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Carcass Management of Non-Diseased Animals in Response to the Coronavirus Outbreak (COVID-19)

This document is intended to help producers and facilities with non-diseased carcass management during the current Coronavirus outbreak (COVID-19). Due to Covid-19, animal production and processing facilities are encountering challenges associated with certain livestock and poultry processing plant closures due to workforce and staffing issues related to the COVID-19 outbreak at those plants. As a result of these shutdowns, and other factors, some animal production facilities may need to depopulate by euthanizing animals. Unlike mortalities at normal rates, large-scale mortalities present challenges that are not part of the typical operation of these facilities. Operators are typically advised to have plans for emergency large-scale mortalities; for example, due to extreme weather or disease. However, those plans may be insufficient given the extensive challenges being faced at the current time.

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

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Who Oversees Carcass Management?

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

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

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

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

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

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

Livestock Carcass Management Options for Non-Diseased Animals
Tier 1 Ranking Management Options Controls and Limits to Environmental Releases



Rank 1:

Negligible to
minimal exposure—
releases regulated
to levels safe
for human health
and the environment

Alkaline Hydrolysis

Tightly contained, using hot sodium hydroxide
Significant reduction of solids volume

  • Relatively fast
    destruction of
  • Extremely limited capacity for mass
    mortality situations
  • Not widely available
  • Creates aqueous waste stream with
    very high oxygen demand – problematic
    for many publicly owned treatment works (POTWs)
Incineration in a Fixed Facility Air emissions regulated under the Clean Air Act (CAA);
pollution control equipment can include scrubbers, fabric
filters; residuals (i.e., ash) managed under the Resource
Conservation and Recovery Act (RCRA); discharges of
wastewater to waters of the United States managed under
the Clean Water Act (CWA)
  • Tightly regulated
  • Safe
  • Reduces volume
  • Efficient
  • Readily implemented
  • Limited local capacity depending on
    location, difficult to process large, whole
    animals, size reduction may be needed
  • Offsite (non-hazmat) transport
  • Limited availability
  • Limited throughput
  • Requires packaging
Landfilling Landfill design and operation regulated under
RCRA, controls include leachate collection and
management and methane recovery; municipal
solid waste (MSW) landfill air emissions regulated
under CAA, requirements include gas collection
and control system installation and operation
  • Tightly regulated
    facilities, leachate control
  • Safe
  • Readily available
  • High capacity
  • Quickly and readily implemented
  • Efficient
  • Potential capacity issues for animal
  • Potential permit issues
    related to accepting large quantities of carcasses
  • Offsite (non-hazmat) transport
  • Denial of use by facilities
Rendering Releases to air and discharges to waters of
the United States regulated under the CAA
and CWA, respectively
  • Recycling into food
  • Safe
  • Reduces volume
  • High throughput
  • Efficient
  • Readily implemented
  • Already permitted for carcass management
  • Limited surge capacity
  • Offsite (non-hazmat) transport
Rank 2:
Higher exposure potential—
uncontained releases to the environment 
Above Ground Burial

Partially controlled releases burial (minor
leaching, runoff, and gas release to air); may
have a low spot when carcass has decomposed

  • If implemented correctly, likely safe
  • On farm
  • Quickly and readily implemented
  • Efficient
  • Less impact to groundwater
    than below-grade conventional burial
  • Scavengers may unearth carcasses
  • Need bed and capping material such as wood chips
  • Potential public health risk
  • Not sustainable for ongoing large volume disposal
  • Regulatory limitations on use
  • May limit future land use
  • Potential future clean up liability
  • May be amenable to carcass size reduction
Air-curtain Burning Air emissions regulated under the CAA, possible
releases from combustion ash if managed on-site
  • Significantly reduced
    air emissions compared
    to Open Burning
  • On farm
  • Reduces volume
  • Requires significant quantities of solid
    fuel; ash management requirements
  • Potential risk to human health
  • Not sustainable for ongoing large volume disposal
  • Potential for public opposition
  • Inefficient
  • Requires skilled operator
  • Regulatory limitations on use
Below Grade, Conventional Burial Uncontrolled leaching from unlined burial;
slow gas release to air
  • Cheapest option
  • On farm
  • Easy to implement
  • Potential for groundwater
    contamination from leachate
  • May limit future land use 
  • Potential public health risk
  • Not sustainable for ongoing large volume disposal
  • Regulatory limitations on use
  • Potential future clean up liability
Composting Partially controlled releases from compost
windrow (minor leaching, runoff, and gas
release to air); where finished compost is tilled
into soils, potential runoff and erosion from
amended soil 
  • If implemented correctly,
    minimal leachate runoff,
    minimal odor; compost can
    be used as soil amendment
  • Safe
  • On farm
  • Quickly and readily implemented
  • Requires significant quantities
    of carbon source (e.g., wood chips,
    corn stover)
  • Significant space
  • Needs size reduction for maximum effectiveness for large
  • Needs on-site supervision by
    certified subject matter expert for maximum effectiveness and
    minimal environmental impact
  • Temporarily restricts land use
  • Takes months to complete unless carcasses are small or safely ground first
Open Burning (Pyres)

Uncontrolled and unregulated combustion
emissions, although state and local ordinances
and regulations can limit the amount and
frequency of open burning that can occur;
possible releases from combustion ash if managed

  • Relatively simple
    logistics to implement
  • On farm
  • Reduces volume
  • Requires significant quantities of
    solid fuel (coal, wood)
  • Potentially significant visible air emissions
  • Ash management requirements
  • Potential risk to human health
  • Not sustainable for ongoing large volume disposal
  • Potential for public opposition
  • Inefficient
  • Difficult to operate
  • Regulatory limitations on use

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What Possible Environmental Concerns Arise from Carcass Management?

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

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

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

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Where Are Facilities That Can Help with Carcass Management?

EPA’s Disaster Debris Recovery Tool (DDRT) is an interactive dataset that maps recyclers and landfills for the planning, response, and recovery of wastes, including animal carcasses. Soon to be expanded nationwide, this tool currently provides information and locations of facilities in 13 states capable of managing different materials and wastes. This tool can assist entities with carcass management by finding landfills and compost facilities. To access the DDRT, visit For states not currently included in the DDRT, EPA’s I-WASTE tool ( also has facility databases for landfills, incinerators, and rendering facilities. The landfill data in the DDRT for those states that are currently included are more up-to-date.

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