The compost industry in Australia needs to improve its self-regulation to secure its ongoing social license to operate, writes Angus Johnston, Principal Consultant at Jackson Environment and Planning.
In early September, I travelled to Austria to attend a Biowaste Study Tour & Practitioner Training Course organised jointly by the International Solid Waste Association (ISWA) and Florian Amlinger – Compost – Consulting & Development.
Austria is, in many ways, a composting utopia. More than 400 of predominantly small composting facilities with an average treatment capacity of almost 3000 tonnes per year produce mostly very high-quality compost for both urban and rural applications.
Austrian governments actively support additional diversion of organics, composting and compost use as the principal approach to organic waste management. While Australia is a very different society, economy and environment, there is much we can learn from how they approach commercial composting in this small European country.
Most remarkably, the Austrian composting and biogas industry has won its social license to build and operate its facilities and, based on a so-called end-of-waste ordinance, its right to sell compost as a product, not as a treated waste.
Planning approval and licensing takes less than half the time it does in Australia (less than one year as opposed to two to three years) and composts sell for up to 50 euro, with packed compost potting soils and blends even for 100 euros per tonne. A comprehensive framework for organic waste management is in place and finding markets for compost is not an issue.
In part this is because many composters are also farmers, a strong social and political force in Austria, but it is also because agreement has been reached between government and industry to set high standards for both composting and composted product.
Farmers have been involved in setting standards and composting source separated food and garden waste, also including their farm manure. As a result, facilities are much easier (and quicker) to license and compost is much easier to sell. The bar has been set high, but in my view, this has been critical to the success of Austrian commercial composting.
Austrian composters have accepted (mostly) tighter limits on their operations than in Australia, based on science and precautionary principal, thus giving regulators greater confidence in their ability to protect environment and human health. This has allowed compost produced at these facilities to be defined as a product, not a waste with a permit to be applied to land. Some organic waste inputs, such as municipal sewage sludge or stricter processing rules for certain animal waste have additional treatment requirements. Others cannot be used in compost manufacture at all, i.e the non-source separated organic fraction in mixed“residual” municipal waste. These conditions and exclusions allow most composts to avoid further regulatory attention and present themselves as a clean ‘organic’ product without any waste stigma.
While there are some arguable points in their guidelines, they remain broadly applicable in Australia. Several requirements in the guidelines would be highly controversial in an Australian context, mainly because they would require changes and incur costs for existing commercial composters.
For example, the guidelines make it clear that pasteurisation is not enough for reliable sanitation and a level of maturation is necessary to manage pathogen reinfection risks. In general, the guidelines advocate product maturation for product quality and environmental performance of the facility. Given most of the recycled organic waste in Australia is converted into pasteurised mulches, and are therefore not matured, this would be a significant change requiring a transition period.
The Australian Standard for Composts, Soil Conditioners and Mulches (2012) (AS4454) currently defines compost via a combination of testing biological stability and plant growth but it allows both raw and pasteurised product to be AS4454 certified. This is a pragmatic approach given the legitimate need to certify mulches in applications where maturation is simply not necessary, but it does make it more difficult to explain the higher value (and cost) of a fully composted product to the market. Why pay more for compost when you can get a certified pasteurised or raw product?
It also means that requiring AS4454 is of limited use to regulators seeking to license composting facility processing Category 3 organic waste such as food and grease trap waste. In NSW, rather than using AS4454 they must publish their requirements separately as NSW resource recovery orders and exemptions and environmental guidelines.
Other potentially controversial requirements (in Australia) include:
- Stricter requirements on when sealed hardstand areas and drainage is required
- Keeping windrow heights below 2.5 metres in all situations
- Managing initial mixes with added clay and finished compost to ensure (among other things) temperatures stay below 70 degrees in the pile and odorous/GHG emissions are minimised
However, with more prescriptive conditions on operations comes greater flexibility to use lower cost open composting systems near sensitive neighbours. The Austrian guidelines only require an odour study for separation distances less than 300 to 1000 metres depending on feedstock (with or without food waste/sewage sludge) and throughput. Smaller facilities processing low risk materials (green waste only) have simplified approval processes. This is only possible given the clearly articulated requirements for process management that are known to be effective in managing typical environmental impacts.
Importantly, the Austrian guidelines cover not just process control and product quality, they also serve as relatively prescriptive guidelines for facility design, approval and operation. This contrasts with the Australian context where some state government environmental guidelines for composting facilities are out of date or have never been published.
The Austrian Compost and Biogas Association has effectively negotiated with government on what constitutes good operational and environmental practice. Experts from local authorities were included in compost training programs from the very beginning. They have also put in place a framework to ensure their members represent that good practice.
The Austrian voluntary certification scheme certifies that the facility is being operated to the environmental guidelines, allowing operators to demonstrate to government and the community that they are responsible operators, and be formally recognised for the fact by the Austrian Compost and Biogas Association. I believe the Australian Organic Recycling Association should take a similar role in Australia.
The compost industry in Australia needs to improve its self-regulation to secure its ongoing social license to operate and avoid the imposition of less practical regulations by government, often in short timeframes and with little consideration of the commercial consequences. This includes certification of environmental performance, not just process control “quality assurance” and product “quality control”. This is a fundamental risk management strategy for an industry that wouldn’t exist without environmental regulation and enforcement. The first practical step is to develop up to date nationalbest practice guidelines for composting and compost use (particularly including putrescible organics) in consultation with industry, state and commonwealth governments.