[USCC] FW: Re: Fecal Coliform testing issues

Tue Nov 7 12:53:59 CST 2006

Tim,
HACCP system with the control points along the way you describe seems 
like a good system. The composter could take the temperature readings 
during the process and then test for fecal coliform at end of the heat 
cycle to varify the material was well mixed and heated throughout the 
pile. If it does not pass it is up to the composter to find a way to get 
the heat high enough and mixed so it will. As it is now the composter 
doesn't know where the problem is to even start work on it. It could be 
poor heating or poor mixing or even re-growth during the final stages of 
stabilization or curing - nothing to do with pathogen kill.

And, like what is happenng in my back yard with the E Coli scare, it 
should be the industry that regulates itself and sets the rules. That is 
what I thought the USCC would do because it is made up of all the 
players and has all the experience and expertise to establish a good 
system.  Its true, as Eliot says, we can do nothing about the EPA  
regulating biosolids compost at point of sale, but we do not need to 
require the other forms of compost to do the same and we can regulate 
metals lower than EPA and catch problems 'before' they happen. We can 
set our own rules. The USCC should set the industry standards, IMO  
Also, if we (UUSCC) believe E Coli 0157 could be a problem (like 
copyralid) we could require it be included in with the testing until it 
is shown to not be a problem, or need corrections before it becomes a 
problem. Last thing the industry needs is a problem with E coli 0157. If 
we don't take the lead someone that knows nothing about composting will.

Frank

Tim Evans wrote:

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>
>I hope the following helps in this discussion.  You still need a good FC
>methodology (including the whole sampling to lab chain) but ... 
>
>In the UK we have adopted HACCP (Hazard Analysis Critical Control Point) as
>the basis for treating organic residuals including biosolids [but not manure
>on farms].  Just one comment, if Walkerton had not convinced people, the
>recent O157:H7 spinach should have made people realise that the pathogen
>risk to humans from manure is much greater than from biosolids.  However,
>back to HACCP: it is a paradigm shift in that although you need output
>standards for the product from the process, you don't use end-of-pipe
>testing as the means of assuring compliance.  [Hazard Analysis and Critical
>Control Point (HACCP) for Composters.  ISBN 0-9532546-6-6 The Composting
>Association, Wellingborough, England]
>
>Until the early 1960s food quality was controlled by end-of-pipe testing.
>NASA questioned the wisdom of this for the manned space program - they did
>not want to risk food poisoning of astronauts when they are in space.  NASA
>realised that they knew the quality of the food they had [destructively]
>tested but not the food that was going into space so they asked the
>Pillsbury company to come up with something better, their answer was HACCP,
>which has become the international system for safety of food, it is
>maintained by FAO.  When those who treat organic residuals use HACCP they
>are talking the same language as those who buy produce from farms, which is
>a considerable advantage. 
>
>Basically, you look at what you are intending to produce and the hazards
>whose risks you want to control in the product(s).  Then at each step of the
>process, does it control the risk of one or more of those hazards and if so
>is there a possibility of by-pass or recontamination further down the
>process, if the answers to those questions are yes, no and no respectively,
>the process step is a critical control point (CCP) for that hazard.  The
>operating conditions for the CCP are set so that they control the risk of
>the hazard to whatever level is decided to be acceptable, the threshold
>conditions are called the Critical Limits (CL).  If the CCP always operates
>within its CLs then everything that goes through the CCP will have its risk
>controlled and by recording the operating conditions (preferably
>continuously) you have a record of control.  HACCP also requires you
>pre-plan corrective action for those times when conditions go outside the
>CLs.  Initially the process is 'validated' by end of pipe testing to
>determine that the CLs are correct, there's no by-pass, etc. and then the
>frequency of end-of-pipe testing is reduced because it is then
>'verification' that the CCPs and CLs are working - the primary proof of
>control has become the [continuous] record of the operating conditions.
>
>Some people in industries with a history of regulation find this difficult
>to get their heads around because they are used to being told by their
>regulators what to do; they want to be told what to do and then to do it at
>minimum cost (CATNAP).  They initially find HACCP a bit scary because
>essentially it says 'you are grown up, nobody is going to tell you how to do
>it, you work out a process, prove it works and then monitor its operation'.
>However, when they have the 'light-bulb moment' they realise the strength of
>HACCP and that it is a better paradigm. 
>
>regards
>
>Tim
>
>Dr Tim Evans
>TIM EVANS ENVIRONMENT
>Stonecroft, Park Lane, Ashtead, Surrey KT21 1EU England
>tel/fax +44 (0) 1372 272 172 mobile +44 (0) 7816 833 991
>tim at timevansenvironment.com
>
>
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-- 
Frank Shields
Soil Control Lab
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