ECN-Statement to the EPPO Working Paper 02/9781 (Stellungnahme)

The working paper 02/9781 “Draft Phytosanitary Procedure - Management of Plant Health Risks Associated with the Use of Biowaste of Plant Origin“ - published by the European and Mediterranean Plant Protection Organization (EPPO) - includes essentials of a translation of those parts of the German Biowaste Ordinance which are relevant for phytosanitary questions of biowastes and products produced from such (compost, anaerobic digestion products).

On account of the available experiences with the enforcement of the German Biowaste Ordinance and on account of the fact that only reasonable requirements make sense and can be guaranteed by the composting plants we are in deep concern and want to comment to the following points in the above mentioned paper:
What is EPPO?
An intergovernmental organization responsible for European cooperation in plant protection in the European and Mediterranean region. Under the International Plant Protection Convention (IPPC), EPPO is the regional plant protection organization (RPPO) for Europe.

1. Direct process validation

The execution of "direct process validation" in each individual composting plant is not reasonable. A direct process validation must furnish the proof that the used treatment technology and process is fundamentally hygienically effective. In cases where the same process is used in another production plant, the identification that this process is comparable must be sufficient. A further process validation is not required. However, the proof is necessary that the time/temperature recording requirements for the hygienization/sanitisation of the source material (= "indirect process validation") will be documented and can be controlled.

In fact, less than 10% of the 450 compost plants in Germany realise direct process validations. In more than 90% of the cases the fulfilment of the requirements for the "direct process validation" could be demonstrated by so-called "Certificates of Conformity” of the German Compost Quality Assurance Organisation. These certificates confirm that the individually examined composting plant uses one of the modular plant types which have been already tested by the German Compost Quality Assurance Organisation BGK. Hygienically tested composting plant types are listed in the report "Hygiene test system for modular plant types" of BGK.

Therefore in reality and practice, factually only "indirect process validations" and product tests are required in Germany. This makes sense as "direct process validations" offer no additional conclusions and security.

On account of the aforementioned reasons we recommend to give up the binding "direct process validation" and to concentrate on requirements for the documentation of the "indirect process validation" (time/temperature) relevant for the proof of the hygiene/sanitary status.

2. Number of product tests

The numbers of hygiene examinations of the final products given in annex 2 of the Biowaste Ordinance are not carried out in daily practice in Germany. The German Biowaste Ordinance provides that the number of 4 to 12 tests per annum (according to the amount of source material) can be reduced if the production plant is subject to an acknowledged and independent quality assurance. This is the normal case in Germany and in most of the European Countries with an essential composting industry. The number of tests can be reduced further if unsuspicious results are continuously stipulated in the frame of Quality Assurance of the plants. So analyses which are not really necessary for hygiene assessments can be avoided.

For this purpose EPPO should also provide a mechanism in the paper which allows the reduction of the number of analyses onto an extent that is really required for the proof of the hygiene/sanitary status of the sites.

Statistical methods of industrial quality management systems are used for that purpose in practical work. They are applied by the competent authorities or by quality assurance systems acknowledged by them. The Biowaste Ordinance of Germany, however, demands a high number of product tests, which in practical work are nearly always distinctly reduced on account of the aforementioned reasons.

3. Guarantee of requirements

Normative authorities who establish the requirements for the quality of products must in addition determine mechanisms for a guarantee of these requirements and how they shall be controlled. Not only in Germany it can be assumed that official controls of the quality of organic fertilisers and their legal regulations are not carried out or not to a sufficient extent.

In this context follows that those sites which fulfil these requirements (coping with correspondingly higher production costs) are set into a competitive disadvantage compared to those who (mostly successfully) trust in a lack of controls of the quality requirements and legal regulations.

EPPO should therefore be aware of a responsibility to determine besides quality requirements for hygiene/sanitisation also mechanisms which are suitable to actually guarantee the enforcement of these requirements in practice and country-wide. One possibility could be seen in the obligation to exclusively use products which are subject to an acknowledged (by authorities) system of voluntary quality assurance.

For the time being the European Compost Network establishes such quality assurance system on a European level. Corresponding systems are already established in several Member States (Germany, Austria, Belgium, Netherlands, Luxembourg, Sweden, UK ...) and partly integrated in the national legal regulations. This applies especially to the German Biowaste Ordinance which would not be subject to execution without such mechanisms of deregulation. The EPPO paper as well that has been written partly according to the corresponding parts of German Biowaste Ordinance would not be effective in practice without such a mechanism.

Status 05.05.2005
Dr. Bertram Kehres
Bundesgütegemeinschaft Kompost e.V.
Chairman of ECN Working Group 2
(Standardisation and Quality Assurance)

Josef Barth
Managing Director
of the
European Compost Network ECN/ORBIT e.V.
European Compost Network ECN/ORBIT e.V. - Postbox 22 29 - D-99403 Weimar
Tel.: +49 25 22/96 03 41 - Fax: +49 25 22/96 03 43 - Email:

Quelle: H&K 7/2005, S. 26

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