Following protocol: how to climb in status
Gaining certification for your product under the Quality Compost Protocol scheme need not be a struggle if you know what is required. Katie Owens offers pointers
The introduction of the Quality Compost Protocol (QCP) in 2007 marked a major shift in attitudes to composting, allowing the end results of the process to be seen as a product, rather than a waste. This is good news in many ways. More organisations are now taking advantage of this and gaining certification for their compost under the Composting Association’s PAS 100 and QCP scheme.
The certification provides evidence that the composter has established an effective management system for producing quality compost. Being able to label it as a product, and not a waste, removes waste regulatory controls on its storage and use. But what is involved in achieving the QCP and obtaining that all-important certificate?
Due to the rapid growth in participating compost producers, the Composting Association contracted two experienced certification bodies to assess producer
compliance with PAS 100 and QCP. The first of these companies to award a certificate under the new arrangements was Organic Farmers & Growers (OF&G), which has been operating certification for organic food, farming and other products since the early 1990s.
In almost a year of providing the inspection and certification service, a number of lessons have been learned by OF&G, which would be valuable to any compost producer planning to join the scheme. Ensuring the application and inspection process runs smoothly is in everyone’s interest, particularly the applicant – especially if they have a deadline to meet for certification.
Think before rushing in
Our best advice is to read the guidance clearly and ensure you understand what is required before you begin the process. Some of the paperwork will need to be adapted to suit the
setup of your operation. For instance, the template batch monitoring record sheet puts four monitoring points at 10, 20, 30 and 40m. PAS 100 requires one monitoring point per each 250m3 of composting material in a batch. If your windrows are not large enough for this, change the numbers to suit your operation.
We find that a lack of thinking and planning of this kind leads to the majority of the non-compliances we identify. Correcting the non-compliances is a delay that can be avoided. Also, make sure you understand the full costs involved. While certification should pay off in the short term, you must consider not just the certification fees, but the cost of the required laboratory tests as well.
Although templates are provided for all the documents that have to be completed, make sure they are properly adjusted to the requirements of your site. For example, the Hazard Analysis and Critical Control Points contain a reference to physical contaminants. Producers should enter, in standard operating procedures, the trigger level for rejection of an input material delivery if it contains physical contaminants.
The importance of sampling
Ensure that samples for your tests are taken when your compost is ready to sell, as soon as the minimum composting process has been completed. If the earliest you would sell it is at eight weeks, sample and send it for testing during the ninth week. Do not wait on windrow sampling just so you can send three together. This is because samples are required from the earliest point the compost is ready to sell or leave the site.
Basic organisation helps no end. Make sure all the paperwork is to hand at inspection time and that you know your way around it – which bits relate to which parts of the application and your operation. Also, run through in advance to be sure that the paperwork links clearly to the reality of working practice on site.
In addition, make sure your batch numbers are clear on your windrows and they link to the paperwork. If you are supplying to agriculture, or soil-grown horticulture, make sure you know how to use the web-based tool (for England and Wales only), or its equivalent Excel spreadsheet version, and that you have evidence of this – a computer available with internet access and the ability to demonstrate your usage of the system.
When an inspection is completed, the report is sent to the certification body, where a certification officer assesses it. When a compliance notice is sent out requiring corrective action, an applicant for initial certification has three months to address all of the issues and respond.
Certified compost producers inspected in a 12-month renewal phase have two months to respond to the compliance notice. In both cases, a certificate will not be issued or renewed until all matters are dealt with.
Remember, the process is nothing to be feared. It is logical and straightforward, as long as applicants apply themselves to it and do not treat it as an afterthought, or an unimportant paper exercise. The benefits should far outweigh the effort and we are always on the end of the phone to give support on the process or certification and making or renewing applications.
Katie Owens is a certification officer at Organic Farmers & Growers
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