Alkaline Hydrolysis Working Group minutes: March 2025

Attendees and apologies

• Katrina McNeill, Burial and Cremation Team, Scottish Government (Chair)
• Caroline Stewart, Burial and Cremation Team, Scottish Government
• Janine Ballantine, Scottish Environment Protection Agency (SEPA)
• James Blackburn, Scotmid Funeral Directors
• Helen Chandler, Kindly Earth
• Douglas Davies, Durham University
• Norman Donnelly, Scottish Environment Protection Agency (SEPA)
• Alistair Gardner, Scottish Water
• Jane Matheson, Edinburgh Council
• Andrew Purves, William Purves Funeral Directors
• Georgina Robinson, Durham University
• Sandy Sullivan, Resomation Ltd
• Robert Swanson, Senior Inspector of Burial, Cremation and Funeral Directors

Apologies

• Ellen Millar, South Lanarkshire Council

Items and actions

Welcome and introductions

Members were welcomed to the group and introductions were made. Members agreed the remit of the group and agreed that the membership list, remit and agreed minutes of meetings are published on the Scottish Government website.

Action: Burial and Cremation Team to arrange for publication of members and remit.

Topics

Content of the Regulations and management plan

The group discussed the content of the Cremation (Scotland) Regulations 2019 (the 2019 Regulations) and agreed it is appropriate to largely replicate the management plan and maintenance/operation of equipment requirements in the 2019 Regulations for the Alkaline Hydrolysis (AH) Regulations.

Retention of records and application forms

The group agreed the statutory application forms set out in the 2019 Regulations can be replicated as far as possible for the AH regulations and the same retention requirements should apply for documents. The Chair advised the group that the order of priority set out in the 2016 Act for who can make funeral arrangements will apply to AH.

Transportation of deceased and use of coffins

The group discussed transportation of the deceased and use of coffins. Coffins are not used in the AH process but can be used for transportation. There were different views about reuse of coffins. The group also commented on the use of shrouds and what might be done where coffins are purchased by the applicant (rather than “rented”) such as recycling. All agreed that it would be essential for the person making the arrangements to be kept fully informed and made aware of what their options are. It was agreed that the operators’ policy on use of coffins for transport could be included in the management plan.

Operators will need to consider practicalities around timing of the AH process itself and when any coffin used might be returned to/collected by the funeral director, depending on whether a funeral director takes back the coffin immediately or would come back to the AH facility to collect. This will be an operational question.

Action: Burial and Cremation Team to consider whether the Funeral Director Code of Practice might need to be updated to include care of deceased in relation to AH.

Identification of deceased

The group discussed how to ensure that the deceased can be identified. Near field communication (NFC) tags on the body bag or stainless steel identification tags inside the bag which would survive the AH process are two options. Management plans should set out how operators will identify the deceased at all stages.

Scottish Water/SEPA consent to operate

The expectation is that most operators will discharge the effluent to the public drain (rather than to land). Scottish Water do not carry out “day to day” checks of operators who have been granted a licence (as happens with online emissions monitoring from crematoriums by SEPA). Scottish Water can carry out ad hoc inspections and take samples and are likely to suggest to operators that sampling points are installed.

Scottish Water noted that there is a maximum capacity for discharge to the public drain and in some areas it may be necessary to refuse consent to discharge to drain when that maximum is reached. Scottish Water can give consent in advance of prospective planning application and can review consents already given and vary them in future. SEPA are copied into planning applications by local authorities.

Action: Burial and Cremation Team will consider adding to the guidance that potential operators should engage early with Scottish Water when considering a planning application.

Sustainability – use of effluent as fertiliser

The group are sensitive to the importance of public perception when introducing any new method of body disposal. All agreed that a phased approach is appropriate for AH. The possible use of the effluent as a fertiliser can be considered once AH has become an accepted alternative to burial and cremation. At that time discussions can take place on whether applicants would be required to give consent for it to be used as such, or whether ensuring the applicant is fully informed of the options an operator offers is sufficient: again transparency is key.

Pregnancy losses – individual or shared

The group agreed that AH is a viable option for pregnancy losses and stillborn babies, similar to cremation, and operators must make clear no residue (powder) will be available from shared cases. For individual cases, there may not be any powder to return. All agreed of the importance of being transparent with the applicant to manage expectations.  

Joint/Bariatric cases

Current AH chambers are not configured to accommodate two adults. The ability to accommodate an adult and child will need to be decided on a case by case basis.

Existing chambers have weight and size limits however, larger chambers may be developed in future. Operators will need to manage expectations for bariatric cases.

The AH regulations will include a requirement to provide weight on application form and operator will need to make clear the capacity they can accommodate.

Preserved body/body parts (including anatomy)

The group discussed whether any body or body parts from anatomy departments are suitable for the AH process. Factors that need to be considered are whether a body/body part has been embalmed and the strength and type of embalming fluid. AH chambers currently include a setting for embalmed bodies which adjusts the duration of the process and strength of the liquid used accordingly. Another consideration is whether they have been plastinated. It is likely the regulations can replicate the equivalent cremation forms, with an added section asking whether a body has been embalmed, plastinated or frozen.

The equivalent of cremation application form A1 (adults or children) should state that it includes body parts.

Action: Burial and Cremation Team to confirm use of AH for anatomical remains with HM Inspector of Anatomy for Scotland and anatomy departments.

Hazards and implants

For cremation, any surviving implants or artificial joints are normally recycled with proceeds going to charity. The applicant can ask for these to be returned to them. It is understood that more is recoverable from AH such as some jewellery which survives the process. The group discussed how the AH regulations can address the options for jewellery, how it is accounted for and whether it will be returned to the applicant. Some operators might prefer that it is a requirement for any jewellery to be removed in advance. All agreed the applicant needs to be fully informed of the options and any requirement to remove jewellery.

Action: Burial and Cremation Team will include reference to jewellery on the draft application forms for the group to consider the wording.

Terminology to use

The group discussed what terminology should be used. The group is alert to the confusion of meaning around the terminology used which led to the baby ashes scandal which was partly attributed to the use of “sensitive language”, rather than being clear what the process was and what each stage involved. It was noted that descriptions and terminology should be accurate about what AH is in the regulations, on the application forms and in guidance notes.

Action: Burial and Cremation Team to consider what terminology might be used and come to an agreed definition for the regulations.

Holdover

The group discussed what the procedure should be if the AH process cannot take place on the same day as the service. For cremation, holdover can be up to 48 hours with the deceased kept in the coffin. If a body is only in a shroud consideration is needed on whether operators should have cold storage for holdover. The dignity of the deceased must be considered as well as the wellbeing/duty of care for staff.

For inspection purposes, inspectors can ask to see the management plans to check contingency plans and information about storage/holdovers and refrigeration.

Action:

• Burial and Cremation Team to ask cremation authorities what happens when it is necessary to hold over cremation and how this might be applied for AH

• Burial and Cremation Team to consider including requirement in regulations for operators to have cold storage for holdover

Any other business and next meeting

No other business was raised.

The next meeting will focus on new premises, further details into the disposal of liquids, and impact assessments. The next meeting date is 17 June 2025.

Burial and Cremation Team

9 June 2025