From BioCycle Magazine
May 1999, Page 30

UNDERSTANDING THE PRINCIPLES

HOW TO SUCCESSFULLY MANAGE A COMPOST FACILITY
Environmental Management Systems lay out an operational plan that maximizes quality performance and creates an efficient response mechanism when problems arise.

Jan W. Allen

When a composting facility is at the edge of the cliff with regard to public acceptance or regulatory approval, it must decide to play or fold. Playing means adapting and moving up the evolutionary ladder. Folding means the perceived cost is too much to bear. When I was manager of the Cedar Grove Compost facility in Seattle, Washington (see preceding article, “Composter Bounces Back From The Brink”), we decided to play. The specific measures taken at our facility are described in that article; in this report, we’ll focus on the principles of the environmental formula we adopted.

There are over 3,500 working compost facilities in the United States today. The number grows by a few hundred every year. Each year, a certain number of facilities lose their public support or otherwise fall out of regulatory compliance. This is in spite of the fact that compost (or composting) is being discovered as a cure for excessive pesticide and fertilizer use, runoff volumes and pollutants, open burning, fugitive dust and soil loss. Even with the growing appreciation of the profound benefits of compost products, the industry still must see its way clear of becoming infamous for creating odors from these facilities. It is possible to manage the composting process on nearly any scale with minimal odors. Yet the balance between minimal odors and becoming a nuisance is extremely delicate. Only a slight change in practices can cause odors to increase dramatically. Frequently, odors will be associated with an increase in waste volume.

Experiences at some facilities now indicate that odors change over distance, sometimes to the detriment of the community. While the odor at a facility boundary might not be characterized as particularly offensive, as the odor moves downwind the character of the odor may become more offensive. This phenomenon has been described as the atmospheric persistence of certain volatile fatty acids while other compounds disperse quickly or fall below our olfactory threshold. Facility operators are required to be responsive to odor complaints even when they may believe the odor standards or the regulatory process is unfair. Fair or unfair, the odor issue is upon many of us. So how can a composting facility grow and flourish in this kind of regulatory climate? In some cases, a single facility can have several agencies issuing permits with redundant or conflicting regulations.

It seems paradoxical that each facility must struggle with the same issues of odor (and other environmental issues) without the benefit of experience from its peers. Yet composting is a profoundly local phenomenon. Local politics and economics shape each facility. This gives the industry strength and weakness. It is strong in the sense that success lies in the hands of the local community where the decisions are made and the recycling loop completes itself. This gives each community the opportunity to address and resolve its own problems. Some communities will reconsider composting, but many will strike a unique solution to suit its needs. The weakness in this industry is that composting is undeveloped as an institution. Both the technologies and management techniques are still evolving. While the present level of innovation is high, not all facilities will survive.

EMS SYSTEM FOR COMPOSTING HARDWARE AND SOFTWARE

Communities and regulators are pressuring composting facilities to show measurable environmental performance. What makes success more certain is skillful execution of both technology (hardware) and management techniques (software). No matter how good the tools, there must be a certain amount of operator training, skill and discipline to effectively manage composting to minimize environmental impacts. A proactive approach to environmental management can have economic rewards and public relations value.

A proactive approach falls into what is known as an Environmental Management System (EMS) or ISO 14001 Operating System. ISO is the International Organization for Standardization. In 1991, the ISO formed an advisory group to study and make recommendations on the need for international environmental standards. In 1993, a technical committee began developing the ISO 14000 series of environmental standards. ISO is not the only organization that produces a standard for environmental performance, however, it is probably the most universal and widely accepted.

The EMS style of management is rooted in statistical process control and a course of continuous incremental improvement. It is remarkably similar to the management philosophy and approach developed by W. Edwards Deming, an American industrial manager who began Japan’s industrial love affair with quality control. He was a pioneer in advocating the setting of goals, measuring performance, and acting to correct and improve performance. An EMS is used to control environmental performance through continuous process improvement.

An EMS departs from the traditional “command and control” style of regulation that has prescriptive limits and specific methods to comply with. The traditional approach discourages exploration to find new and better ways to get the job done. Permitted practices are black and white and inflexible. An EMS makes room for innovation while continually holding the permittee responsible for environmental performance.

EMS COMPONENTS

The basic foundation of an EMS is a written plan, which includes a description of responsibilities for managers, production workers, temporary workers and the regulators. The plan itself has five subsections: Environmental policy; Planning; Implementation; Checking and corrective actions; and Management review. The environmental policy lays out the various components and goals of an operation’s EMS, an important investment in time and energy for a facility operator. The new management approach may not require wholesale technology changes or capital investment, but will require a philosophical and personal commitment from every employee — from the CEO to the loader operators. It also requires some commitment from the regulators to respond in a defined and predictable manner. In fact, the stakeholders go beyond the employees and regulators and encompass the stockholders, the local community, purchasers of the company’s products, etc.

It is often more meaningful and credible if an EMS is implemented at the request or suggestion of the regulating authority. If a facility is willing to proceed with EMS development, the permitting or regulating agency can lend support and value to the process by sharing in any public disclosure. The agency can and should then protect its reputation by participating in the review and approval of the final EMS.

No EMS will ever be created successfully without making improvement in environmental performance its primary goal. If a facility feels it is losing public acceptance, it should not delay in moving toward an EMS approach. It should also communicate that it is doing so to receive full credit in the court of public opinion.

The planning component specifies the methods and procedures designed to maximize environmental performance. Here is an illustrative scenario: The EMS for a composting facility may stipulate that incoming waste is processed within 48 hours and feedstocks must be prepared to balance C:N ratios to 25:1 or greater, have a porosity of 55 percent or greater, etc. Then, in late spring, the operation has odor complaints. The regulating agency steps in and reviews the complaints, the facility’s response, and other factors. Regulatory officials meet with the operators to explore the cause. The alleged cause of increased odor complaints is an increase in the proportion of grass in the incoming feedstocks. The agency believes the EMS should be revised to compensate for this increased grass proportion. The two parties come to consensus on a new set of performance targets for the weeks when grass increases above an agreed upon percentage. These targets might include increased porosity and carbon in the preparation of process feedstock to help compensate for the rapid oxygen demand caused by decomposing grass.

The EMS must include enough quantitative record keeping to define the facility’s performance (through implementation of the operational plan). Porosity and carbon are just two examples of quantitative measures of the composting process. The same example may have relied upon pH, moisture, density, volatile solids loss, pile height, batch size, processing time, turning frequency, time of day for certain activities, or any number of other criteria. When a problem arises, the EMS will help determine what practices were implemented at the time the complaint occurred. This sounds simplistic but it has proven to be an extremely helpful management tool. In this way, an EMS can be implemented and adjusted over time.

CHECKING AND CORRECTION

If there is an environmental problem when a facility is operating under an EMS, the checking and correction element comes into play. This is the dynamic, continuous improvement process at work. If a facility cannot check and correct itself through its EMS, then the regulator can open the EMS to review and either request it be modified or require the facility to improve performance through revised permit conditions. The permitting agency has a responsibility to provide leadership in the form of consistent response. It also must react in a measured way when problems do occur.

The last component involves management review of the reports being prepared under the EMS. Are there performance problems? Is there some indication of why a problem occurred? If not, a response should include review of the implementation and correction processes. For example, if odor complaints suddenly increase for a facility, the EMS allows the management to communicate to concerned parties that an EMS is in place and how that plan provides for corrections.

VALUE OF THE SYSTEM

The value of an EMS has been proven in restoring troubled facilities to acceptable performance and public acceptance. It allows a systems-based view of an organization, not just the parts at one point of compliance. If a facility is under fire for odors (or other environmental issues like water runoff or noise) in a community, the adoption of an EMS can both restore public acceptance and save money. There can be obvious savings in reducing or avoiding the cost of litigation. Effective implementation of an EMS also should improve operating efficiency, reduce the risk of fines or penalties, and improve the prospects of receiving approval for facility expansion when an application is made. This last consideration may be the most important for many composting facilities. Today, the average facility in North America receives less than 10,000 tons/year. Yet as programs expand in subscribers and feedstock categories, this amount certainly will rise. The largest composting facilities today are processing ten times this amount or more.

An inherent advantage to the EMS approach is that it allows facilities to become self-regulating, eliminating the daily hands-on style of regulating that is so expensive and time consuming for many agencies. Regulators should make sure the EMS is relevant and productive. It doesn’t diminish their authority or their ability to change permit requirements. Instead, regulation and reporting responsibilities are put in the hands of the facility operator — with the appropriate accountability.

For example, if odor complaints suddenly increase for a facility operating under an EMS, the regulatory agency should request a response from the operator. Given the difficulty of determining whether complaints are due to actual odor increases or changing perceptions, the regulator then can consider both sides of the story. The regulator can communicate to concerned parties that an environmental management system is in place which stipulates that their complaints be considered.

If investigation of a complaint episode results in the conclusion that the facility has performed satisfactorily, the agency can have the confidence to work through the political process. It often helps an agency to explain to elected officials and other concerned parties that the facility is bound to a standard of performance and a review of the complaint is underway. While not everyone will welcome the news that a deliberate process is underway, such an explanation goes a long way to resolving the fears and frustration of most reasonable complainants.

Choosing to implement an EMS will build credibility — a quality earned through action. If past actions have damaged an organization’s credibility then future actions must restore it. Ultimately, the path to community acceptance and a good reputation is earned through proactive initiatives and a reasonable response to community concerns.

Jan Allen is Compost Technology Group Leader with CH2M Hill in Bellevue, Washington. He was general manager of Cedar Grove Composting when it implemented an EMS. Two suggested reference materials are Draft International Standards, International Organization for Standardization, 1995, 20 pages; and The ISO 14000 Miniguide, Craig Mesler & Thomas Flahive, Quality Resources, 1997, 50 pages. These are available through bookstores or via Internet booksellers.