[USCC] National Organic Program Compost Standard

Frank & Rosy Shields franke@cruzio.com
Tue Jan 23 22:15:39 2001


Regarding the C\N ratio between 25 and 40:1.

The problem I have is often wood chips are used as bulking to give porosity
during the composting then screened out at the end. Also there are organic
materials like redwood, bark, peats that are slow to degrade at any size
fraction and IMHO should not be included into the C/N ratio because they
contribute little to the composting (heating) process.

Frank

Frank Shields
Soil Control Lab




----- Original Message -----
From: "Bob R." <rrynk@jgpress.com>
To: <compost@compostingcouncil.org>
Sent: Tuesday, January 23, 2001 10:13 PM
Subject: Re: [USCC] National Organic Program Compost Standard


> Regarding the NOPS compost standard and time-temperature requirements, I
can understand the need to insure that compost is safe to use where the use
requires such safety. Maybe PFRP or PFRP-like provisions are one solution.
But in light of the fact, as Cary explained, many successful composting
protocols do not rely on 131 F (to 170 F)  for three or 15 days, it seems
that alternatives should have been included in the rule. Not all compost is
made from manure or biosolids.
>
> HOWEVER, the time-temperature provisions are just one part of the rule.
The rule also calls for compost to be made from materials with a combined
C:N ratio between 25:1 and 40:1. This provision is justified on the basis
that this range "ensures" that conditions will generally be appropriate and
composting will proceed "with minimal producer oversight."  According to the
explanation given , a C:N ratio lower than 25:1 risks "putrefaction" and
higher C:N ratios (> 40:1) would fail to maintain temperatures above 131 F
for a long enough time. Quite frankly, I think that this is a load of
factory-farmed manure. The rule already requires
> composting at 131 F for prescribed time periods so regulating the C:N
ratio for that purpose is redundant. Furthermore it is inaccurate. While C:N
ratio is an important parameter, it is not CRUCIAL to the process or the
product. It neither ensures nor precludes heating or putrefaction (moisture
content is more important). Sure, C:N ratios ranging from 25:1 to 40:1 are
great. However, lower and, especially, higher C:N ratios are more than
workable, and often desirable (e.g. autumn deciduous leaves typically come
in at about 60:1). Lower C:N ratios can be undesirable due to ammonia
release to the environment but 25:1 is not the lower
> limit here, plus that's not the purpose of the rule anyway. Furthermore,
many, many farms composters operate at C:N ratios below 20:1, largely
because they cannot afford to purchase and handle amendments. Are these
windrows strictly aerobic? Nope, but few windrows are. Perhaps (?) a C:N
ratio guideline would be useful but this one is certainly too narrow.
>
> BUT, that's not even my main point. My main point is that, considering the
flaws, the compost part of the rule appears to have been assembled together
without a great deal of knowledge or research. It is almost as if someone at
USDA said: "Well we have to put something down so lets look in a book or ask
NRCS what to do." Having found the 25:1 to 40:1 recommendation in a book, or
in the NRCS standard, it must have seemed like a good idea to "put it down
." The resulting rule indicates that the USDA staff involved, including
NRCS, are unfamiliar with composting and how it is practiced -- on farms and
elsewhere. How can someone write a
> rule affecting several industries without knowing what they are writing
about?
>
> Rufus Chaney wrote:
>
> > Dear Colleagues:
> >
> > I thought a few comments may help clarify this issue, although in no way
am I contradicting the comments from Cary Oshins.
> >
> > Please recall that the rule is related to demonstrated pathogen kill,
not stabilization of compost or quality of compost from the usual view of
organic farmers. The verified demonstration that pathogens were transferred
from raw manure to organic vegetables and caused human disease was part of
EPA's reason for doing this rule. And the 503 composting practices needed to
kill pathogens to the extent required is well known from the literature.
There has been plenty of data to set these limits, and EPA is considering
requiring pathogen measurements in some cases rather than showing that the
time-termperature-turns met the requirement.
> >
> > I suspect many will be frustrated by parts of this rule. No one asked me
about any part of it. I don't know if other USDA staff were consulted by EPA
or their contractors in developing the text of the rule.
> >
> > I hope we can all agree that demonstrated pathogen kill in organic
amendments should be part of a rule for regulated organic farming standards.
> >
> > Rufus Chaney
> > USDA-ARS-Animal Manure & Byproducts Lab
> > Beltsville, MD
> > 301-504-8324
> >
> > >>> caryoshins@lehighcounty.org 01/22/01 11:52AM >>>
> > Having visited and worked on and with a fair number or organic farms
over
> > the past several decades, I am quite distrubed by the highly
prescriptive
> > nature of the definition of compost in the final rule.  Most toubling is
the
> > 5 turns in 15 days at >131 F requirement.  Except for the farms
following
> > the Controlled Microbial Composting Method of the Leubke's, I don't
think
> > any of them would have met that standard, and that includes all the
> > biodynamic farms.  Yet to claim that these farms would not meet organic
> > standards is ludicrous!  I'd like to see the research that backs up the
> > time/temp requirement.  I know that both Rodale Institute and Woods End
have
> > done reserach that showed that there was no difference in compost
quality
> > between minimally-turned compost and more-frequently-turned compost,
simply
> > a difference in how long it took to finish (and even that was not all
that
> > different).
> >
> > I will be interested in hearing how certifiers are going to react to
this
> > requirement.  Hopefully they will sensibly ignore it.
> >
> > Cary Oshins
> > Composting Specialist
> > Lehigh County Office of Solid Waste
> > caryoshins@lehighcounty.org
> >
> > _______________________________________________
> > Compost maillist  -  Compost@compostingcouncil.org
> > This list is a free service provided by and for members of the US
Composting Council.  For full posting privelages, individuals can join
through our website at:
http://www.compostingcouncil.org/member_application.html
> > For information on subscribing, unsubscribing, digest or other options,
go to:
> > http://mailman.cloudnet.com/mailman/listinfo/compost
> >
> > _______________________________________________
> > Compost maillist  -  Compost@compostingcouncil.org
> > This list is a free service provided by and for members of the US
Composting Council.  For full posting privelages, individuals can join
through our website at:
http://www.compostingcouncil.org/member_application.html
> > For information on subscribing, unsubscribing, digest or other options,
go to:
> > http://mailman.cloudnet.com/mailman/listinfo/compost
>
> --
> Robert Rynk
> JG Press. Inc. --
> BioCycle/Compost Science & Utilization
> 419 State Ave.
> Emmaus, PA 18049
>
> 610-967-4135;   fax: 610-967-1345
> email: rrynk@jgpress.com
>
> websites:
> www.biocycle.net
> www.inbusiness.org
>
>
>
> _______________________________________________
> Compost maillist  -  Compost@compostingcouncil.org
> This list is a free service provided by and for members of the US
Composting Council.  For full posting privelages, individuals can join
through our website at:
http://www.compostingcouncil.org/member_application.html
> For information on subscribing, unsubscribing, digest or other options, go
to:
> http://mailman.cloudnet.com/mailman/listinfo/compost
>