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WRAP’s vision is a world in which resources are used sustainably. Our mission is to accelerate the move to a sustainable resource-efficient economy through re-inventing how we design, produce and sell products; re-thinking how we use and consume products; and re-defining what is possible through re-use and recycling.

Find out more at www.wrapcymru.org.uk Document reference (please use this reference when citing WRAP’s work): [WRAP, 2016, Banbury, Quality Management Systems’ support for composting sites in Wales, Prepared by Matt Taylor and David Tompkins]

Written by: Matt Taylor and David Tompkins, Aqua Enviro

Front cover photography: Compost windrows (image from: http://www.refsol.co.uk/composting/) While we have tried to make sure this report is accurate, WRAP does not accept liability for any loss, damage, cost or expense incurred or arising from reliance on this report. Readers are responsible for assessing the accuracy and conclusions of the content of this report. Quotations and case studies have been drawn from the public domain, with permissions sought where practicable. This report does not represent endorsement of the examples used and has not been endorsed by the organisations and individuals featured within it. This material is subject to copyright. You can copy it free of charge and may use excerpts from it provided they are not used in a misleading context and you must identify the source of the material and acknowledge WRAP’s copyright. You must not use this report or material from it to endorse or suggest WRAP has endorsed a commercial product or service. For more details please see WRAP’s terms and conditions on our website at www.wrap.org.uk

WRAP – Quality Management Systems’ support for composting sites in Wales 1

Executive summary Robust management systems are central to the production of quality compost – whether that compost is subsequently applied to land as a waste (typically) via an Environmental Permit or as a product accredited by the Compost Certification Scheme (CCS). This project examined the implementation of quality management systems (QMS) at composting sites across Wales, to understand whether they supported the consistent production of compost that met market requirements.

Through a process of document review, site visits and visual assessments of composting processes, we concluded that compost is of appropriate quality for its intended markets in Wales. However, certain issues were identified. The most important of these was that QMS documentation at some sites was only retained for auditing purposes and was not used as the basis for running the site. The layout and usability of the various QMS documents – especially the Hazard Analysis and Critical control points (HACCP) plan and Site operating procedures (SOPs) – also tended to be poor, although based on templates previously provided by REAL.

The requirement to implement a QMS is intended to ensure that compost of the required quality is consistently produced. Such a system should benefit rather than hinder compost producers, since it applies a logic and process flow that allows any problems with compost quality to be readily identified and remedied. However, the fundamental operations at a composting facility are relatively straightforward, and the QMS as required by the CCS could be considered overly onerous, potentially contributing to the observed separation between documented procedures and actual site operations.

Within the current CCS framework, site operators are required to play a key role in development of quality management systems, and the scheme owners (REAL) should consider how this requirement can be more robustly implemented.

Other issues related to the content of PAS100, and particularly to the HACCP requirements – which could be described as misleading or incorrect. This led to errors in templates provided by REAL for scheme members, which were then propagated to almost all composting sites (the templates have subsequently been withdrawn). At a small number of facilities there were more significant (process) issues, primarily caused by a lack of operational space on site.


Contents 1.0 Introduction ................................................................................................... 3

1.1 Compost Production in Wales ...................................................................... 3 1.2 Importance of quality .................................................................................. 4 1.3 Quality management systems in composting ................................................ 4

1.3.1 General principles for compost production .......................................... 4 1.3.2 General principles for compost use .................................................... 5 1.3.2.1 Compost Certification Scheme ........................................................ 6

2.0 Aims and objectives........................................................................................ 7 3.0 Methodology ................................................................................................... 7 4.0 Results and discussion ................................................................................... 9

4.1 General compliance with scheme rules ......................................................... 9 4.2 PAS100 and CCS ......................................................................................... 9

4.2.1 HACCP plans: content and format ...................................................... 9 4.2.2 Standard Operating Procedures: content and format ......................... 10 4.2.3 Assessing levels of physical contaminants ......................................... 12

4.3 Site constraints .......................................................................................... 12 4.4 Review/updating of documentation ............................................................. 12 4.5 Future support ........................................................................................... 12

5.0 Conclusions and Recommendations ............................................................. 13 5.1 Conclusions ............................................................................................... 13 5.2 Recommendations ..................................................................................... 13

Acknowledgements We would like to thank the numerous commercial compost producers in Wales for their participation in this project. The time they devoted to provision of documents, participation in site visits and discussion on our recommendations is particularly appreciated.


1.0 Introduction 1.1 Compost Production in Wales Currently, over 100,000 tonnes of biodegradable material is composted every year in Wales1. Ten Welsh compost facilities are certified under Renewable Energy Assurance Ltd’s Compost Certification Scheme (the REAL CCS), Table 1-1. Certified compost must be produced according to the requirements of PAS 100:2011 (the UK’s specification for composted materials).

Table 1-1 List of Welsh certified compost facilities

Producer number

Operator / Company name Site name Feedstocks* Compost type /

grade(s)

PR107 Bryn Compost Limited Gelligiarwellt Farm Green waste + ABPs

Soil conditioner 0 to 15

PR274 Cowbridge Compost Ltd

Cowbridge Compost Ltd

Green waste + ABPs

Soil conditioner 0 to 30

PR114 CWM Environmental Ltd

Nant-y-caws Composting Facility

Green waste + ABPs

Soil conditioner 0 to 10 Soil conditioner 0 to 25

PR270 CWM Environmental Ltd

Nant-y-caws Composting Facility Green waste


PR287 FCC Environment (UK) Ltd

Llanddulas Composting Facility Green waste


PR245 Flintshire County Council Waste Management Services

Greenfield Composting Facility Green waste


PR284 The Green Waste Company (Abergavenny) Ltd

Maindiff Court Farm Green waste Soil conditioner 0 to 40

PR267 Gwrtaith Gwynedd Glanllynnau Green waste Soil conditioner 0 to 40

PR289 MD Recycling Ltd Crugmore Farm Green waste Agriculture 0 to 40

PR238 Ynys Mon CC Penhesgyn In Vessel Composting Facility Green waste Soil conditioner

0 to 20 *Green waste means tree and shrub prunings / grass clippings etc; ABPs means Animal By-Products such as food waste from domestic and commercial kitchens

1 https://naturalresources.wales/media/2805/wales-waste-information-eng.pdf


Two additional composting sites are not certified under this scheme (Figure 1-1).

Figure 1-1 Certified and non-Certified compost facilities in Wales

1.2 Importance of quality The composting industry is entirely reliant on sustainable outlets for its product. If the compost is not of sufficient quality, i.e. it does not meet customers’ requirements, then those sustainable outlets (e.g. agriculture, horticulture, growing media) will be unavailable and other more expensive outlets will be required (e.g. land restoration, incineration, landfill). This will not only be undesirable for the composting facilities, but will conflict with the Welsh Government’s recycling targets. Such outcomes are a genuine risk to the industry; in 2007 a farm assurance scheme placed a moratorium on the use of green compost due to concerns about quality which was not fully lifted until several years had elapsed. Almost 70% of compost is applied to agricultural land2 which means such an outcome in Wales would have a massive impact. It is therefore vital that composters produce material that is of sufficient quality to meet customers’ requirements, and that they have systems in place to ensure that quality can be delivered consistently.

1.3 Quality management systems in composting 1.3.1 General principles for compost production Where waste materials are processed, the production and use of compost in Wales are normally controlled by the Environmental Permitting Regulations3. These require the compost producer to hold an appropriate permit from the environmental regulator (Natural Resources Wales). Whilst bespoke permits can be issued, the most common permits

2 http://www.wrap.org.uk/sites/files/wrap/ASORI%202012.pdf

3 http://www.legislation.gov.uk/uksi/2010/675/pdfs/uksi_20100675_en.pdf


covering composting activity are Standard Rules (SR) 2012 No. 7 and SR 2012 No. 3. These are for ‘open’ systems4 and ‘closed’ systems5, respectively. Both permits require that a management system is followed:

1.1.1. The operator shall manage and operate the activities:

(a) in accordance with a written management system that identifies and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, non-conformances, closure and those drawn to the attention of the operator as a result of complaints; and

(b) using sufficient competent persons and resources.

1.1.2 Records demonstrating compliance with rule 1.1.1 shall be maintained.

1.1.3 Any persons having duties that are or may be affected by the matters set out in these standard rules shall have convenient access to a copy of them kept at or near the place where those duties are carried out.

1.1.4 The operator shall comply with the requirements of an approved competence scheme

There is a similar regulatory requirement for management systems to be in place when the compost is subsequently used, except where the composting process and compost product are certified under the Compost Certification Scheme (CCS). This is considered further in the next section.

1.3.2 General principles for compost use Where waste materials are processed, a separate permit is required to use the resulting compost. Once a permit to use the compost has been obtained, subsequent applications must be made to the regulator to allow the permit to be deployed (i.e. for the compost to actually be used). As part of the deployment application the composter has to demonstrate how the compost will provide benefit to the receiving land, and that the use of the compost in the way described will not cause harm. This process may require the applicant to undertake a site-specific risk assessment, particularly where the compost is intended for use in (e.g.) a groundwater Source Protection Zone (SPZ) 2 or within 500m of a Site of Special Scientific Interest (SSSI).

When compost has been certified under the CCS, it can be used without these checks because of the (specified) materials from which it is produced, the (prescribed) systems governing the composting process, and the compost’s compliance with (listed) quality parameters.

CCS-compliant sites must have a Quality Management System (QMS) which details the process used to produce the compost, and considers relevant hazards which may be present in the feedstocks and describes how these will be managed to prevent them causing a risk in the specified end use. In more detail, the core requirements of any QMS should be:

identification of the intended compost market and any product quality aspects specific to that market;

a consideration of hazards present in feedstock materials that could impact negatively on product quality (rendering product unfit for the identified markets) unless managed/controlled during the composting process;

4 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/479457/LIT_7551.pdf

5 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/479884/LIT_7546.pdf


an identification of the critical control points – and critical limits – that ensure hazards are controlled to a point where the final compost quality is fit for use in the identified market(s);

ensuring that Standard Operating Procedures (SOPs) are in place and dovetail where necessary with the critical control points and limits; and

ensuring that a formal review process is in place to ensure that the QMS remains valid.

1.3.2.1 Compost Certification Scheme Quality management is core to the requirements of PAS100:2011. Indeed, it is the individual site’s quality policy that sets the acceptable standard for compost, which could be far in excess of the baseline values presented in the PAS where customer demand and hazard management require it. Section 4 of PAS100:2011, which outlines the requirements for compost producers relating to Quality Management Systems (QMS), states the following:

A QMS specific to a defined composting process, its resulting composts, and any products that contain those composts shall be established and maintained.

The QMS shall control all operations and associated quality management activities necessary to achieve compost that is fit-for-purpose… Where specific controls are applied they shall be monitored, recorded and evaluated, both before and after process validation. Corrective actions shall be defined.

Whilst further clauses specify the requirements for oversight of the QMS, the following important note is appended:

NOTE The HACCP plan… influences the quality policy… and SOPs… and should be regarded as part of the QMS.

This note is important, as it is the HACCP (Hazard Analysis and Critical Control Points) planning process that requires compost producers to first define what is considered fit for purpose, and to design the upstream hazard management approaches accordingly. For example, if a compost producer wishes to supply compost to a farmer for application to land ahead of oilseed rape, then pathogens of brassica crops are a hazard that must be considered and managed within the HACCP plan and its associated critical control points. Likewise, cereal pathogens are a relevant hazard for cereal crops, but may not be relevant to oilseed rape. Should the compost producer wish to supply materials suited to a wide range of agricultural crops, then a wide range of hazards would need to be considered – and then controlled, if appropriate.

The HACCP process encompasses both hazards to safety and ‘critical quality’ hazards that impact on fitness-for-purpose, with the most commonly cited of these latter being physical contaminants.

Alongside the basic HACCP planning process, the PAS requires compost producers to check with their customers to understand whether they need compost of a quality that is higher than specified by the PAS baseline (a concept of ‘customer-specific fitness-for-purpose’). Where such needs are identified, then the composter’s quality policy must state how they will be met. All of these elements must then be reflected in the site’s standard operating procedures (SOPs) (Figure 1-2).

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4.0 Results and discussion 4.1 General compliance with scheme rules Based on our review of the key QMS documents (particularly the HACCP and SOPs) and scrutiny of process flow during our site visits, we conclude that there is good overall compliance with the requirements of the environmental regulator and CCS. A small number of exceptions to this conclusion are discussed in the following sections.

4.2 PAS100 and CCS 4.2.1 HACCP plans: content and format Each participating site had a HACCP plan that was based on the recently withdrawn REAL template. This template is problematic, since it doesn’t accurately reflect the principles of hazard assessment that are core to HACCP planning. This is partly due to text in PAS100:2011 itself, and in particular Section 5.1.1, which lists a series of exemplar hazards. Unfortunately, the scenarios described in the PAS are mostly risks – specifically, risks of outcomes due to inadequate control of hazards. Some examples of inappropriate hazard definition are listed in Table 4-1.

Table 4-1 Comments on some hazard descriptions in PAS100:2011

Text in PAS100:2011 (Section 5.1.1.) Comments

a) adverse effects on the environment – including human and animal health – due to pathogens in compost;

Pathogens are the hazard that must be managed, not adverse effects on the environment (which are the risks that must be minimised through appropriate hazard management)

b) adverse effects on plant health due to pests, pathogens, toxins (see 3.74) or intermediate biodegradation breakdown by-products in compost;

Pests, pathogens, toxins and breakdown products are the hazards that must be managed, not the adverse effects on plant health (which are risks that must be minimised through appropriate hazard management)

c) adverse effects on plant health where compost is used in sensitive applications (e.g. ingredient in growing medium) due to immaturity of the compost;

Compost immaturity (which cannot be parameterised, but may be reflected in biological activity / oxygen demand or electrical conductivity etc.) is the hazard, not adverse effects on plant health (which are risks that must be minimised through appropriate hazard management)

Perhaps due to the errors in PAS100:2011, the approach taken in all HACCP plans at participating composting sites was confusing. In some cases they sought to manage risk (rather than hazard) and in some cases multiple critical control points were identified for specific hazards, when the principles behind HACCP require that single – Critical – control points be identified for specific hazards. Furthermore, the HACCP plans (in general) did not take a logical approach to presentation – for example, by considering potential control points in a stepwise fashion through the composting flow (Figure 4-1) and then separately listing just the Critical Control Points (CCPs), Critical Limits and methods of control. Adopting this approach would more readily ensure that HACCP requirements were embedded within SOPs, which would in turn better ensure that hazards were managed as intended.


Process flow diagrams were absent from all of the HACCP plans reviewed; the inclusion of such diagrams allows CCPs to be clearly identified, and these can then be referenced in the SOPs. This approach should also eliminate the tendency to rely on end product testing – at the intervals required by PAS100:2011) – to demonstrate compliance with the HACCP. Such end product testing is intended to offer an occasional check to demonstrate that the Quality Management System is operating as intended; it should not be core to the HACCP planning.

The general reliance on a REAL template also meant that some control measures were included that could be considered overly precautionary in the light of available evidence. For example, there is no evidence that toxins in ragwort will survive composting processes to be present in final compost at concentrations sufficient to harm grazing livestock should compost be applied to grazing land. With no evidence available, then management of such a hazard through total exclusion of ragwort could be considered appropriate. However, now that such evidence is available, HACCP plans should be changed to reflect this. It was not clear where site staff obtain their information on hazard management, and this could be a role that the scheme owners (REAL) or trade body (ORG) fulfil in the future.

4.2.2 Standard Operating Procedures: content and format All of the sites had SOPs based on the recently withdrawn REAL template, which contains all the information in one document and runs to around a dozen pages. The accessibility or ‘user friendly’ nature of this document varied from site to site, with some being comfortable with the current style of the document, and others finding it unhelpful.

In other sectors, SOPs are formatted as a suite of documents with a single page/sub section focusing on each separate aspect of site operation. When presented in this way the SOPs should contain all the required information (without cross referencing to other documents) to allow a trained and knowledgeable individual to undertake the task with minimal/no supervision.

Some of the participating sites laminated their SOPs and left them in break rooms so that the operatives could become familiar with them. Others, particularly those who were operating smaller composting sites, felt the current format wasn’t an issue as they did not have numerous employees to train, often operating the site themselves. The larger sites, who typically had more site staff, on the other hand felt that the current format was not entirely helpful, particularly for new employees. As a result one site had produced individual laminated sheets highlighting different aspects of site operations and what was required.

Ideally, the SOPs should be treated as an ‘operating manual’ or checklist. If each procedure is followed as prescribed by its SOP, then the whole process should manage hazards as required by the HACCP plan, and consistent quality of compost should be guaranteed. Requiring SOPs to be used in this way would also facilitate process audits – not only to the benefit of the Certifying Bodies, but also to the benefit of the sites themselves. Should an SOP not be followed (and the ‘operating checklist’ not be completed), then this would help operators understand where issues were arising if compost quality were ever to fail to achieve the required standard.

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Management Systeems’ support for commposting sites in Wales 11


4.2.3 Assessing levels of physical contaminants All of the sites who participated in the study mentioned assessing the level of physical contaminants in both incoming feedstocks and in the final compost. Indeed, rejecting highly contaminated loads was identified as a critical control point with a critical limit in every site’s HACCP plan, as well as each site’s SOP where acceptance criteria were based on percentage contamination in the incoming feedstock. However, none of the sites detailed how operators should assess the level of contamination.

4.3 Site constraints At two sites there were severe space restrictions, which led to windrows being too close together – i.e. not kept the minimum distance apart, and even overlapping. This meant that the bottom of a windrow could be moved with the adjacent one, causing material to shortcut the composting process. Similarly, piles of oversize material were encroaching onto certified compost, which could easily lead to cross-contamination of the compost and result in the compost containing elevated levels of contaminants. These issues were primarily caused by space constraints, although a lack of markets for oversize was mentioned by the operators as an issue. One operator admitted that there was a lack of senior management oversight, due to changes in senior personnel.

4.4 Review/updating of documentation It is a requirement of the CCS that all QMS documentation is reviewed annually as part of a management review, and that an internal audit is undertaken. In some cases, the documentation was out-of-date, with former staff listed as responsible for certain processes. Additionally, there were various typos and errors (e.g. incorrect EWC codes, references to old versions of documents) which should have been identified during management reviews and/or audits. Likewise, changes in the evidence base were not necessarily reflected in changes to HACCP plans (Section 4.2.1).

Where site staff were involved in development and implementation of a quality management system, the QMS tended to more accurately relate to how the site was operated, and documents were more likely to be kept up-to-date.

4.5 Future support Provision of support (for example, to update QMS documentation or to change processes) was outside the scope of this project. However, the composters were asked whether any specific future assistance or support would be of benefit to their businesses. The key issue was around a lack of sustainable outlets for compost oversize. At most sites there was a significant stockpile of this material, which was more or less contaminated with plastics and other physical contaminants – severely constraining its potential uses. Support to improve feedstock quality would therefore be welcomed.

Another issue that was highlighted was the lack of interaction/knowledge exchange between composters. Some operators commented that a forum whereby sites could exchange knowledge and experience would be very useful as they are often facing the same issues, yet rarely discuss them. ORG already host sector group meetings for members of the REA, but REAL could consider hosting similar networking events for members of the Compost Certification Scheme.


5.0 Conclusions and Recommendations 5.1 Conclusions Based on visual assessments made during site visits, the certification status (of CCS member sites) and the absence of negative feedback on compost quality from customers receiving compost from all sites visited, we conclude that the compost is of appropriate quality for its intended markets in Wales6.

The key issue is that at some sites, the QMS documentation is only retained for auditing purposes and is not used as the basis for running the site. The requirement to implement a QMS is intended to ensure that compost of consistent (required) quality is produced – but it also benefits operators, by applying a logic and process flow that allows problems with compost quality to be identified and remedied. However, the fundamental operations at a composting facility are relatively straightforward, and the QMS as required by the PAS could be considered overly onerous, potentially contributing to the observed separation between documentation and site operations.

There is no simple solution to this. Within the current framework, site operators must play a key role in development of quality management systems, and the scheme owners (REAL) should consider how this can be encouraged / monitored. During any future review of PAS100, serious consideration should be given to the QMS requirements, and whether these can be amended in a way that would encourage operators to implement them correctly, whilst at the same time ensuring that compost quality is not jeopardised.

Minor improvements could be made at many sites, including the format of QMS documentation and the use of photographs to allow operatives to identify when material is of sufficient (physical) quality. At a small number of sites there were more significant issues, primarily caused by a lack of space.

5.2 Recommendations This project has shown that compost produced in Wales is suitable for its intended markets. This is based on a combination of:

Site visits to view the compost process flow, from feedstock receipt to final compost screening. Such assessments were (purely) visual, with no samples taken or tested as part of the visits;

The certification status of sites that are part of the CSS; and The lack of negative feedback from customers on product quality.

However, the project highlighted a number of issues with the content and implementation of the CCS. In particular, the complexity of the scheme in relation to the (relatively) simple process of composting, meant that scheme documentation was often retained for auditing purposes only and played little part in day-to-day composting operations. Whilst this has not obviously led to the production of sub-standard compost, one of the intentions of the scheme (and particularly PAS100:2011) is that a quality management system be implemented that guarantees the quality of the final compost. The occasional sampling and testing required by PAS100 is intended merely as a check that the quality management system is functioning correctly.

Furthermore, the scheme owners (REAL) rely on the Certifying Bodies to address minor issues that arise during site audits, while major issues can be reported back to REAL for comment and/or action. Whilst this distinction helps to ensure that the auditing process is

6 We were reliant on site staff to provide feedback on their customers’ experience, but as our site visits occurred at various times in any given composting cycle, we did not witness quality issues that we considered were likely to give rise to sub-standard compost


independent, it can mean that the scheme owners have no feel for how the scheme is actually perceived and implemented. It is unreasonable to expect Certifying Bodies to have the in-depth technical knowledge required to scrutinise the content and quality of documentation they review, and to decide whether scheme processes are actually implemented as intended. To address these various findings, our recommendations are that:

ORG issue clear guidance on completing HACCP plans to avoid the current confusion between risk and hazard (this may also require that PAS100 is updated – see below).

ORG consider offering ‘hazard updates’ to the composting sector when new evidence is available – to ensure that HACCP plans best reflect available evidence.

ORG publicises its feedstock visual inspection guidance (http://www.organics-recycling.org.uk/uploads/article2903/Visual_assessment_guidance_light_plastics_V1R0.pdf) and the benefits it can bring to sites. This guidance should also be edited to allow a separate visual check of compost quality before it is despatched from sites.

The process of QMS development genuinely includes the involvement of site staff who will be responsible for its implementation. This could take the form of a written and/or oral test to demonstrate an understanding of the QMS requirements.

PAS100 should be updated to correct the errors around the definitions of risk and hazard. REAL should remind operators of the importance of keeping compost/oversize

piles/windrows separate. This requirement should also be communicated to Certification Bodies so that they can monitor this during routine audits.

REAL consider amending the standard format of SOPs, and that the new format becomes an auditable aspect of the CCS. Presenting SOPs as an ‘operating manual’ or checklist would help ensure the production of quality compost and facilitate audits.

REAL and the Certifying Bodies consider simplification of the scheme to better ensure that QMS systems are actually used. This could include the introduction of a daily checklist or task list that is completed and signed-off by relevant site staff.

REAL remind CCS members of the need for annual reviews to keep systems and documents up to date.

REAL discuss the findings of this report with their Certifying Bodies. REAL consider co-ordinating networking events for CCS members, so that they can share

knowledge and experience.

www.wrapcymru.org.uk

oin014-001 final 2.2 061117 - wrap cymru final english.pdf · wrap – quality management...

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