EA responds to ORG questions on Compost stability and End of Waste
The Environment Agency has responded to a request from REA Organics Recycling Group for clarification of their expectations on compost stability with a view to establishing their requirements prior to potential review of PAS100.
Clarity sought on stability requirements
Earlier this year, at the request of some members ORG was considering initiating a review of the PAS100 specification. We have invited and reviewed members’ opinions, reported on these at the most recent ORG Sector Group meeting on 2nd October and have discussed the revision process and likely costs with BSI.
We have sought clarity from the regulators on a number of questions around compost stability in PAS 100 (particularly on what is the purpose of including a test for compost stability and an associated threshold), whether the plant response test would be a suitable alternative to the stability test, and whether there are any other requirements that we should be aware of for compost to achieve End of Waste status.
Compliance with PAS 100 (and the compost Quality Protocol in UK countries other than Scotland) is required by regulators when producers want to demonstrate compliance with End of Waste. Regulators also control what is required in their End of Waste positions, including which standards or PASs must be complied with. Consequently it is very important for us and industry to understand what regulators expect from a review of PAS 100.
The EA has highlighted the importance of a comparator material and that where industry would like to change specific aspects of PAS 100 this should be clearly justified and linked to a specific, relevant comparator material that has been agreed with them.
The EA will require the inclusion of a stability threshold and can see no viable alternative to it. They believe that plant response testing is a good indicator that compost is fit for purpose, but it is not necessarily the best or only indicator that compost biodegradable wastes have been fully recovered.They also said that without relevant comparison or significant risk assessment/justification, they do not think the heavy metals limits should be revised upwards and may even like to see them tightened.
How we will take this forward
There are ongoing discussions on the revision of the EU Fertilisers Regulation, which is likely to contain proposals for End of Waste criteria for composts and digestates (more info HERE). If it does, PAS100 as the basis of our End of Waste position is likely to be superseded (national provisions required to give way to EU provisions where both have the same scope). As a result any further PAS related research or work on our part will be influenced by what happens at EU level next year. We feel that the review of PAS100 is only justifiable if the revised EU Fertilisers Regulation does not include End of Waste criteria for composts. We will consider the EA's feedback in due course and will continue to liaise with them.
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