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Update on the PAS 110 review
ThereâÂÂs been a lot of discussion recently around the PAS 110 and we are grateful for the input we have had from members.
ThereâÂÂs been a lot of discussion recently around the PAS 110 and we are grateful for the input we have had from members.
Residual Biogas Potential (RBP) and timescales for the review
The current position of the regulators is that the Residual Biogas Potential/RBP (or an equivalent test) is required to demonstrate âÂÂfull recoveryâ i.e. that material has not been pushed quickly through the system without being recovered and equivalence with a virgin comparator. At the moment there doesnâÂÂt appear to be another test method that meets the same objectives or, if there is one, more R&D work would be required in order to set an appropriate threshold.
In order to make progress before the next formal PAS 110 steering group, an informal meeting of the Steering Group was held on 24th October, which was attended by REA and other trade bodies. At the meeting it was highlighted by the attending trade bodies and operators that if more time had been available in this review, AD operators would have favoured a replacement of the RBP method with a cheaper and shorter one. However, given the considerable delay this review has already been subjected to, in order to avoid further delay, we are now left with no choice but supporting a retention of the current test method and a refinement of its limit level to a more appropriate level.
The current position of the regulators is that the Residual Biogas Potential/RBP (or an equivalent test) is required to demonstrate âÂÂfull recoveryâ i.e. that material has not been pushed quickly through the system without being recovered and equivalence with a virgin comparator. At the moment there doesnâÂÂt appear to be another test method that meets the same objectives or, if there is one, more R&D work would be required in order to set an appropriate threshold.
In order to make progress before the next formal PAS 110 steering group, an informal meeting of the Steering Group was held on 24th October, which was attended by REA and other trade bodies. At the meeting it was highlighted by the attending trade bodies and operators that if more time had been available in this review, AD operators would have favoured a replacement of the RBP method with a cheaper and shorter one. However, given the considerable delay this review has already been subjected to, in order to avoid further delay, we are now left with no choice but supporting a retention of the current test method and a refinement of its limit level to a more appropriate level.
A formal proposal to refine the current RBP limit level in the PAS 110 will be submitted to the environmental regulator by the PAS 110 Steering Group. At the time of writing the proposal is being prepared by REA in conjunction with ADBA and ADOWG. In parallel, the PAS 110 appointed technical author has started the redrafting of the PAS 110 specification. Please contact Kiara at REA if you wish to see a copy of the draft proposal (07717 294793, kiara@r-e-a.net).
Please note that in addition to requesting a refinement of the limit level and a change of the virgin comparator from cow to pig slurries, our proposal includes the addition of a clause to the PAS 110 specification that enables âÂÂnovel approachesâ to be followed. The proposed text of the new clause is: "the competent authority (e.g. the regulator) may approve an alternative test that achieves their objectives". This clause should facilitate the addition of an alternative test in the future and the development of new tests which are shorter and cheaper than the current RBP. This test is expensive and time consuming and replacing it is widely supported by the industry; allowing for an equivalent alternative has the advantage of avoiding a long wait for a full review of PAS110.
Subject to the approval of the steering group, the draft will then be sent out for a 4 week consultation process. This should happen well before Christmas.
Pasteurisation
The members of the Steering Group who attended the meeting on 24th October were supportive of exempting co-operatives from the pasteurisation, as long as a robust definition of co-operative is given in the PAS 110. These members were also supportive of including a phytohygiene validation regime in PAS 110 to allow relevant facilities to adopt novel time/temperature regimes that are not currently listed in Annex A of PAS 110.
The final recommendations made by the whole PAS 110 Steering Group at the next formal meeting at the end of November will hopefully confirm the above positions.
PTEs limit levels
The members of the Steering Group who attended the meeting on 24th supported the setting of new PTE limits for digestates on a fresh weight basis. The final recommendation made by the whole PAS 110 Steering Group at the next formal meeting will hopefully confirm this position.
Other aspects of PAS 110
Other aspects such as physical contaminant limit levels, test method for determining PTE concentrations, sampling point and sampling/testing regime were discussed at the meeting on 24th. If you wish to receive an update on these aspects or a clarification on any of the aspects above, please do not hesitate to contact Kiara (07717 294793, Kiara@r-e-a.net).
Please note that in addition to requesting a refinement of the limit level and a change of the virgin comparator from cow to pig slurries, our proposal includes the addition of a clause to the PAS 110 specification that enables âÂÂnovel approachesâ to be followed. The proposed text of the new clause is: "the competent authority (e.g. the regulator) may approve an alternative test that achieves their objectives". This clause should facilitate the addition of an alternative test in the future and the development of new tests which are shorter and cheaper than the current RBP. This test is expensive and time consuming and replacing it is widely supported by the industry; allowing for an equivalent alternative has the advantage of avoiding a long wait for a full review of PAS110.
Subject to the approval of the steering group, the draft will then be sent out for a 4 week consultation process. This should happen well before Christmas.
Pasteurisation
The members of the Steering Group who attended the meeting on 24th October were supportive of exempting co-operatives from the pasteurisation, as long as a robust definition of co-operative is given in the PAS 110. These members were also supportive of including a phytohygiene validation regime in PAS 110 to allow relevant facilities to adopt novel time/temperature regimes that are not currently listed in Annex A of PAS 110.
The final recommendations made by the whole PAS 110 Steering Group at the next formal meeting at the end of November will hopefully confirm the above positions.
PTEs limit levels
The members of the Steering Group who attended the meeting on 24th supported the setting of new PTE limits for digestates on a fresh weight basis. The final recommendation made by the whole PAS 110 Steering Group at the next formal meeting will hopefully confirm this position.
Other aspects of PAS 110
Other aspects such as physical contaminant limit levels, test method for determining PTE concentrations, sampling point and sampling/testing regime were discussed at the meeting on 24th. If you wish to receive an update on these aspects or a clarification on any of the aspects above, please do not hesitate to contact Kiara (07717 294793, Kiara@r-e-a.net).
Last update: 05/11/2013
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