[USCC] Making Compost Regulations

[frank]

David, and composters,

>From what I have seen there are three ways compost is regulated.

 The first is a sheet of paper handed to out that state all the 
materials (compost, lime, fertilizer etc.) and amounts that must be 
added at all projects. Doesn't matter what the soil pH already is or the 
crop or the make-up of the compost you just add that amount.

 The second method is restricting materials that exceed an upper or 
lower range (ex. EC5 must be below 10 or organic matter above 25%). This 
is nothing more than a definition of 'compost'. I agree with the 
definition approach but not restricting a product outside the range for 
purchase and use.

 The third is the End Use guidelines. What type of compost is best used 
for potting mixes,  mulches, berms or blankets. This has been tried over 
the years by many and found to seem simple at first but quickly so 
complex it is impossible and results are meaningless.

IMO all these types of regulations are -completely- meaningless without 
considering application rate and specific site conditions. They only 
serve as another hoop the compost producer and end user must jump 
through, while at the same time, trying to reduce inventory and 
establish optimum conditions.

  Problem is we labs generate so much information about the compost then 
hand all the results to the regulators and users. They have no idea how 
to use the data. So ignore all the results or pick out just a few of the 
numbers and regulate them without considering their connection with 
other numbers.   

 There is a better way:

I suggest the regulators need to stick to health and environmental 
safety and, once those conditions are meet, let the grower make the 
decisions as to how much and what product is needed.  Phosphorus 
applications to sensitive areas around water, special restrictions for 
materials used on playgrounds, the definition of what can be called 
'compost' all need to be regulated.  

 Before the grower can make good decisions about how much and type of 
material to use we (USCC) need to take the lab data produced and, via 
grouping and interpreting, provide the grower with information (not 
numbers) about the product. I started working on this when in the S & P 
committee before they went in the End Use direction and then I worked 
with the  CaDOT group until they went off in their direction of 
restricting upper and lower ranges in connection with End Use. There 
needs to be more work on this but I have already done a lot, what I can 
without help.

I suggest about ten characteristics about each product is enough. 
Growers need to know if a product is, or is not a good nutrient source 
or if it is a high or low organic source, stable or has high carbonates. 
I picture a sheet of paper that has on it a check list that the DOT 
foreman, while looking over a site; the slope, soil type, water, plants 
etc. make  check marks listing characteristics of materials he wants to 
use to do what he wants done. Then goes out and finds, or have 
formulated, that type of material needed.

Not being able to do this with USCC and again with CaDOT has been a bit 
of a disappointment for me because I think it is the direction we need 
to go.

Frank

Schellinger, David A. wrote:

>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 
>
>
> Frank,
>To trust that an individual grower or foreman for the construction
>project has the necessary background to use materials properly is asking
>for trouble.  The state environmental engineers should make the call on
>what materials are suitable to stabilize banks, reduce erosion, filter
>sediments, etc., and not the foreman or growers.  Keep in mind that road
>construction is a state project and is only performed by contracted
>construction companies.  Generally speaking, aside from soil specific
>factors that would regulate application rates and particle sizes used,
>the base requirements for specific end uses would probably be very
>similar in nearly all cases anyway.  
>
>More often than not, the vegetation specialists used on construction
>projects have never used any other material other than typical straw
>mulch, hydro seeding or some variation of erosion mat to stabilize
>slopes to be seeded.  Using composted materials not intuitive to all as
>one might expect.  Environmental considerations are required to assure
>that contaminants and sedimentation are minimized from these locations.
>
>
>Trust that the state environmental engineers may be more capable of
>determining the appropriate standards of materials and application
>rates.  If the contractors adhere to the prescribed application of
>materials, adverse environmental results from improper use of materials
>should be minimized.  
>
>Dave Schellinger
>W. A. Callegari Environmental Center  
>
>
>Compost huggers and regulators;
>
>Most regulations first list 'uses', then list the requirements the
>compost must meet for that use.
>
>IMO this does not work because each 'use' (mulch, top dress, soil
>application, potting mix, etc) has many different requirements based on
>things like; receiving soil, slope, climate, plants, other materials in
>the mix ...and many more.
>
>What should be done:
>Compost should be put into groups based on test results:
>1) High -to- low nutrient provider
>2) High -to- low salts (EC)
>3) woody -to- high organic -to- medium organic -to-  low organic -to-
>soil-like
>4) Stable -to- unstable
>5) High -to- low carbonates
>6) High -to- low C/N ratio
>7) high -to- low size distribution
>8) ......
>
>Let the GROWER, the DOT foreman, the one trained to stabilize a bank or
>grow a pine tree; the one who knows what TYPE of material is needed and
>HOW MUCH is needed for a specific site make the decisions. They are not
>stupid and they know more than the regulators do about what is needed at
>a specific site because there are so many on site variables and they get
>to look at the site. From experience they know what works. If they want
>to keep their job they will do the right thing so they can be TRUSTED. 
>And let the composters provide them with a wide variety of materials to
>work with. In fact let them provide the COMPLETE RANGE of materials in
>the list above. The feedstock of each compost facility will determine
>the type of material they can provide. And they will formulate for the
>best market - but let them sell ALL.
>
>  
>

-- 
Frank Shields
Soil Control Lab
42 Hangar way
Watsonville, CA  95076
(831) 724-5422 tel
(831) 724-3188 fax
frank at compostlab.com
www.compostlab.com