HACCP ANALYSIS Approved by: <insert name> Issue 1. Issued: <insert date> This document is a template aimed to guide you through the process and provide the relevant information for compliance with BSI PAS 100:2005 and the Compost Quality Protocol. Read through this document, insert text where prompted and amend any part of the standard text so that it is appropriate to your biowaste inputs, composting process and compost outputs. Delete this instruction text. Please delete any reference to the Compost Quality Protocol if you seek certification to ‘PAS 100 only’. Association for Organics Recycling template info Issue 1 Revision 2 Issued: 14/01/2010 Issued by: AFOR COMPANY DETAILS AND RESPONSIBLE PERSON 1. Company name, address and telephone number <insert here> 2. Composting facility name, address and telephone number <state ‘As above’ or insert here if different> 3. Person with overall responsibility for compliance with BSI PAS 100:2005, the Compost Quality Protocol and the Association for Organics Recycling’s Compost Certification Scheme <insert name and position> Guidance: This is the person responsible for filling in, checking and issuing the compost quality management system documents, for ensuring the procedures are implemented and necessary records are kept, and for communicating with the certification body. HACCP FOR COMPOST PRODUCTS MADE FROM ‘GREEN WASTES’ BY OPEN-AIR, TURNED WINDROW COMPOSTING 1. Principles of the HACCP System The HACCP system consists of the following seven principles: PRINCIPLE 1 © The Association for Organics Recycling 2010 Page 1 of 8 Issue 1. Issued: <insert date> HACCP ANALYSIS Approved by: <insert name> Conduct a hazard analysis. PRINCIPLE 2 Determine the Critical Control Points (CCPs). PRINCIPLE 3 Establish critical limit(s). PRINCIPLE 4 Establish a system to monitor control of the CCP. PRINCIPLE 5 Establish the corrective action to be taken when monitoring indicates that a particular CCP is not under control. PRINCIPLE 6 Establish procedures for verification to confirm that the HACCP system is working effectively. PRINCIPLE 7 Establish documentation concerning all procedures and records appropriate to these principles and their application 2. HACCP analysis specific to composting process For each hazard, the composting process has been worked through step by step to identify: whether there is a step that controls the hazard; whether it is a Critical Control Point (CCP) for that hazard; the operating limits (Critical Limits) for the CCP that will control the risk of the hazard; how the CCP can be monitored; what can be recorded to show that it has been operated effectively; corrective actions for if something is found to have gone wrong; and measures for verifying that the CCP is operating effectively. All personnel whose activities affect compost quality or hazards and other items covered in Table 1 are appropriately trained. Accordingly, table 1 does not include such training, either as a control measure or corrective action. This HACCP assessment must be reviewed as part of the annual management review (see the quality policy and process control document). The review must include; changes in customers’ needs, processing technologies, input materials, and any new hazards that emerge. © The Association for Organics Recycling 2010 Page 2 of 8 Issue 1. Issued: <insert date> HACCP ANALYSIS Approved by: <insert name> Table 1. HACCP Analysis Process step Hazards Control measures Critical limit Monitoring procedures Reception of ‘green waste’ and compost screening Objectionable compost appearance or damage to equipment for handling, mixing or applying compost due to excessive contamination with; 1. plastic, 2. glass, 3. metal, 4. concrete and consolidated mineral fragments (e.g. rocks and stones), and 5. other non-biodegradable items. Input load only accepted if most of any physical contaminants (litter/contrary material) are removed prior to composting. Checks that site personnel visually inspect every input load delivered. Hazards Process step Reception of Physical injury those ‘green waste’ handling product due to presence in compost of; 6. sharps Litter/contrary material on the surface of each load accepted does not exceed the percentage limit stated in the SOPs (see guidance in SOPs). Corrective action Record If CL is exceeded, reject load. If within CL, accept load and remove sufficient physical contaminants to Contracts / ensure that screened agreements with compost (all particle size ‘green waste grades) complies with PAS suppliers re sources limits and contains no and quality. hypodermic needles. Use screen mesh with Checks that site smaller apertures and/or personnel inspect change screen speed every load (update SOPs accordingly). delivered. Compost known or Screen mesh has suspected not to comply suitably sized dealt with as per SOPs. apertures. Record of whether load is accepted or rejected, and if latter, reasons for rejection. Control measures Critical limit Monitoring procedures Record Input load only accepted if most of any physical contaminants (litter/contrary material) are removed prior to composting. Checks that site personnel visually inspect every input load delivered. All composted material screened as per SOPs. Compost screening. Litter/contrary material on the surface of each load accepted does not exceed the percentage limit stated in the SOPs (see guidance in SOPs). No hypodermic needles. Removal of any hypodermic needles found present. © The Association for Organics Recycling 2010 Corrective action If CL is exceeded, reject load. If within CL, accept load and remove sufficient physical contaminants to Contracts / ensure that screened agreements with compost (all particle size ‘green waste grades) complies with PAS suppliers re sources limits and contains no and quality. hypodermic needles. Compost known or suspected not to comply dealt with as per SOPs. Page 3 of 8 Verification / Comment Compost test results do not exceed physical contaminant (plastic, glass, Records of metal, other communications with consolidates) ‘green waste’ suppliers. upper limits in BSI PAS 100:2005. Records of product No hypodermic preparation. needles reported present. Records of any complaints from compost users or those in the compost supply chain. Record of whether load is accepted or rejected, and if latter, reasons for rejection. Verification / Comment Compost analysis shows absence, or negligible incidence, of sharps. No Record of hypodermic communications with needles reported ‘green waste’ suppliers. present. Records of any complaints from compost users or those in the compost supply chain. HACCP ANALYSIS Approved by: <insert name> Issue 1. Issued: <insert date> Table 2. Continued Process step Hazards Control measures Critical limit Monitoring procedures Corrective action Reception of Toxic effects on ‘green waste’ animals or humans resulting from direct ingestion of compost or via food or fodder; and/or toxic effects on the environment due to; 7. wood treated with preservatives, 8. plant materials treated in the same growing season with composting-resistant herbicides, pesticides or insecticides, 9. plant materials from ‘heavy traffic’ highways. Re 7: Visual inspection, rejection of load, or acceptance of load followed by removal of treated wood. Re 8: Acceptably low risk (diversity of sources and dilution with cleaner inputs); control measures unnecessary. Re 9: Acceptably low risk due to dilution with cleaner inputs; control measures unnecessary. Re 7: Absent. Re 7: Checks that site personnel inspect every input load delivered. Re 7: Compost from windrows known or suspected not to comply dealt with as per one of options in SOPs. Green waste supply agreements, contracts, communications with suppliers, and any other documents providing instructions or feedback Re 7, 8 and 9: remind staff on these topics. and suppliers of the policy, contract arrangements and control measures; cease accepting loads from a particular source if contamination is known to have occurred repeatedly and supplier has not attempted corrective action or action has been ineffective. Re 7 and 9: Compost analysis shows compliance with PTE (heavy metals) in BSI PAS 100:2005. Re 8: Plant response to compost when tested at laboratory shows no abnormalities and germination and growth performance exceeds minimum in BSI PAS 100:2005. Process step Control measures Critical limit Monitoring procedures Corrective action Verification / Comment Hazards Reception of Spread of weeds as a ‘green waste’ result of using compost due to; 10. weed propagules (e.g. weed seeds and other plant parts that regrow) in compost (those species that may survive good practice composting). Re 8: Not present in significant quantity. Re 9: Not present in significant quantity. Visual inspection of Japanese Knotweed each input material absent from all input loads load for Japanese accepted for composting. Knotweed. Reject and send any loads that contain it to a licensed landfill. Record Verification / Comment If accepted load was Contract and records of Compost analysis subsequently found to have communications with shows compliance contained Japanese ‘green waste’ suppliers. with plant knotweed, composting propagule (weed batches containing it are Record of load parts) limit in BSI disposed in a licensed rejection. PAS 100:2005. Checks that site landfill. No Japanese personnel inspect Improve thoroughness of Records of any Knotweed in every input load load inspection checks. complaints from compost, visible delivered. If Japanese knotweed compost users or those from on-site found in a compost batch, in the compost supply checks or reported Visual checks of the entire batch is disposed chain. by laboratory. compost quality. in a licensed landfill. Guidance: Under Schedule 9 Part II of the Wildlife & Countryside Act (1981) it is an offence to plant, or otherwise cause to grow, Japanese knotweed in the wild. It does not qualify for exemption of Section 34 of the Environmental Protection Act 1990, but is considered as controlled waste. © The Association for Organics Recycling 2010 Contracts / agreements with green waste suppliers re sources and quality. Record Page 4 of 8 HACCP ANALYSIS Approved by: <insert name> Issue 1. Issued: <insert date> Table 3. Continued Process step Hazards Control measures Critical limit Monitoring procedures Corrective action Record Verification / Comment Actively Managed Composting phase (sanitisation and stabilisation) Plant disease as a result of using compost due to; 11. plant pathogens in compost (those species that may survive good practice composting). Guidance: Research indicates that BSI PAS 100:2005 recommended composting conditions for the sanitisation phase eradicates most plant pathogens (with the possible exception of Tobacco Mosaic Virus). Suppliers asked to exclude plant materials known or suspected to contain such plant pathogens, where possible. Resistant plant pathogens absent. Checks that plant input material suppliers appropriately instructed, and compost users and those in the supply chain warned if necessary. Resend instructions and warnings, clarify if necessary. Remind staff and suppliers of the policy, contract arrangements and control measures. Cease accepting loads from a particular source if contamination is known to have occurred repeatedly, (especially with Tobacco Mosaic Virus) and supplier has not attempted corrective action or action has been ineffective. Records of any complaints from compost users or those in the compost supply chain. Plant response test to compost carried out as per BSI PAS 100:2005, shows absence of plant disease – suitable verification for plant species with same disease susceptibilities as tomato plants. No incidences of plant disease as a result of compost use, reported by end users. Process step Hazards Control measures Critical limit Monitoring procedures Corrective action Record Actively Managed Composting phase (sanitisation and stabilisation) Plant disease and spread of weeds as a result of using compost due to; 12. plant pathogens and weed propagules in compost (those species unlikely to survive good practice composting). Composting conditions and duration sufficient to kill or reduce plant pathogens to within acceptable levels. Sanitisation phase: temperature and moisture levels and turning frequency as per SOPs. Monitoring of composting conditions (temperature, turns and moisture) as specified in SOPs. For batches which are near to completion of composting: if records show deficiencies or compost is suspected not to comply with PAS limits (see verification) it will be dealt with as per SOPs. For batches starting / inprogress, adjustment according to operator experience - of C:N and porosity of shredded mix, windrow size, windrow shape, water added, frequency of turning etc (as per SOPs). Composting windrow record sheet and evaluation sheet. Compost users and those in compost supply chain warned. Stabilisation phase: minimum duration of composting and number of Results of turns as stated in SOPs. monitoring equipment calibration (see SOPs). © The Association for Organics Recycling 2010 Page 5 of 8 Records of any other corrective actions carried out. Verification / Comment Compost analysis shows: 1. compliance with plant Records of propagule maintenance and (weed parts) calibration of monitoring limit in BSI equipment. PAS 100:2005; 2. absence of Records of any disease in complaints from plant response compost users or those test in BSI PAS in the compost supply 100. chain. HACCP ANALYSIS Approved by: <insert name> Issue 1. Issued: <insert date> Table 4. Continued Process step Hazards Actively Managed Composting phase (sanitisation and stabilisation). Process step Critical limit Monitoring procedures Corrective action Record Verification / Comment Human or animal Same as for 12. disease as a result of infection from contact with compost due to; 13. human and animal pathogens in compost (those species unlikely to survive good practice composting). Same as for 12. Same as for 12. Same as for 12. Same as for 12. Compost analysis as specified in BSI PAS 100:2005: Maximum of 1000 CFU g-1 E. coli; Salmonella spp absent in 25 g. Hazards Critical limit Monitoring procedures Corrective action Record Verification / Comment When liquor is added to windrow. Windrow to repeat Composting windrow sanitisation phase or dealt record sheet and with as per another option evaluation sheet. in SOPs. Compost carrying Actively pathogens due to; Managed Composting 14. pathogens in liquor phase (leachate plus (sanitisation rainwater run-off) and applied to windrows stabilisation) after sanitisation phase. Control measures Control measures Composting on Liquor is not added to impermeable windrow after phase surface engineered described in SOPs. to ensure liquor is captured. Liquor not added to sanitised windrows nearing completion of composting. © The Association for Organics Recycling 2010 Page 6 of 8 Compost analysis for ‘indicator species’ as specified in BSI PAS 100:2005: Maximum of 1000 CFU g-1 for E. coli; and absence of Salmonella spp. in 25 g of product. HACCP ANALYSIS Approved by: <insert name> Issue 1. Issued: <insert date> Table 5. Continued Process step Hazards Control measures Critical limit Stabilisation / Compost toxic to plants when used at maturation recommended rates, phase due to; 15. it containing volatile organic acids, 16. microbial activity at a rate sufficiently high to create adverse conditions for plant roots. Unacceptable deterioration of bagged compost under typical storage conditions and/or malodour when using compost due to; 17. unsuitably high microbial activity (unstable / immature). Ensure aerobic composting for at least the sanitisation and stabilisation durations stated in SOPs. Compost has been stabilised Temperature of and matured (if appropriate) stabilising batch. for the minimum duration specified in the SOPs. Subjective Earthy compost smell when assessment of stabilised and matured (if compost smell, by applicable), absence of acrid experienced malodours. operative. Aerate batch and extend sanitisation phase for batch. Records of: duration each batch was sanitised, stabilised and matured If CL not met or above (if applicable) for; corrective action not taken, monitoring batch dealt with as per assessments; SOPs. destiny of non-conforming Management review of batches; and any need to change SOPs for complaints from any compost grade. customers or those in the compost supply chain. Compost complies with quality requirements in BSI PAS 100:2005 - plant response tests - stability test (CO2 evolution) - plus any more stringent stability result agreed with the customer for ‘mature’ compost grade(s). Refer to Quality Policy. Process step Hazards Control measures Critical limit Monitoring procedures Corrective action Record Verification / Comment Actively Managed Composting phase (sanitisation and stabilisation) Stalled biodegradation Add water as per during composting due SOPs. to; 18. Hazards 15, 16 and 17 occurring due to insufficient moisture in windrow and biological decomposition process stalling. As per SOPs. Windrow monitoring Incorporate water into as described in windrow using method SOPs. stipulated in the SOPs. Composting windrow record sheet and evaluation sheet. Records of any complaints received from customers or those in the compost supply chain. Compost complies with quality requirements in BSI PAS 100:2005 - plant response tests. - stability test (CO2 evolution). © The Association for Organics Recycling 2010 Monitoring procedures Corrective action Composting mass temperatures show trend of decline. Page 7 of 8 Record Verification / Comment HACCP ANALYSIS Approved by: <insert name> Issue 1. Issued: <insert date> Table 6. Continued Process step Hazards Control measures Critical limit Monitoring procedures Corrective action Record Verification / Comment Compost not Compost sampling and performing as expected or added costs when testing formulating products due to; 19. inconsistent compost quality. Representative sample obtained from each batch sampled (see guidance in application pack). Frequency of compost sampling and testing: Comparison of compost test results with quality criteria. Additional sampling and testing if results for one or more parameters ‘Fail’ minimum quality in BSI PAS 100:2005. Applies also to any ‘Fail’ result in any additional quality specification subscribed to (see quality policy). Review suitability of input material types / sources and composting process if sufficient consistency in quality is not achieved or if this deteriorates after process validation. Compost sample test results history (e.g. collated for each quality parameter). Compost sample test results history shows acceptable quality consistency. Process step Control measures Monitoring procedures Corrective action Record Verification / Comment Product labelling sheet and any other literature and advice. Compost found to have gone to unintended use: Advise customers and / or recall. Records of: compost dispatched, and any reported incidents of compost used other than as intended. Product labelling and traceability information (weighbridge out ticket and/or Product Dispatch Note [see template in application pack]) supplied to product recipient. Compost dispatch records kept and any reports or observations of compost use other than as intended. Hazards Labelling and Compost unfit for the purpose used due to: other safeguards 20. inappropriate use against (not as intended). unintended use. not less than minimum in BSI PAS 100:2005; as per any additional Batch sampling and testing the compost testing schedule is customer requires. appropriate for checking the effects of variations in characteristics of input materials. Critical limit Customer receives No compost knowingly going product information, to unintended use. including ‘safe use’. Advice / statements about application types the compost is suitable for. Checks when compost dispatched that it is the grade / product type ordered. Record of any process management review. No persistent customer Record of any customer complaints about complaints about inconsistent inconsistent compost compost quality. quality. Compost marketing literature. © The Association for Organics Recycling 2010 Page 8 of 8