Guide to PAS100 and composting certification
Date Published: 19/02/2009
OF&G provided this article a short while ago to LAWR Magazine (Local Authority Waste and Recycling). After a couple of conversations I’ve had today about composting, I thought it was worthy of reproduction, so here goes:
The introduction of the Quality Compost Protocol in 2007 marked a major shift in attitudes to composting, allowing the end results of the process to be seen as a product, rather than a waste.
This is good news in many ways and more and more organisations are now taking advantage of this and gaining certification for their compost under the Composting Association’s PAS 100 and Quality Compost Protocol scheme.
The certification provides evidence that the composter has established an effective management system for producing quality compost. Being able to label it as a product and not a waste removes waste regulatory controls on its storage and use.
But what is involved in achieving the Quality Compost Protocol and obtaining that all-important certificate?
Due to the rapid growth in participating compost producers, the Composting Association contracted two experienced certification bodies to assess producer compliance with PAS 100 and Quality Compost Protocol. The first of these companies to award a certificate under the new arrangements was Organic Farmers & Growers (OF&G), which has been operating certification for organic food, farming and other products since the early 90s.
In almost a year of providing the inspection and certification service a number of lessons have been learned which would be valuable to any compost producer planning to join the scheme.
OF&G Certification Officer, Katie Owens, has been involved since the start in the company’s move into PAS 100 and the Quality Compost Protocol. She explained: “From our point of view it was a natural progression because inspection and certification is what we have long and successful experience of doing. The area of composting was a departure for OF&G, but having provided the service for around a year now we’ve gained some valuable insights that are definitely worth sharing with any future applicants – and perhaps even with some existing ones.
“Ensuring the application and inspection process runs smoothly is in everyone’s interest, particularly the applicant and especially if they have a deadline to meet for certification.
“Our best advice is to read the guidance clearly and ensure you understand what’s required before you begin the process. Some of the paperwork will need to be adapted to suit the set-up of your operation. For instance, the template batch monitoring record sheet puts four monitoring points at 10, 20, 30 and 40 metres. PAS 100 requires one monitoring point per each 250 m3 of composting material in a batch. If your windrows are not large enough for this, change the numbers to suit your operation. We find that a lack of thinking and planning of this kind leads to the majority of the non-compliances we identify. Correcting the non-compliances is a delay that can be avoided.”
Katie’s top tips on preparing for and successfully completing the certification process include:
• Make sure you clearly understand the full costs involved. While certification should pay off in the fairly short term, you must consider not just certification fees but the cost of the required laboratory tests as well.
• Although templates are provided for all the documents that must be completed, make sure you have read them and that they are all properly adjusted to the requirements of your site. For example, the HACCP contains a reference to physical contaminants. Producers should enter in their Standard Operating Procedures the trigger level for rejection of an input material delivery if it contains physical contaminants.
• Make sure samples for your tests are taken when your compost is ready to sell, as soon as the minimum composting process has been completed. If the earliest you would sell it is at eight weeks, sample and send it for testing during the 9th week.
• Do not wait on windrow sampling just so you can send three together. This is because samples are required from the earliest point the compost is ready to sell or leave the site.
• Basic organisation helps no end. Make sure all the paperwork is to hand at inspection time and that you know your way around it – which bits relate to which parts of the application and your operation. Also run through in advance to be sure that the paperwork links clearly to the reality of working practice on site. Remember, this is not just a paper exercise!
• Make sure your batch numbers are clear on your windrows and they link to the paperwork.
• Make sure, if you are supplying to agriculture or soil-grown horticulture, you know how to use the web-based tool (for England and Wales only) or its equivalent excel spreadsheet version and that you have evidence of this (i.e. a computer available with internet access and the ability to demonstrate your usage of the system).
When an inspection is completed the report is sent to the certification body where a Certification Officer assesses it. When a compliance notice is sent out requiring corrective action, an applicant for initial certification has three months to address all of the issues and respond. Certified compost producers inspected in a 12-month renewal phase have two months to respond to the compliance notice. In both cases, a certificate will not be issued or renewed until all matters are dealt with.
Katie summed up: “The message we’d like to get across is that the process is nothing to be feared. It’s logical and straightforward as long as applicants apply themselves to it and don’t treat it as an afterthought or an unimportant paper exercise. It’s crucial that we all get this right. The benefits should far outweigh the effort that goes into getting that all-important certificate and we’re always on the end of the phone to give support on the process or certification anf making or renewing applications.”