At the end of January, a representative from the Environment Agency (EA) presented at a webinar led by the REA and gave an update on the ongoing revision of the Quality Protocols (QP) and also explained the next steps in the review process. The outcome of the EA’s review of the QP for both PAS110 Anaerobic Digestate and PAS100 Compost has concluded that each QP is currently not fit for purpose and requires revision. There are a number of issues within each QP which are summarised as follows:
- Levels of plastics allowable under each of the current QPs, and therefore found within both compost and digestate spread to land, are currently too high. This is causing land contamination and market confidence issues. If existing markets loose confidence in the product, the product has not met the legal criteria for end of waste.
- To resolve this issue, it has been proposed that acceptable plastic levels in product will match those currently specified in SEPA’s regulatory position statement, which is 0.06% (50% of current PAS100).
- The review also needs to consider and incorporate the updated fertiliser regulations and latest soil science.
- Levels of other physical contamination in compost, such as sharps and stones also need to be reduced.
- The digestate specification requires refinement, to ensure that digestate does not lose integrity whilst in storage. In response, it has been suggested that stability requirements need to be revised.
- Initial feedback suggested the scope digestate QP could be broadened to include new processing techniques and end markets, such as dried digestate.
Although there are a number of key issues that need to be resolved, the EA also welcomes suggestions from the sector on how the scope of the revision can be defined to enable even further benefits for the sector. The revised QP documents are expected to be rebranded as a “Resource Framework” under the EA and published on the .gov website. By taking ownership of the standards, the EA expects to be in a better position to make any further updates more easily.
It is also highlighted that while the EA remain optimistic on the outcome of this revision, there are no guarantees that each QP can be republished as a Resource Framework and end of waste maintained; therefore, it is pivotal the industry works together to ensure that the issues above are resolved through a revision of the QP.
A ‘task and finish’ group must be formed for each QP and the scope of the review shall be defined.
The EA have stated that the group must be organised by the 30th May 2021, for both protocols, otherwise their support (and the end of waste position shall be withdrawn. In response to this, the industry is now coordinating to ensure the group is organised in advance of the May deadline.
It is anticipated the review shall take approximately six months to complete and costs for each QP revision have been estimated at around £25,000. However, both factors are subject to the number of items within scope and therefore the time it will take to review each item. It has not yet been agreed how this shall be funded.
Please get in touch with WRM if you would like more information on the ongoing QP reviews.