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Q&As on the requirements of PAS 100:2011
Question 1. I am working towards certification to PAS 100:2011 for my 0 – 40 mm compost grade. My composting process is already certified with PAS100:2005 (and the CQP). Do I have to undergo process validation all over again for PAS 100:2011 (with passes for all tests on three consecutive batches)?
Answer
A composter with an already validated, PAS 100:2005 certified composting process and compost grades would not have to undergo process validation again unless in the situation described in PAS 100:2011, clause 4.10.5:
‘If any non-temporary change occurs that affects compost quality, or if a non-temporary change in the required quality of compost occurs, the production process shall be re-validated (see 4.5). In the event of temporary change(s) of this kind, the composter shall sample and test the relevant compost grade(s) as appropriate for determining the effects of any such temporary change(s) on compost quality.
NOTE Types of change that affect compost quality are a matter of judgement, so are not specified in this PAS. If the composter has applied to a certification body for initial or renewal certification, an interpretation of the certification scheme rules can be sought.'
Unless the situation described in 4.10.5 applies, it will be sufficient simply to demonstrate that all documents have been updated and that the composter is now operating to the revised documents.
However, laboratory use of the E. coli method of test specified in the edition of PAS 100 the composter is being assessed against is important. In addition, the composter's 3 most recently sampled and tested batches would have to show compliance with PAS 100:2011's more stringent limits on total physical contaminants, plastics, and if a ‘mulch' grade the more stringent stones limit. In addition, the composter must have clearly stated his/her ‘sharps' policy for each PAS 100 compost grade and corresponding test results for each grade must demonstrate compliance with that policy [see also PAS 100:2011 Table 3's notes a) and e)].
With regard to the E. coli method of test, AfOR's article on transition from PAS 100:2005 to PAS 100:2011 can be found HERE.
Question 2. I am seeking guidance/clarification with respect to clause 20.4 of AfOR Compost Certification Scheme Rules Issue 1, Revision 3. The clause says that: Biodegradable polymers, bags, packaging or other products made of such material shall be allowed as input materials to the composting process if they have a valid certificate of conformity to the "compostable†criteria within BS EN 13432, BS EN 14995, DIN V 54900, ASTM D6400, or AIB-Vinçotte International S.A.'s ‘Program OK 2' criteria for "home compostable†packaging, plastics or equivalent. These scheme rules require that the valid certificate has been issued by an independent certification body.
Does this mean that if food/catering waste is supplied in biodegradable bags in an articulated wagon do we need to have a valid certificate of conformity for the bags from the supplier? Or, do I need to ask the supplier of the food/catering waste for a written declaration that the bags are indeed biodegradable and comply with BS EN 13432 (or similar)?
Answer
You or your waste supplier will need to check with the manufacturer of the ‘compostable' / ‘home compostable' bag / packaging products that these are independently certified to one of the relevant standards. If certified, these items must carry their product-specific certification code in addition to the ‘compostable' / ‘home compostable' conformity mark and the word ‘compostable' or ‘home compostable' (according to the product's scope of certification). In addition, the supplier of the bags should be able to supply the valid certificate issued by one of the relevant certifying bodies.
If you doubt that the bag / packing product is genuinely ‘compostable' / ‘home compostable', this can be investigated. AfOR can investigate the certification status of a specific bag / packaging product by looking up its certification code on the relevant certification body's list of certified products and checking this against the description of the certified item. If the bag / packaging product does not carry a certification code, it is likely that it hasn't been certified and is a fake.
AfOR has recently released guidance to clarify the confusion amongst compostable products and items. The guidance can be downloaded from HERE.
Please make sure your waste supplier is aware there is a requirement that the bags are independently certified ‘compostable' to BS EN 13432 or equivalent standard.
Question 3. The Standard Operating Procedures template state that ‘A site operative shall spread and inspect each load deposited at the storage area. The outcome of the inspection is recorded on the <Input Load Inspection Record Sheet>. A copy of the relevant part(s) input load inspection record sheet should be provided <specify frequency e.g. once per month> to each waste supplier.' Is it obligatory to use the 'Input load inspection record sheet'?
Answer
PAS 100:2011 requires inspecting each load of incoming material, but does not require recording each inspection. So, it is not obligatory to use the 'Input Load Inspection record sheet'. However, PAS 100:2011 does require that for each of any input material load or part-load rejected after delivery, a record is kept (see clause 6.1.10 of PAS 100:2011). Thus, it is obligatory at least to keep a record of any input materials rejected loads.
Question 4. Table 2 in the Standard Operating Procedures template (see below) specifies criteria for acceptance / rejection of input loads delivered, with corrective actions that shall be carried out if the load exceeds the specified criteria. Is it mandatory to use the criteria specified in the Table?
Answer
No, the score system described in the table is rather recommended by AfOR as good practice, particularly if you have problems with contamination in the feedstocks delivered to the composting site.
Keeping a record of the scores assigned to each input load delivered to the site will assist you in providing evidence of any contamination occurred and communicating any issues related to contamination to your waste supplier and the crews. This system also will help you to have clear and transparent acceptance / rejection criteria that can be specified in the contractual arrangements with your waste suppliers.
Question 5. PAS 100:2011 states that ‘the composter shall state criteria for the acceptance of input materials and rejection of unsuitable wastes/materials, based on the HACCP Plan. The criteria shall also require the input material supplier to demonstrate that all practicable measures have been taken to prevent contamination of input materials with unsuitable wastes/materials.' How can I demonstrate this?
Answer
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By specifying in your SOPs clear criteria for acceptance / rejection (mandatory);
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By effectively implementing such criteria on the site (mandatory);
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By keeping a record of all the communications with your waste suppliers related to contamination of input materials with unsuitable wastes/materials (mandatory);
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By rejecting input load materials if they exceed the acceptance criteria specified in your Standard Operating Procedures and in your contractual arrangements (mandatory);
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By keeping a record of the scores assigned to all input waste delivered to the site (recommended);
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By revisiting the contractual arrangements with your waste suppliers so that they include clearer provisions with regard to acceptance / rejection criteria and actions that will be taken if these are not met (recommended);
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If contamination occurs on a regular basis, by obtaining from the waste supplier evidence that shows which actions have been taken to prevent or reduce the contamination levels in the input materials (mandatory). Examples of such actions are:
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Re-educating the crews
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Revisiting the contracts with the crews (i.e. so that they are based on performances achieved in terms of feedstock quality);
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Improving the educational information that is provided to householders (e.g. waste collection leaflets, local authorities' websites, bins' labels /stickers)
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Reviewing the collections vehicle cleaning procedures, design and collection rounds logistics; and
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Implementing a ‘three strikes and you are out' policy.
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