Ensuring appropriate consultation with Maori under Treaty of Waitangi
commitments.
Definitions:
CONTROLLED WASTE. Healthcare waste that is recognisable as coming from a
healthcare facility (see Appendix A for examples), which:
a) May be contaminated or soiled with potentially infectious human or animal
body fluids which shall not be expressible under compaction; or
b) Is not infectious but may be considered culturally or aesthetically offensive.
29
4 WASTE GENERATORS’ RESPONSIBILITIES

4.1 General
The waste generator shall be responsible for ensuring the safe management of
healthcare waste from generation disposal. This responsibility shall be on-going.
NOTE – Where a waste generator also transports or disposes of waste, the
responsibilities outlined in sections 5 and 6 also apply.
……
4.2 Generators’ responsibilities
To meet the objectives of this Standard the generators shall:
……
Develop, implement and review a waste management policy (see 4.3);
Where applicable, pre-treat waste (see section 7 and table 2);
Verify that transport and disposal contractors comply with contractual
responsibilities, relevant legislation and/or Standards (see section 9);
Establish a waste tracking system (see 4.9);
Maintain an emergency waste management plan (see section 9);
……
4.3.5 Consultation
Consult with local authority, transporter and waste landfill operator to ensure all
relevant requirements are considered.
……
4.3.8 Treaty of Waitangi commitments
The waste management policy shall take into account that some iwi and hapu
resource management plans include statements of concern regarding the
pollution of water, water bodies and other taonga, and policies for their
protection from contamination. Hazardous waste issues are fundamental to
the kaitiakitanga responsibility to protect and nurture the physical well being
and mauri of resources and places.
……
4.3.15.2
Waste audits should involve activities such as:
a) Carrying out waste analysis (refer section 4.10);
b) Reviewing waste records and documentation to ensure they are complete
and accurate;
c) Reviewing records of incidents, accidents and complaints related to waste
management;
d) Comparing waste records with transporters and disposal operators;
e) Assessing transport operators and disposal facilities;
f) Monitoring temperature and time records where these are required for
certain waste types;
g) Observing waste management practices (e.g. waste segregation at
generation points);
h) Use of questionnaires/surveys; and
i) Interviewing staff/transport operators/disposal agents.
……
30
6 TRANSPORTERS’ RESPONSIBILITIES
6.2 Vehicle requirements
6.2.1 General
Vehicles should be dedicated specifically for the transportation of waste. They
should also be constructed in such a manner to physically separate the driver’s
compartment from the waste compartment by a permanent and sealed barrier.
The dangerous Goods Rule has provisions allowing for the transport of small volumes
of dangerous goods.
NOTE – This would allow for the transport, by healthcare professionals, of small
volumes of home healthcare waste requiring special disposal.
……
7 WASTE TREATMENT AND DISPOSAL
7.1 General
The purpose of waste treatment is to reduce the risk of the waste and to enable it to
be disposed of as general or lower-risk category waste.
7.2 Responsibilities
To meet the objectives of this Standard, agencies/organisations responsible for
waste treatment and disposal shall:
a) Comply with regional and local authority requirements including regional and
district plans;
b) Comply with the conditions of any consent they hold under the Resource
Management Act;
c) Implement controls to protect workers and the public from hazardous
emissions from pre-treatment, treatment and disposal facilities;
d) Establish a healthcare waste tracking system (see 4.9);
e) Maintain an emergency waste management plan (see section 9);
f) Store waste in accordance with section 8; and
g) Ensure appropriate staff training is implemented (see section 10).
Each regional and local authority has plans specific to their area for
controlling the treatment and disposal of waste – including healthcare waste.
The treatment and disposal of hazardous and controlled waste shall meet the
requirements of the relevant legislation.
7.3 Pre-treatment of hazardous waste
In some cases, it may be practicable to pre-treat hazardous or controlled wastes to
allow re-categorisation as a lower risk or non-hazardous waste category.
Pre-treatment may result in the emissions of odours, volatile gases, volatile heavy
metals, and contaminated condensates. It may be necessary to consult the relevant
regulatory authority on these aspects.
7.9 Disposal to sewer
Before liquid residues are classified as suitable for disposal to sewer, the
requirements of the relevant local authority shall be met (e.g. trade-waste bylaws).
……
31
Guidelines for On-site Wastewater Management (GDC 2012)

Section 4.4.4 of the Guidelines, ‘Prohibited discharges’, sets out those discharges
(including ‘Trade waste’ and ‘Commercial disinfectant or deodorant or sewage mixed
with the same, or any antiseptic or germicide powder or fluid, unless specifically
stated to be suitable for use in a septic tank or treatment system’) that are not
permitted into an on-site wastewater system, unless ‘approved through design for
which building and resource consent has been granted’. Thus GDC, in implementing
the proposed separation of these wastewaters from the municipal sewerage and
treatment process, will need to gain specific building and resource consent.
Section 4.4.4 Prohibited discharges
Trade waste
Unless otherwise approved through design for which building and resource
consent has been granted, the following discharges into an on-site
wastewater system are not permitted:
o Stormwater, including roof and rainwater tank overflow, and surface
drainage waters
o Back-flush waters from a swimming pool or spa pool or water
softener unit
o Discharge or back-flush from a spa bath in excess of 120 litres capacity
o Disposable napkin, clothing or similar materials
o Animal carcass or offal
o Animal effluent or kennel/cattery washdown flows
o Trade waste
o Wastewater from a commercial bakery, food production kitchen, or
food processing facility
o Petrol or other flammable or explosive substance whether solid, liquid
or gaseous.
o Commercial disinfectant or deodorant or sewage mixed with the
same, or any antiseptic or germicide powder or fluid, unless
specifically stated to be suitable for use in a septic tank or treatment
system
o Commercial laundry flows
o Commercial or industrial waste flows other than flows generated from
facilities serving employees, residents, students, or guests.
(Guidelines, pp28-29)
Traditional septic tank systems are considered to provide Primary
wastewater treatment, and the Guidelines require that Conservative Design
Loading Rates must always be used for primary-treated blackwater effluent
and discharge beds. Trenches and leach field beds can be installed shallow
and mounded in well-draining soils where insufficient groundwater clearance
may otherwise impede installation, as long as the distribution zone into the
trench or bed is below natural ground level. However, for Wisconsin Mound
systems this may not be necessary where the requirements of AS/NZ
Standard 1547:2000 can be met. The minimum depth of unsaturated soil
32
below irrigation through which the wastewater must be able to infiltrate is

400mm and, for category 1 and 2 soils, and the Design Report must
demonstrate clearance to groundwater is at least 600 millimetres or will not
result in any adverse effects. Further, the type of planting must be specified,
and must have high evapo-transpiration properties. Lists of appropriate and
unsuitable taxa are included in Table 1 below.
Table 1: Plants for Soakage Areas (Guidelines, GDC 2012)

Suitable plants Unsuitable Plants
Astelias Large trees
Ground ferns (e.g. Blechnum, Pine trees
kiokio) Gum trees
Carex grasses Poplars
Toetoe (but not pampas) Willows
Sedges Macrocarpa
Tree ferns e.g. wheki Palm Trees –particularly Phoenix
Rengarenga lily and Date Palms
Fuchsia Oaks (especially Swamp Oak and
Rhododendrons Silky Oak)
Flax Wisteria
Begonias Bougainvilleas
Azaleas Hollies
Geraniums Privets
Most native shrubs but especially Bamboo
Fivefinger, Kaka beak and Poroporo Figs and Rubber Plants
Kikuyu and paspalum lawns Elms
Karaka
Pohutakawa
33
Table 2: Some other NZ approaches to managing mortuary and funeral home liquid wastes
AUTHORITY METHODS FOR MANAGEMENT OF TRADE WASTES TO SEWERAGE SYSTEMS LINK

New Plymouth Trade Waste Bylaw: mortuaries may need permit. http://www.newplymouthnz.com/CouncilAt
District Council Decision based on quality, volume, flow rate and also impact on health and safety, capacity of oZ/TradeWaste/
(Trade Waste wastewater system, nature of the activity and potential reactions with other components in
Bylaw) the wastewater stream.
Rotorua District The premises11 are classified under the Trade Waste Bylaw as either Acceptable, Conditional http://www.rdc.govt.nz/our-
Council (Trade or Prohibitive. services/pollutioncontrol/Documents/The-
Waste Bylaw) The characteristic of concern for mortuaries (and health practices, hospitals, rest homes) are: Trade-Waste-Bylaw-Brochure.pdf
wash water, chemicals, grease and fats, toxic constituents/heavy metals and medical wastes.
Taupo District Mortuaries (also doctor’s surgeries, hairdressers, laundries) with discharges <5cu.m./day are https://www.taupodc.govt.nz/our-
Council (Trade Controlled Trade Wastes (i.e. trade waste complying with the classification of trade waste in council/policies-plans-and-
Waste Bylaw 2010) Clause 3.1.2 of this Bylaw and complying with the standards set out in Schedule 512). bylaws/bylaws/Documents/Trade-Waste-
Bylaw-2010.pdf
Western Bay of Trade wastes are either Permitted, Conditional or Prohibited. Schedule 1A sets out the http://www.westernbay.govt.nz/our-
Plenty District Permitted Discharge Characteristics, and Schedule 1B those that are Prohibited. If a mortuary council/policies-plans-
Council (Trade meets the S1A conditions then it will be Permitted, and not require resource consent. bylaws/Documents/Trade%20Wastes%20Byl
Waste Bylaw 2008) aw%202008.pdf
Auckland City Funeral parlour wastewater is a Deemed13 trade waste (i.e. a person may discharge Deemed https://www.watercare.co.nz/SiteCollection
trade waste into the public wastewater system without a transitional consent or trade waste Documents/AllPDFs/PDFs%20v2%20111010/
agreement) with no special requirements for discharge to the sewer. Hospitals and Auckland%20Trade%20Waste%20Bylaw%20
mortuaries, however, are Conditional trade waste discharges and will require a transitional 2013%20-%20Official%20Copy.pdf
consent or trade waste agreement. A Prohibited trade waste may not be introduced or
discharged into the public sewer system.
11
Rather than the type of activity per se.
12
Appendix 8 below.
13
Deemed trade waste means any trade waste discharged into the public wastewater system as a
result of an activity listed in schedule 1 and which:
(a) meets the requirements listed in schedule 1 and the controlled substances standards; and
(b) is not conditional trade waste and does not have any of the prohibited characteristics listed in schedule 3.
34
References and bibliography

Cash, M. and Taurima, W. 1999. Tumatanui. The experience of a group of Maori funeral
directors (A bicultural research project). The Open Polytechnic of New Zealand
Monographs in Maori Business: Breaking the Boundaries No1.
Centers for Disease Control and Prevention, Healthcare Infection Control Practices
Advisory Committee. 2002. Draft Guideline for Environmental Infection Control in
Healthcare Facilities. www.cdc.gov/ncidod/hip/enviro/envquidedraft-pdf
D’Amato, V. A. Septic Tank Design, Function and Performance. Prospectus Drive, Suite F
Durham, NC 27713.
D’Amato, V. A., Bahe, A., Bounds, T., Comstock, B., Konsler, T., Liehr, S. K., Long, S. C.,
Ratanaphruks, K., Rock, C. A., Sherman, K. (2008). Factors Affecting the Performance of
Primary Treatment in Decentralised Wastewater Systems. Water Environment Research
Foundation, United States of America. ISBN: 1-84339-781-1
Department of Building and Housing. (2011). Compliance Document for New Zealand
Building Code, Clause G14, Industrial Liquid Waste – Second edition. Wellington, New
Zealand.
Department of Labour. Occupational Safety and Health Services. 2000. Managing health
and safety risks in New Zealand mortuaries. Guidelines to promote safe working
conditions. Occupational Safety and Health Information Series.
Environmental Protection Agency (EPA). Underground Injection Control: Permit
Application. OMB No. 2040-0042. Form 7520-6 (Rev. 12-11).
Gisborne District Council. (2010). Your Septic System, what you need to know: A user’s
guide to home wastewater systems. GDC, Gisborne, New Zealand.
Gisborne District Council. (2012). Guidelines for On-site Wastewater Management. n-
218973 v6. GDC, Gisborne, New Zealand.
Gisborne District Council. (2012). Regional Plan for Discharges to Land and Water, Waste
Management and Hazardous Substances. ISBN: 0-9582033-5-0.
Gisborne District Council. (2015). Gisborne District Cemeteries and Crematoria Bylaw
2015. GDC, A539617. Gisborne, New Zealand.
Gisborne District Council. (2015). Gisborne Trade Waste Bylaw 2015. A527306. GDC,
Gisborne, New Zealand.
Gisborne District Council. (2015). Residential Wastewater Systems, An introduction to
installing and maintaining a domestic septic tank. GDC, A574901. Gisborne, New Zealand.
Green, C. L. (2003). Worry-free wastewater, NFDA’s environmental study concludes septic
systems can safely treat funeral home wastewater.
Green, C. L. (2008). Funeral Directors are Environmentally Good Citizens. National Funeral
Directors Association, NFDA Services Inc. Retrieved from
file:///F:/mortuary%20and%20funeral%20home%20waste/Funeral%20Directors%20are%
20Environmentally%20Good%20Citizens.htm
35
LaKind, J. S., & Bouwer, E. J. (2003). Septic Study: Investigation of the Removal of
Formaldehyde and Phenol by Funeral Home Septic Systems. National Funeral Directors
Association, Brookfield, WI.
Landcare Research New Zealand Limited. (2011). S-map Soil Report. Retrieved from
http://smap.landcareresearch.co.nz/home
Marshall, J. M. (2000). Method and Apparatus for Treating Medical Waste Water. United
States Patent, US006126830A. Ohio, United States of America.
Ministry of Health. (2008). Health and Disability Services (Infection Prevention and
Control) Standards. Standards, New Zealand Paerewa Aotearoa, NZS 8134.3.2008. ISBN:
1-86975-096-9.
Ministry of Transport. (2008). Transporting Dangerous Goods Safely: An Industry Guide.
Wellington, New Zealand. ISBN 978-0-478-07236-5.
Morgan K., Fa’aui T., and Manuel R. 2006. Decision making at the Interface: Mauri and its
contribution to the Rena Recovery Authors.
Morgan, K. 2006. ‘An indigenous perspective on water recycling’. Desalination 187 (2006)
127–136
Morgan, 2012. CONTRACT 12RF01 FINAL REPORT How can Mātauranga Māori contribute
to the Rena disaster response? Auckland University.
Murray, T., Murray, L., Neho, M., Joyce, R., Taurima, W., Cash, M. & The Solomon Family.
Tumatanui: The experience of a group of Maori funeral directors (A bicultural research
project). The Open Polytechnic of New Zealand Monographs in Maori Business: Breaking
the Boundaries (1).
New Plymouth District Council. (2015). Mortuary and Funeral Home Waste: Trade Waste.
New Plymouth, New Zealand. Retrieved from
file:///F:/mortuary%20and%20funeral%20home%20waste/Trade%20Waste.html
Nikora, L. W., Te Awekotuku, N., Rua, M., Temara, P., Maxwell, T., Murphy, E., McRae, K.,
& Moeke-Maxwell, T. Tangihanga: The Ultimate Form of Māori Cultural Expression-
Overview of a Research Programme. Tangi Research Programme, University of Waikato,
New Zealand.
Ohio Environmental Protection Agency. (2008). Interim Onsite Sewage Treatment System
Guidance Document: Division of Surface Water. Ohio, United States of America.
Olson, P. R. (2015). Knowing “Necro-Waste”, Social Epistemology, A Journal of
Knowledge, Culture and Policy. DOI: 10.1080/02691728.2015.1015063 Retrieved from
http://dx.doi.org/10.1080/02691728.2015.1015063
Patwary, M. A., & Sarker, M. H. (2012). Quantitative assessment of mortuary waste:
occupational safety and environmental health. School of Science and Engineering,
Teesside University, Middlesbrough, UK. DOI: 10.5430. Retrieved from
http://dx.doi.org/10.5430/jha.v1n1p49
Royal et al. 1995 [re Mauri and the NZ Coastal Policy Statement; reference details to
follow]
36
State of Wisconsin Department of Safety & Professional Services Division of Safety and
Buildings. 2012. Mound Component Manual For Private Onsite Wastewater Treatment
Systems (Version 2.0).
US Bio-Clean. (2014). The Definitive Guide to Medical Waste Disposal. US Bio-Clean,

Arizona, United States of America.
Walls, C., Brownless, J., & Cluroe, A. (2000). Managing Health and Safety Risks in New
Zealand Mortuaries: guidelines to promote safe working conditions. Department of
Labour: Occupational Safety and Health Service, Wellington, New Zealand. ISBN 0-477-
03633-3.
Water Corporation. (2010). Industrial Waste Information Brochure: Funeral Parlours and
Mortuaries. ID: 364791.
Wyoming Funeral Directors Association. Is CJD a danger to healthcare and mortuary
staff? Prions Blood Funeral Director Embalmer, WFDA.
37

Environmental Planning Regulations 16 128 Appendix 1 Land Based Discharge of Mortuary Wastewater Feasibility Report

Hochgeladen von

Dokumentinformationen

Originalbeschreibung:

Copyright

Verfügbare Formate

Dieses Dokument teilen

Dokument teilen oder einbetten

Freigabeoptionen

Stufen Sie dieses Dokument als nützlich ein?

Sind diese Inhalte unangemessen?

Copyright:

Verfügbare Formate

Environmental Planning Regulations 16 128 Appendix 1 Land Based Discharge of Mortuary Wastewater Feasibility Report

Hochgeladen von

Copyright:

Verfügbare Formate

Appendix 1

Separation and land

Prepared for the Gisborne District

Nga Mahi Te Taiao

Discussion and recommendations

Treatment and discharge system design and operational management

Communication with hospitals and funeral homes

The Wastewater Technical Advisory Group (WTAG) and Wastewater Management

Relevance to Iwi Maori o Te Turanganui a Kiwa

Proposed separation and treatment system for mortuary and funeral

 Developing arrangements for monitoring the training and assessment of

Collection, transport, and delivery to treatment station

7 Biodegradation is the breakdown of chemicals by microorganisms. Biodegradation rates for Formaldehyde

Other potential contaminants

Separation of leach-field leachate from ground and surface water

 Hospital/funeral home waste

In order to mitigate against any adverse environmental effects, a precautionary

Figure 3 Buffer/holding tank

Figure 4 Typical soakage bed profile (GDC, 2012)

Figure 5 Elevated Wisconsin Mound in construction (GDC, 2012)

Example of proposed in-situ tank system and leach field

Inlet for mortuary

Lower outlet sealed

Figure 7 Discharge holding tank and leach field venue

Discharge point from truck

Figure 8 Standard leach field being lain (GDC, 2015)

Guidelines and statutory contexts

HSNO Act 1996

Rule 5.6.14 (Discretionary Activity): The discharge of septage to land from a

iv. A temporary ablution building on the same property as the holding

d. The actual or potential impact on any values of scheduled

Managing health and safety risks in New Zealand mortuaries. Guidelines to

Gisborne Trade Waste Bylaw 2015

NZ Standard: Management of Healthcare Waste NZS4303:2002 (some relevant

4 WASTE GENERATORS’ RESPONSIBILITIES

Guidelines for On-site Wastewater Management (GDC 2012)

below irrigation through which the wastewater must be able to infiltrate is

Table 1: Plants for Soakage Areas (Guidelines, GDC 2012)

AUTHORITY METHODS FOR MANAGEMENT OF TRADE WASTES TO SEWERAGE SYSTEMS LINK

References and bibliography

US Bio-Clean. (2014). The Definitive Guide to Medical Waste Disposal. US Bio-Clean,

Das könnte Ihnen auch gefallen