Consultation outcome

Summary of responses and government response

Updated 4 December 2025

Introduction

This report details the distribution of feedback provided by consultees following public consultation on the revised Crematoria Process Guidance Note “PGN 5/2 (25)”. The consultation took place between 9 October and 3 December 2023.

Crematoria play a uniquely sensitive and important role in society – providing a vital service to individuals, families and communities during some of their most difficult moments. This new guidance for the sector reflects these sensitivities while contributing to our broad environmental goals in reducing the health and environmental impacts of crematoria emissions.

Crematoria process guidance note: PGN 5/2 (25)

This guidance note provides a technical summary of the crematoria process operated across the UK and sets out the limits, control measures, and the Best Available Techniques (BAT) for the sector.

This guidance also, where appropriate, gives details of any mandatory requirements affecting emissions to air, such as those contained in other regulations.

Consultation summary

Defra received 50 responses, of which 25 responded on behalf of local authorities, 15 from private organisations and 9 by individuals. One reply was made anonymously.

All of the responses have been collated and presented in this report. Where a response to a consultation question showed a high degree of agreement or consensus, no changes are proposed. However, replies are provided to questions 4, 8, 11, 13, 17, 19, 22, 24 and 25 to inform the reader.

Recommendations

Changes will be made to the implementation dates proposed in questions 4, 17, 24 and 25 to reflect the amended timescale in publishing the new guidance. Guidance on calculation and reporting of carbon emissions has been made non-mandatory.

Questions and summary of responses

The consultation questions, responses and recommendations.

Question 1: to what extent do you agree or disagree with the introduction of the first implementation date after one year from the publication of the new guidance, for new and replacement cremators?

Question 1 answers: 24 Strongly Agree, 22 Agree, 2 Neither Agree nor Disagree, 2 Question not answered.

Response: 90% of respondents strongly agree or agree.

Recommendation: No change

Question 2: to what extent do you agree or disagree with the second implementation date after four years from the publication of the new guidance, for all cremators?

Question 2 answers: 15 Strongly Agree, 24 Agree, 4 Neither agree nor disagree, 3 Disagree, 1 Strongly Disagree,3 Question not answered.

Response: 78% of respondents strongly agree or agree. 8% of respondents strongly disagreed or disagreed. 

Recommendation: No change.

Question 3: to what extent do you agree or disagree with the exceptions for the installation of flue gas treatment?

Question 3 answers: 8 Strongly Agree, 30 Agree, 5 Neither Agree nor Disagree, 2 Disagree, 3 Strongly Disagree, 2 Question not answered.

Response: 76% of respondents strongly agree or agree. 10% of respondents strongly disagree or disagree.

Recommendation: No change.

Question 4: provide any comments you may have about any of the changes in relation to the implementation of the mandatory mercury abatement in the proposed new guidance. 

Question 4 answers: many respondents agreed that implementing mandatory mercury abatement is necessary and welcome this development.

However, some consultees raised concerns regarding the feasibility of the proposed first and second implementation dates of 1 January 2024 and 1 January 2027, respectively, as the guidance is yet to be released. 

Some respondents, whilst not opposed to the implementation of mercury abatement, felt that the criteria for exemption on the grounds of technical or logistical limitations should be expanded and appropriate timescales for exemption should be clearly defined.

One respondent suggested that the exemption should be removed, stating that operators have had a long time to prepare for this requirement and should not be allowed further dispensation.

Another advised that those unable to install mercury abatement due to space limitations should investigate alternative options to reduce their emissions and improve local air quality and that these assessed options should be submitted to the Regulator.

Some respondents suggested that limiting standby cremators and unabated cremators to operating only 100 hours a year, after four years, may be problematic to manage as the cremation cycle time may vary depending on non-technical factors, such as the type of materials used in the coffin. These comments further suggest that a limit of 100 cremations would make more sense to local operators and their Regulators and, therefore, should be considered.

Response: the implementation dates will be amended to reflect a time period following publication of the guidance. The first implementation date will now be 1 month from the publication of the new guidance for new and replacement crematoria, while the second implementation date will be four years post-publication for existing crematoria. 

Mercury abatement requirements were set over 20 years ago, and the industry has successfully transitioned into compliance via the burden-sharing scheme. Nevertheless, some operators still have unabated cremators and state physical constraints as a limiting factor. This position is no longer tenable as the intervening years have provided sufficient time to invest and future-proof these installations.

Unabated crematoria also have the potential to operate at an economic advantage to sites implementing full abatement, which distorts the marketplace as well as resulting in emissions of mercury. Non-compliant installations will have four years to comply with these requirements post-publication.

The feedback on the 100-hour operating limit for standby cremators is recognised; however, maintaining the 100-hour limit in the existing process guidance note 5/2 ensures that there is no backsliding in terms of unabated operations.

Deviating from a time limit and introducing a metric based on the number of cremations would lead to operation significantly above the 100-hour threshold (potentially up to 250 hours depending on the size of the deceased and coffin). This approach would therefore be a regressive step for emissions compliance and is unacceptable in terms of impact for the reasons stated above.

Recommendation: the first implementation date changed to 1-month post-publication of the new guidance for new and proposed crematoria. The second implementation date changed to 4 years post-publication for existing crematoria.

Question 5: to what extent do you agree or disagree with the introduction of temporary cremators?

Question 5 answers: 11 Strongly Agree, 26 Agree, 8 Neither Agree nor Disagree, 2 Disagree, 1 Strongly Disagree, 2 Question not answered.

Response: 74% of respondents strongly agree or agree. 6% of respondents strongly disagree or disagree.

Recommendation: No change

Question 6: do you think the definition of “standby cremators” is currently clear?

Question 6 answers: 13 Very Clear, 27 Clear, 7 Unclear, 1 Very Unclear, 2 Question not answered.

Response: 80% of respondents think that the definition is very clear or clear. 16% of respondents think the definition is very unclear or unclear. 

Recommendation: No change

Question 7: do you think the definition of the newly introduced “temporary cremators” is clear?

Question 7 Answers: 12 Very Clear, 33 Clear, 3 Unclear, 2 Question not answered.

Response: 90% of respondents think the definition is very clear or clear. 6% of respondents think the definition is unclear. 

Recommendation: No change

Question 8: provide any other comments you have about standby or temporary cremators?

Question 8 answers: a few comments suggested that standby cremators should be phased out. Conversely, some felt the use of standby or temporary cremators was acceptable but believe these should come with built-in abatement and be subjected to the same compliance requirements as abated cremators.

A few respondents suggested limiting standby cremators to 100 cremations instead of 100 hours per annum, as such an approach was perceived as making it easier for crematoria operators to plan. One respondent further suggested that if the 100-hour limit is retained, the process steps that constitute the 100-hour limit should be clarified.

One comment suggested a need for standby or temporary cremators in the short term but indicated that a condition should be included to avoid the extended operation of such equipment. This respondent suggested that this is addressed for temporary cremators but not for standby units, and it may be desirable to place some limitations to avoid the utilisation of a standby unit (particularly an unabated unit) over a prolonged period of years.

Another suggestion raised by one respondent was that the stack height of standby and temporary cremators should be specified and be at least 1 metre above the height of any building within 20 metres to help ensure adequate dispersion of pollutants. This respondent stated that standby or temporary cremators are usually located outside the back of crematoria, screened from view in a yard or similar, so they may have tall buildings, walls, or fences nearby, which could impede the proper dispersion of pollutants.

Response: as discussed with the Technical Working Group (TWG), mitigating circumstances determine the need for standby or temporary cremators, and they will remain an operational necessity for the sector. There are sufficient controls to ensure that emissions from these units do not significantly impact local air quality or other sensitive receptors. There is a requirement that standby cremators should be:

• identified and included in environmental permits
• they shall only be brought into operation if there is a clear operational need
• all periods of operation and the reason for standby cremator operation must be recorded in the log
• unabated standby cremators must only operate for up to 100 hours per year, to ensure there is no backsliding in terms of unabated operations in accordance with the requirements of existing process guidance note 5/2(12)

The guidance also specifies what activities constitute 100 hours of operation. No cremation should be commenced once 100 operating hours have been reached. If the 100-hour limit was exceeded mid-cremation, that cremation would be completed.

Concerning stack heights for standby and temporary cremators, defining a stack height as suggested by one of the respondents is inappropriate and should always be based on an assessment of the environmental impact of emissions to air on relevant sensitive receptors. There is guidance on how to assess the impact of emissions from crematoria on local ambient air quality; this is included in the crematoria guidance.

Local authorities may require an operator to consider an increase in stack height where an air emission risk assessment shows a likelihood of significant impact of emissions from the process on relevant human and/or ecological receptors. The position remains that the measures included in the new guidance for controlling emissions from these cremators are appropriate.

Recommendation: No change

Question 9: to what extent do you agree or disagree with the proposed limit of 100mg/m3 for carbon monoxide as an operational limit as opposed to an emission limit value (ELV) in the proposed new guidance?

Question 9 answer: 2 Strongly Agree, 23 Agree, 19 Neither Agree nor Disagree, 2 Disagree, 2 Strongly Disagree, 2 Question not answered. 

Response: 50% of respondents strongly agree or agree. 8% of respondents strongly disagree or disagree.

Recommendation: No change

Question 10: to what extent do you agree or disagree that these operational control limits for temperature, residence time and oxygen content can be relaxed provided compliance with all emission limit values can still be achieved?

Question 10 answers: 21 Agree, 12 Strongly Agree, 9 Neither Agree nor Disagree, 4 Disagree, 2 Strongly Disagree, 2 Question not answered.

Response: 66% of respondents strongly agree or agree. 12% of respondents strongly disagree or disagree. 

Recommendation: No change

Question 11: provide any other comments you have about any of the operating conditions?

Question 11 Answer: many of the respondents support the relaxation of the operational control limits if the emission limits can still be achieved, noting that this could also contribute to a reduction in energy consumption and carbon emissions from crematoria. 

Some responses expressed concern about the introduced requirement for carbon monoxide (CO) to be monitored at the exit of the secondary combustion chamber as opposed to the current monitoring requirement, which is post-abatement and means that plants with multiple cremators require only one CO analyser.

The responses stressed that this new requirement for monitoring at the exit of the secondary combustion chamber means that each cremator would need an analyser, which in turn will add to the capital costs. 

Another respondent considered the reporting requirements for continuous monitoring unclear. The respondent advised that the guidance should clarify the reporting requirements for continuously monitored data and in what format.

One respondent stated that allowing some operators to tweak the combustion parameters could give them a commercial advantage and that, instead, crematoria should be encouraged to operate at lower emissions if they can achieve them. They further recommended that guidance should place the onus on the operator to explain why they want to alter the combustion parameters and provide robust justification to the regulator. 

Response: for cremators fitted with flue gas treatment, different conditions/limits for the temperature, residence time and oxygen content at the exit of the secondary combustion chamber may be authorised by the Regulator provided all the other requirements of the guidance are met, including all emission limit values. This flexibility could reduce energy consumption, reduce CO2 emissions, and encourage the use of new cremator technologies, some of which can operate under different or more novel conditions.

Regarding the location of carbon monoxide monitoring, the monitoring requirement at the exit of the secondary combustion chamber is necessary to ensure continued improvement in emissions. Carbon monoxide is an indicator of incomplete combustion, so monitoring at the exit of the secondary combustion chamber provides a better indication of the performance of each cremator and could highlight when intervention is needed.

Monitoring and controlling CO emissions will minimise emissions of unburnt organic compounds, including polycyclic aromatic hydrocarbons and dioxins and furans, which are much more challenging to monitor. It is also important to note that this requirement only applies to new and replacement cremators and should be budgeted for accordingly in the capital set-up costs.

A Regulatory Impact Assessment was carried out by Defra to determine the environmental benefits of the updated guidance and the costs associated with its implementation. This assessment considers that the conditions in the updated guidance are appropriate for the protection of human health and the environment and that the benefits associated with the implementation outweigh the costs.

The reporting requirements in the new guidance are precise. There is a requirement in the guidance for operators to report all operational monitoring data within a timescale, frequency, and format agreed upon with the Regulator. A reporting mechanism for periodic monitoring data is also specified.    

Recommendation: No Change.

Question 12: to what extent do you agree or disagree with the changes introduced that set more restrictive conditions in current guidance – Bypass mode?

Question 12 answers: 31 Agree, 4 Strongly Agree, 11 Neither Agree nor Disagree, 2 Disagree, 2 Not answered

Response: 70% of respondents agree or strongly agree. 4% of respondents disagree.

Recommendation: No change

Question 13: provide any other comments you have about any of the operating conditions in bypass mode?

Question 13 answers: some respondents expressed concern about allowing cremators to operate in bypass mode for up to 100 hours per annum due to equipment failure; some welcomed the provision in the guidance for reporting the hours of operation in bypass mode to the regulator. 

Some respondents have queried the assessment method of the impact of bypass operation on local ambient air quality, stressing that the recommended H1 tool is not appropriate for screening emissions to air from small stacks.

Several respondents supported the recommendation of short-term power interruptions being one of the scenarios under which crematoria can operate in bypass. While in support of this, one respondent believed that there are other situations or failures that could potentially lead to cremator operation in bypass and that it will likely be specific to each site, depending on the set-up. The respondent advised that the decision about using the bypass should be made in consultation with the Regulator.

Response: cremators should not be habitually allowed to operate in bypass mode without proper justification, as this indicates operational or maintenance issues with the plant, which require investigation and rectification.

The situations under which crematoria can operate in bypass are sufficiently addressed in the guidance. Regulators can, in exceptional cases, consider the operation of crematoria in bypass outside the circumstances listed in the guidance, and this should be evaluated on a case-by-case basis. 

Additionally, the 100-hour limit on bypass operation is consistent in limiting local air quality impacts, as set out in other parts of the guidance.

In unusual and unexpected circumstances, where an Emergency Release Valve (ERV) is likely to operate in exceedance of 100 hours, the impact on local ambient air quality should be assessed before the 100-hour limit is reached using the H1 software screening tool. The limitations of the H1 tool when considering small stacks are recognised, and the Environment Agency has commissioned the development of a screening tool for emissions from small stacks.

The small stack screening tool will enable users to carry out screening assessments of emissions to air from combustion and industrial sources with stacks less than 15m in height. It will implement the approach specified in the existing air emissions risk assessment (AERA) guidance. The tool will complement the current H1 tool, which will remain in use for taller stacks and emissions other than those to air. The tool will be made available to operators and regulators in due course.  

Recommendations: No change.

Question 14: to what extent do you agree or disagree with the ELV set out for NOx in the proposed new guidance?

Question 14 answers: 31 Agree, 7 Strongly Agree, 10 Neither Agree nor Disagree, 2 Not answered.

Response: 76% of respondents agree or strongly agree. 

Recommendation: No change

Question 15: to what extent do you agree or disagree with setting ELVs for NOx from the end of the four-year implementation period in the proposed new guidance?

Question 15 answers: 31 Agree, 4 Strongly Agree, 9 Neither Agree nor Disagree

2 Disagree, 4 Not Answered.

Response: 70% of respondents agree or strongly agree. 4% of respondents disagree. 

Recommendation: No change

Question 16: to what extent do you agree or disagree with the monitoring frequency set for NOx and ammonia (NH3) in the proposed new guidance?

Question 16 answers: 32 Agree, 3 Strongly Agree, 9 Neither Agree nor Disagree, 3 Disagree, 1 Strongly Disagree, 2 Not answered.

Response: 70% of respondents agree or disagree. 8% of respondents disagree or strongly disagree.

Recommendation:  No change

Question 17: provide any other comments you have about the proposals for NOx in the proposed new guidance.

Question 17 answers: there was consensus on the need to monitor NOx emissions, which has been introduced as part of the new guidance. However, respondents queried the proposed emission limit value, stating a need for more data to set an Emission Limit Value (ELV) for NOx. Some have also questioned how achievable the proposed ELV is using Selective Non-Catalytic Reduction (SNCR), considering that only one data point for SNCR was obtained, showing emissions of 114 mg/Nm3. 

Some respondents also raised concerns over the impact of ammonia, which can be used as a reagent for SNCR, especially as it could be a contributor to secondary PM2.5.   

One response suggested that crematoria operators should consider not burning coffins in cremators because some construction materials contribute to NOx formation during the cremation process.  

Another respondent raised cost concerns, suggesting that funding should be provided to some of the Local Authorities for the installation of the NOx monitoring equipment.

Response:  in line with this Process Guidance Note, SNCR is used as a NOx abatement technique in combustion processes across various industrial sectors and can achieve reductions in emissions of between 60% and 80%. It is included in the guidance as an emerging technique because its application to cremation is not yet optimised and is not available from all equipment manufacturers. However, the available data suggests that it can achieve 114 mg/Nm3, which is significantly below the proposed emission limit value with significant headroom.

Members of the TWG extensively discussed options for NOx control at the last meeting of the TWG, where the draft was authorised. The argument concerning data availability for NOx emissions is well made. However, in considering an appropriate ELV, the TWG decided upon a threshold that they considered commensurate to the performance levels observed in control techniques found in combustion industries.

It should also be noted that the measures in the guidance are not exhaustive; operators have the flexibility to introduce other NOx reduction techniques or measures that can provide an equivalent level of environmental protection.

With SNCR, overdosing on ammonia can result in emissions to air of ammonia, which is why a monitoring requirement for ammonia slip has been introduced where SNCR is installed. This will ensure that Regulators have adequate data on performance to determine problems and inform improvements where necessary.

It is also understood that SNCR can increase particulate emissions on unabated cremators, but as already stated in this document, the operation of unabated crematoria will no longer be accepted as part of the implementation of this updated guidance. 

Regarding cost, a Regulatory Impact Assessment was carried out by Defra to determine the environmental benefits of the updated guidance and the costs associated with its implementation. The assessment considers that the recommendations are appropriate for the protection of human health and the environment and that the benefits associated with the implementation outweigh the costs.

The implementation dates are reasonable, giving the stakeholders time to address any financial, technical, or logistical issues that may arise. In cases where these issues are outside the operator’s control, the Regulators have the discretion to consider the issues presented to them and decide on an appropriate route forward. 

One month after guidance publication, all new and existing crematoria will need to monitor NOx emissions, and compliance with the ELV will be 4 years forthwith.

Recommendation:  The implementation date for NOx monitoring and the implementation of the agreed ELV will now be 1 month from the publication date of the new guidance and 4 years post-publication, respectively, for all crematoria.

Question 18: to what extent do you agree or disagree with producing an impact assessment on local air quality as a way to complement the existing stack height methodology?

Question 18 answers:  21 Agree, 9 Strongly Agree,13 Neither Agree nor Disagree,4 Disagree, 1 Strongly Disagree, 2 Not answered.

Response: 60% of respondents agree or strongly agree. 10% of respondents disagree or strongly disagree.

Recommendation:  No Change

Question 19: provide any other comments you have about this matter in the proposed new guidance – stack height?

Question 19 answers: several respondents agree with the requirement for operators to assess the impact of air emissions on local air quality but have queried the availability of suitable alternatives to Technical Guidance Note (Dispersion) D1 stating that H1 is only appropriate for assessment of emissions from taller stacks and that air dispersion modelling is too expensive.  

Some respondents have queried the relevance of referring to D1 in the guidance since it is not a tool for assessing pollutant dispersion and its effects on ambient air quality. Some respondents have also queried if there would always be a requirement for stack heights to be increased if an impact assessment predicts a significant effect on ambient air quality; the respondents suggest that an increase in stack height may not always be possible due to issues such as obtaining planning permission and cost.   

One respondent considers that this is not required as Local Air Quality Management (LAQM) has been in place for many years, and Local Authorities are required to assess their area against the pollutants in the AQ objectives. Local authorities are also required to carry out an annual status report.  

Response: operators have flexibility in how they determine stack height. Whatever method is used to determine the stack height (and efflux velocity), the impact of emissions to air on local ambient air quality shall be assessed. For new crematoria, this should form part of the permit application. For existing crematoria, this should be done at permit review. The air emissions risk assessment will ensure that emissions from crematoria do not exceed any relevant environmental standard.   

D1 is a 30-year-old design tool for calculating stack height; it is unsuitable for assessing environmental impact. An operator can produce an air dispersion modelling report where H1 cannot be used for the air emissions risk assessment. Note that the H1 tool is a screening tool that may require an operator to assess further (for example, by carrying out detailed modelling) if the relevant emissions cannot be screened out. Operators are encouraged to follow the Environment Agency’s methodology for carrying out an AERA; this can be found at Air emissions risk assessment for your environmental permit.

As previously stated, the development of a small stack screening tool has been commissioned by the Environment Agency for the assessment of emissions to air from small stacks. This can be used if the stack height is less than what is acceptable for the H1 tool. The tool will be available to operators and regulators in due course. 

Recommendation: No change

Question 20: to what extent do you agree or disagree with the new measures considered for the calculation and reporting of carbon emissions?

Question 20 answers: 25 Agree, 8 Strongly Agree, 6 Neither Agree nor Disagree, 7 Disagree, 2 Strongly Disagree, 2 Not Answered.

Response: 66% of respondents agree or strongly agree. 18% of respondents strongly disagree or disagree.

Recommendation:  while the guidance on calculation and reporting of carbon emissions remains in the Process Guidance Note, we have made clear that this is non-mandatory guidance that operators may wish to consider on a voluntary basis for the reasons set out in the response to question 22.

Question 21: to what extent do you agree or disagree with the implementation dates considered to fit fuel and electricity metering?

Question 21 answers: 22 Agree, 6 Strongly Agree, 12 Neither Agree nor Disagree, 6 Disagree, 2 Strongly Disagree, 2 Not answered.

Response: 56% of respondents agree or strongly agree. 16% of respondents strongly disagree or disagree. 

Recommendation:  as mentioned in the response to question 20, we have transitioned the measures on fuel and electricity metering to non-mandatory guidance for the reasons set out in the response to question 22 and as such have removed specific implementation dates.

Question 22: provide any comments you have about the measurement and reporting requirements for carbon emissions in the proposed new guidance.

Question 22 answers: while many respondents welcomed the proposed requirement for measuring and reporting carbon emissions, others highlighted that Local Authority officers dealing with permits are unlikely to have the skills or knowledge to check the data submissions accurately, which will be a time-consuming and unnecessary burden on them. Further to this, some respondents believed that such changes should come with funding for local authorities and small private crematoria.

Many respondents also felt that information on the carbon content of different coffin types and the embedded carbon arising from the manufacturing process would not be readily available to Funeral Directors and where available, the Funeral Directors would not be forthcoming with that information to enable reliable and consistent reporting across the cremation industry.

A few respondents consider this proposal for measuring and reporting carbon emissions from the coffins as unnecessary, considering that the crematoria have no control over the coffin construction materials. These respondents felt it would be easier and more beneficial to regulate coffin materials to reduce emissions at source and before arrival at the crematorium.

There was a suggestion that an average CO2e figure for a coffin could be established, which could then be applied to the annual number of cremations instead of relying on potentially poor data from funeral directors.    

Response: in the HM Treasury’s ‘New approach to ensure regulators and regulation support growth’ action plan, the government committed to cut administrative costs for business by 25% by the end of the Parliament.

While carbon emissions are a key environmental issue for the crematoria sector, the core purpose of this PGN revision is to update standards relating to emissions to air of locally harmful pollutants such as mercury. We have therefore decided to revise the PGN to make clear that the carbon reporting and measurement requirements are non-mandatory guidance to operators.

This is intended to inform operators about how to measure carbon emissions while minimising regulatory burdens on industry. We have also amended the sections of the PGN on ‘efficient operation’ and ‘energy recovery’ to make the non-mandatory nature of these sections clear.

In addition, given the special nature of this sector and the unique service that it provides to the public, references  to reducing the carbon content of coffins have been removed from the guidance.

Guidance on measuring and reporting greenhouse gases and conversion factors for fuel and electricity consumption are readily available. Local Authority officers can use these resources to validate data that is voluntarily submitted. 

Recommendation: No change

Question 23: to what extent do you agree or disagree with the changes affecting the CAMEO Burden Scheme currently in place?

Question 23 answers: 21 Agree,14 Strongly Agree, 5 Neither Agree nor Disagree, 7 Disagree, 1 Strongly Disagree, 2 Not Answered.

Response: 70% of respondents agree or strongly agree. 16% of respondents strongly disagree or disagree. 

Recommendation: No change

Question 24: provide any comments you have about the role of CAMEO in the proposed new guidance.

Question 24 answers: almost all respondents agree that the CAMEO burden-sharing scheme has been a success and that it is no longer required with impending mandatory mercury abatement for all cremators four years from the publication of the new guidance.

Some of the respondents, whilst in support of closing the CAMEO scheme, are unsure of what would happen to those crematoria that are unable to install mercury abatement due to limitations of space and a possible inability to expand, as reflected in the proposed new guidance.

We received a comment from a respondent who believed this proposal would take away a valuable source of revenue from abated crematoria that benefit financially from CAMEO. 

Response: In line with the new guidance, there is no obligation on those crematoria with mercury abatement to participate in burden-sharing arrangements. Burden-sharing arrangements are a cost-sharing mechanism so that crematoria with mercury abatement installed are not at a financial disadvantage to those that do not.

At the beginning of this review, over 70% of funerals were conducted at crematoria with mercury abatement. We anticipate that this number will rise rapidly to almost 100% with the introduction of mandatory mercury abatement for all crematoria. With the impending change, it is arguable that the CAMEO Scheme will no longer remain viable, and the scheme may be closed over the intervening years up to the point where mercury abatement is mandatory for existing installations that operate over 100 hours per year.

The closure of the burden-sharing will become necessary in time hence the regulatory option will remain in place until 31 December 2029, with a final report made to the Local Authority (the Regulator) no later than 1 April 2030.

Recommendation: No change

Question 25: are there any other comments you want to make about the proposed new guidance?

Question 25 answers: Most comments indicated that the guidance is generally well received and will ensure that emissions from crematoria are controlled. 

Some other comments digress from the original scope and raise various topics such as alkaline hydrolysis, mandatory conversion to only electric cremators, and the need to regulate some materials used in the cremation industry.

One respondent considered the implementation date of 1 January 2024 for mandatory MCERTS accreditation too soon. The respondent further queried the relevance of mandatory MCERTS accreditation, stating that there is no data to support any claim that results from non-MCERTS organisations are inferior to those obtained from MCERTS-accredited organisations. 

Response: as agreed with the TWG, there is a need for appropriate accreditation for monitoring methods, equipment and personnel, which would, in turn, offer the following potential benefits:

• consistency and quality assurance of emission testing,
• consistency in the reporting of results.

The requirement for mandatory MCERTS accreditation is still considered appropriate. The guidance will be amended so that the implementation date is 1-month post-publication. 

Concerning Alkaline Hydrolysis (Resomation, Aquamation), this is outside the scope of the new guidance. In the UK, it is currently unregulated as there are no emissions into the air and, therefore, does not come within the scope of Part B regulation under the Environmental Permitting (England and Wales) Regulations 2016, Schedule 26 of the Environmental Authorisation (Scotland) Regulations 2018 and Part C regulation under the Pollution Prevention and Control (Industrial Emissions) Regulations (Northern Ireland) 2013.

Recommendation: A change in the date of the mandatory MCERTS Accreditation from 1 January 2024 to 1 month from the publication of the new guidance.