[USCC] Vol 29, #9--Regulation by various agencies

Wed Aug 9 20:47:57 CDT 2006

U.S. COMPOSTING COUNCIL 15th ANNUAL CONFERENCE AND TRADESHOW Wyndham Orlando
Resort | Orlando, FL | January 21-24, 2007 The National forum for those
involved in the development and expansion of the composting and organics
recycling industry CONFERENCE PROGRAM, REGISTRATION FORMS, WORKSHOP AGENDAS,
EXHIBITOR INFORMATION AND SPONSORSHIP OPPORTUNITIES ARE AVAILABLE AT THE
USCC WEBSITE: www.compostingcouncil.org OR CALL THE USCC AT 631-737-4931 

Hey Frank,

The way I see it, the reason there are so many concerns about facility
adherence to the regulatory frameworks is because the regulations do not
accurately reflect what is occurring in the processes (you know, it looks
good on paper).  It is not as difficult to compost other feedstocks and
achieve PFRP temperatures as it appears to be when facilities mix woody
debris with biosolids and expect to consistently reach the desired
temperatures over the prescribed time period.  If other feedstocks were also
applied to this process, perhaps there would be an improvement, supporting
your idea of adding biosolids as a "tag along" feedstock in other composting
processes.  But, regulations would likely require permitting even for such a
small addition.  This may be a blessing in disguise.  I have often
questioned whether there should be standards regulating process management
to improve compost quality rather than to expect voluntary changes that
would improve quality of products. 

As scientists we all work to help improve the industry, but we still need to
be cognoscente of the effects that any changes would have on the current
situation.  Improving temperature data collection patterns and methods would
be an excellent way to start looking for solutions to the current dilemma,
but I suspect that a single reading taken at a specific depth will not
improve upon the current situation.  When I apply scientific and statistical
principals to this situation I find that; 1) an average of two or more
temperatures will always provide more accurate data than a single
observation, and 2) a single temperature reading at any spot in a compost
pile may not accurately reflect the highest temperature at that location.

I must conclude that averaging multiple temperature readings at a single
location would provide better results than a single reading. It may take
more time to collect temperature data at multiple depths, but it would
definitely improve upon the current situation.  

Part of the science behind the problems associated with composting biosolids
should be determining the fates of the more recalcitrant materials that may
be found in treated biosolids.  Even though many of the contaminant levels
will be extremely low after secondary treatments, it is in the best interest
of the biosolids composting industry to know that the materials they sell
will not pose a significant threat to the health of people who use or come
in contact with the end product.  If human health issues were not important,
there would be no need for regulatory framework for the use and disposal of
biosolids.  That is why I keep bringing up the issue of potential
contaminants, so we don't lose track of the reasons for the analyses we do
perform on composts and especially on biosolids compost.  I urge more
stringent analytical testing.

Reading the following literature it became evident to me that most
time/temperature data come from research that examined the destruction of
pathogens in the minimal amount of time, rather than focusing on the minimal
temperature relative to the time required for pathogen kill.  The research
in this document examined the temperature necessary to reduce pathogens ten
fold (logarithmic reduction). Some research expressed in this document was
based on pathogen reduction during biosolids composting that shows some
pathogens can be killed effectively in short periods of time at even 121
degrees C.  Keep in mind that this literature does not provide data on all
of the organisms at all temperature regimes, but appears to show a potential
for pathogen reduction even at 10 degrees below PFRP temperatures.  Also
stated in this literature, ammonia, competition for resources by other
microorganisms and resource availability play a significant role in pathogen
reduction.  With additional research as you suggest, there is not reason to
believe at this time that composting biosolids at lower temperatures for
longer periods may not provide a more reasonable way to reduce pathogens
without major reconstruction of the regulatory framework or the composting
processes.  This concept is definitely worth a study or two. 

TetraTech, Inc. ISG/E&A Environmental Consultants, Inc. 2001.  RESEARCH
CONCERNING HUMAN PATHOGENS AND ENVIRONMENTAL ISSUES RELATED TO COMPOSTING OF
NON-GREEN FEEDSTOCKS.  Oregon Department of Environmental Quality #38600.

Dave Schellinger

Alternatives, L.L.C.

Compost maillist  -  Compost at composter.com

Ongoing Sponsors of the USCC Discussion list are:

Food Industry Environmental Network (FIEN), a regulatory and policy e-mail
alert service for environmental, food and agricultural industry
professionals.

Contact Jack Cooper 301/384-8287 JLC at fien.com --- www.fien.com

Renewable Carbon Management, LLC with the containerized, in-vessel NaturTech
Composting System www.composter.com rcm at composter.com

Non-members of USCC are encouraged to join the Council through our website
at: http://www.compostingcouncil.org/membership.cfm     For discussion list
policies and information regarding subscribing, unsubscribing, digest or
other options, go to:http://mailman.cloudnet.com/mailman/listinfo/compost

For additional help in unsubscribing or to report bugs and problems, send a
message to the List Manager, Jim McNelly, at compost-owner at composter.com 