PAS100 revision - Update March 2018
BSI and REAL initiated a revision of PAS100 - Specification for composted materials back in summer 2017. The revision process has involved stakeholder engagement, a public consultation and review panel and steering group discussions. ORG have contributed on behalf of our members (through consultation with them) at every stage of the process. More info here on our consultation response and members' views. More info on the revision process can be found here.
The final steering group meeting took place earlier this month and general consensus was achieved on many of the issues. It is important to remember that with the many different stakeholders involved, changes to PAS100 will be a compromise. It was clear from the start of the process that some changes (i.e. particularly for changing limit levels) would require to be justified by robust evidence in order to be accepted by stakeholders.
During the consultation process, a market led approach for compost quality limits was suggested and discussed at length during the review panel meetings. After much discussion, it was finally agreed that there would be no changes to tables 3 and 4 - the minimum compost quality and these would remain as they are in the current version. This was mainly due to insufficient evidence and research to fully justify the changes.
There was also a great deal of discussion about a proposal to introduce independent or witnessed sampling for every sample taken for certification purposes. The steering group agreed that this would not be taken forward at this time and the current arrangement of spot checks and random independent sampling would be maintained. It may be that a future revision of the scheme rules will require an auditor to observe the sampling procedure.
The below summaries the main changes to PAS100:
- Some definitions updated and definition of customer added.
- There is a new clause regarding compost being fit for purpose and the compost producer agreeing (in writing) with the customer any additional or more stringent parameters than in tables 3 and 4.
- The HACCP section has be re-written to reflect advice from HACCP experts and to extend the requirements to consider hazards affecting quality as well as safety.
- Requirement to have an index of Quality Management System documents.
- Requirement for input materials to be checked against acceptance criteria (and rejected if not within acceptance criteria).
- If using automated monitoring equipment on insulated aerated static piles, the monitoring point must be moved on every monitoring occasion.
- Frequency of testing can either be measured in cubic metres (as currently) or in tonnes.
- Additional recommendations for soil sampling.
There are two outstanding issues to be resolved following the steering group meeting and these will be discussed separately with those raising them and the conclusions and proposals circulated to the steering group.
The project team are working on the final draft, and this will go out to members of the steering group (Jeremy Jacobs sits on this on behalf of ORG) for a short consultation. Following this, BSI will work on formatting etc and the new version of the standard is likely to be published in the next 3 months. There will be a transition period of at least 6 months for operators to comply with the new requirements, details of this are still to be confirmed.
ORG will inform members as soon as the final version is published, we are also planning to host a webinar to outline the changes, if you are interested in attending this, please let Jeremy know.
For more details on any of the above, please contact Jeremy.
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