Public Health impact of Crematoria

There are no legal requirements for emission control for crematoria in British Columbia.

This is in contrast with other jurisdictions were regulators often require strict temperature control and temperature recording at various locations. Some countries require continuous monitoring and have emission limits for specific pollutants and for parameters that indicate the completeness of combustion.

Crematoria are licensed to operate under the Cremation, Interment and Funeral Services Act (CIFSA)[1]. The agency overseeing the implementation of the Cemetery and Funeral Services Act is the BPCPA (Business Practices and Consumer Protection Authority of British Columbia).

• Section 28 of the act specifies:
  • That in order to get licensed a test of the operation of the crematorium has been completed and the test demonstrated that the crematorium operates in accordance with the manufacturer's specifications, the bylaws of the applicable local government and the laws of the Province.
  • That the professional engineer has the necessary knowledge, skill and experience to certify this document.
• Section 10: The container enclosing the human remains for the purpose of cremation does not contain: plastic; fiberglass; foam or styrofoam; rubber; polyvinyl chloride; and zinc.

Some shortcomings of the act are that there are no legal requirements for emission control, for monitoring, and for recordkeeping of maintenance activities to keep the unit operating at an optimal level to protect public health.

The Business Practices and Consumer Protection Authority (BPCPA) provides on there website a crematorium operator application checklist. http://www.bpcpa.ca/Docs/cf_crematoria_application_guidelines.pdf (last updated Nov 2005, accessed Dec 2005). Some excerpts:

• The crematorium operator is required to create bylaws himself which address:
  • Cremation and operational procedures
  • Training
  • Document and authorization requirements
  • Proper processing of paper work
  • Housekeeping
  • Company policy matters
  • Identification process
• In addition each crematoria operator is required to keep a maintenance log.
• Another technical checklist to guide applicants who are working with a professional engineer in the design, construction and completion of a crematorium is provided at http://www.bpcpa.ca/Docs/cf_crematoria_checklist_technical_requirements.pdf.
  • The guide asks for a copy of temperature recording and stack emission analysis for:
    • Carbon Dioxide CO2 %
    • Carbon Monoxide CO %
    • Oxygen O2 %
    • Nitrogen N2 %
    • Water H2O %
    • Particulate emission
• The major public health concern for the people living in the vicinity of crematoria is probably not mercury but other pollutants such as particulate matter and pollutants from incomplete combustion.
• Mercury is of concern because of long-range transport. Most Mercury is volatilized as elemental mercury, some is oxidized and a small fraction is bound to particulate matter. Volatilized Mercury re-deposits and may bio-accumulate in the food chain after methylation by microbiota.
• The best option would be to remove amalgam fillings before cremation, but in practice this might be difficult to achieve for practical and cultural reasons. This option is worth to explore with the crematorium operator.

The number of cremations is increasing in BC, as in the rest of North America.

• According to the Cremation association of North America (CANA) 78 % of deaths were cremated in BC in 2004, (approximately 23107 cremations). There has been a steady increase since 1996 when 71.4 % of bodies were cremated. CANA predicts that the absolute number and the percentage of deaths cremated will further increase in the future.
• The percentage of cremation for the whole of Canada was 56% in 2004.
• Emissions from crematoria contains a varying degree of pollutants such as particulate matter, volatile organic compounds, carbon monoxide, nitrogen oxides, sulfur dioxides, hydrogen chloride, heavy metals (cadmium, mercury, and lead), and dioxins and furans.
• Technology is available to reduce these emissions significantly. It is assumed that, if modern crematoria operate correctly, emissions are relatively small with a small impact on public health. Emission data in North America are sparse and only done on crematoria with new installations.
• Case 1: Crematory emissions testing at The Woodlawn Cemetery (New York, June 1999), one of the only crematories in North America with additional pollution control equipment in New York, was funded jointly by CANA and the EPA. Sampling was done upstream and downstream from pollution control equipment (wet scrubber).The CANA website gives the test results but doesn’t specify if the data are up or downstream from the scrubber. The data from this single test serve as national reference for mercury and other pollutants from crematoria for pollutant inventories. [2]
• Case 2: The environmental Protection Office of Toronto Public Health reported on stack testing for PM, heavy metals including Mercury, dioxins and furans, dispersion modeling and actual ambient air monitoring before and after Saint Johns crematorium became operational. They found low pollutant emission rates and concluded that the contribution of the studied crematorium to the ambient air quality was very small.[3]
• Case 3: In September 1997 the provincial government granted First Memorial Funeral Services a certificate to operate its crematorium. From the beginning of the operation, the crematorium has regularly contaminated the neighborhood with dense black smoke. First Memorial was ordered to stop its emissions by the Ministry of Environment, but appealed the order to the Environmental Appeal Board. The crematorium questioned the jurisdiction of the regional waste manager since crematoria are licensed to operate under the Cemetery and Funeral Services Act and are exempt from the provisions of the Waste Management Act. [4] The Board concluded that the air emissions being released from the Appellant’s crematorium may be the subject of a Pollution Prevention Order under the Waste Management Act.
  The crematorium voluntarily closed the unit while they upgraded their equipment, and ultimately dropped their appeal.

Mercury:

Estimates of average mercury release per cremation of a human body vary considerably:

• • 5 to 3.41g in Sweden and Finland[5]: Similar to the 3g in finding from studies from Mills in UK[6] and Kunzler and Andree[7] in Switzerland.
  • Emissions from crematoria were estimated to be the third highest emission source of Mercury in Sweden[8].
  • 1.5 g to 4.5 g in the UK (National Atmospheric Emissions Inventory or NAEI ):.
  • NAEI estimates that in 1998, crematoria accounted for 11% of the United Kingdom’s total atmospheric mercury emissions. Between 0.4 to 1.23 tonnes mercury (for 446,000 cremations)[9]
  • 0.94 x 10^-3 g in US. Results of the testing for uncontrolled mercury emissions of a propane-fired incinerator at a crematorium inCalifornia ranged from 3.84 x 10^-8  to 1.46 x 10^-6  kg/body burned; the average mercury emission factor was 0.94 x 10^-3 g/body burned. The test results were obtained from a confidential test report to the Califonia Air Resource Board (FIRE, 1995).[10]
  • EPA estimated that all US crematories, together, would have produced a total of 108 kg of mercury emissions in 1999 (598,721 cremations).
  • A US flow model estimates cremation as the third largest source of air emissions of mercury from products at 2436 kg a year in 2005 (3.4 g per cremation and approximate 709,000 cremations)[11].

In Canada, amalgam continues to be used for tooth restorations due to its durability and low cost. The use of amalgam for new fillings in dentist office is declining and may eventually even become phased out. Maybe this problem resolves itself spontaneously in the future. In the immediate future though emissions from mercury will probably increase since there is an increase in the number of cremations and more people retain their heavily restored teeth into old age.

• Amalgan contains approximately 50% mercury. It is considered special waste through application of the BC Special Waste Regulation (BCSWR) under the BC Waste Management Act.[12]
• Canada-wide Standard (CWS) on Mercury for Dental Amalgam Waste was endorsed by the Canadian Council of Ministers of the Environment (CCME) in 2001.[13]
• The release from crematoria is not considered in the CWS for Dental amalgam waste.
• Dentists have a legal requirement to use a mercury separator in their office.
• According to environment Canada Approximately 1.3 T/yr of mercury in new filling material is placed each year in the mouths of Canadians and approximately 2 Tonnes/yr of mercury in amalgam waste is generated from the removal of old fillings and from the placing of new fillings.[14]
• Of the 215,742 deaths in Canada in 2004, 120,714 bodies have been cremated.[15].
• This gives an estimate of 109 kg to 411.6 kg mercury emissions from cremations for the year 2004 (If we use the estimates of 0.9 to 3.41 g mercury emissions per cremation).
• The total mercury emission for Canada in 2000 was estimated as 8,025 kg.[16]
• The OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic calls for Application of Best Available Techniques (BAT) to prevent the dispersal into the environment of mercury from crematoria[17].
• National emission standards that require gas cleaning to remove mercury vapor at new or large crematoria are in place in several European countries (Austria, Belgium, Germany, Great Britain, The Netherlands, Norway Sweden and Switzerland).

·         Mercury has been found to be significantly elevated in the hair of crematorium workers especially in administrators who work in closed environment with limited air ventilation. Of the 97 crematoria workers, 3% had concentrations higher than 6 ppm which is considered as the maximum tolerable level. Mean mercury concentrations were 1.96 ppm for administrative personnel and 1.47 ppm for ground personnel compared to 0.97 ppm for controls. The number of amalgam fillings was taken into consideration. A limiting factor of the study is that there is no information on possible diet exposure to mercury. The authors argue that fish is only a minor part in the diet in the UK. The authors conclude that this study contributes to the evidence that emission monitoring and control is warranted. [18]

• Mercury levels found around crematoria are below the levels that are believed to cause health problems. In New Zealand Nieschmidt and Kim [19] found soil mercury levels in the neighborhood of crematoria up to a maximum of six times the background level. They calculated that only 0.05% of the likely total mercury emissions were deposited in the local soil.
• A detailed review of references on Mercury emissions from crematoria is done by John Reindl from Wisconsin¹⁰.
• Canada Wide standards for mercury apply to industrial incinerators of which crematoria are exempt.
  For new or expanding facilities of any size, application of best available pollution prevention and control techniques, such as a mercury waste diversion program, to achieve a maximum concentration in the exhaust gases from the facility as follows:
  • Municipal waste incineration 8,9 20 µg/Rm3
  • Medical waste incineration 20 µg/Rm3
  • Hazardous waste incineration 50 µg Rm3
  • Sewage sludge incineration 70 µg/Rm3

Dioxins and furans:

Since cremation is a combustion process of organic matter dioxin and furans may be formed during the process due to incomplete combustion or new formation in the stack induced by high temperatures.

In the USA the emission of dioxins and furans measured at a crematorium with new technology was 0.5 µg TEQ per cremated body.

European test data found higher values: 4.9 µg TEQ per body at two Dutch crematoria and 70–80 µg TEQ in a British crematorium with older technology. Reviewers of the EPA dioxin emission inventory report recommend to use the Dutch Data as reference.[20]

A Japanese study, Takeda et al (2001) found an average of 3.9 µg and a median of 1.8 µg TEQ/body with a maximum of 24 µg TEQ/ body. The operational condition of the crematorium, mainly the temperature control, influenced to a large extent the emission of dioxins and furans. Takeda found in a study in Japan 1998 measurements ranging from 9.9pg to 6500 pg TEQ/m3 and in a second study in 2001 measurements between 64 pg TEQ/m3 and 24000 pg TEQ/m 3. [21]

The authors concluded that it is necessary to take measures immediately to reduce emissions given the high volume of cremations.

A recent stack test conducted by Environment Canada at a crematorium located in Mainland, Ontario detected a dioxins and furans concentration of 227 picograms ITEQ/m3 resulting in an estimated annual emission rate of .079 milligrams/year. Higher individual test run results have been noted in testing performed by a commercial source testing firm on a similar new facility in Windsor, Ontario.[22]

Canada-wide standards have been developed for waste incineration, burning salt laden wood in coastal pulp and paper boilers, iron sintering, electric arc furnace steel manufacturing, and conical municipal waste combustion, crematoria are exempt.

• Municipal waste incineration 80pg I-TEQ/m 3
• Medical waste incineration 80pg I-TEQ/m 3
• Hazardous waste incineration 80pg I-TEQ/m 3
• Sewage sludge incineration 80pg I-TEQ/m 3

Particulate matter and greenhouse gases.

Particulate matter produced by crematoria may impact the air quality level.

The production of greenhouse gases such as carbon dioxides and nitrogen oxides is another factor to consider. The required energy, mostly from natural gas, electricity or propane, for the combustion of human remains is considerable. Cremation generally takes 2-3 hours in a sealed chamber, during which the temperature ranges between 760 – 1149 ⁰C.

In Sweden a liquid nitrogen freeze-dry process is under investigation as alternative for cremation. Another innovative idea in Sweden is the recuperation of heat generated in some crematoria. For example water used to cool exhaust gases to prevent the formation of dioxins and furans, contributes to the warming of municipal heating system.

Conclusion and recommendations:

• Crematoria have the potential to have a negative impact on public health.
• There is a lack of emission data of existing facilities in Canada and North America. The few emission studies that have been done are on new facilities.
• Internationally there is clearly a concern around the polluting capacity of crematoria. Crematoria emissions are strictly regulated in most European countries, Japan, and Hongkong. In Canada and the USA, emissions of crematoria are ‘assumed’ to have only a small impact on public health.
• Crematoria should use the best available technology economically achievable to reduce air pollutant emissions and should operate at an optimal level with strict temperature control to obtain complete combustion.
• Minimum operating temperatures, minimum oxygen levels, maximum carbon monoxide levels, maximum opacity measures, maximum PM levels should be established based on work in other jurisdictions.
• A crematorium should not be cited [sic] close to a neighborhood.
• Stack emissions and ambient air quality should be monitored before and after a crematorium starts functioning.

Veerle Willaeys

Resident Community Medicine UBC