In March of 2024, revisions were made to Colorado's compost regulations (Section 14 of the Solid Waste Regulations) with the primary intention of increasing the opportunities for food waste composting via increased allowable volumes at Conditionally Exempt Small Quantity facilities, and opening up food waste composting to certain Class I facilities. However, in addition to these changes, other revisions were made that added finished compost testing and storage requirements, as well as a new training requirement for some operations. These changes impact both new and existing facilities.
In order to facilitate compliance with these revisions, the following is a summary of the changes to the regulation, which types of facilities are affected by those changes, and the compliance requirements for each.
Section 14.6 (D) Finished Compost Testing
Facilities: All that distribute finished compost offsite (CESQ, Class I, II, and III)
Revision: All finished compost must now be tested for both biological indicators, fecal coliform and salmonella. Previously it was one or the other.
Schedule: March 30, 2024 - All finished compost produced after this date must be tested for both fecal coliform and salmonella.
March 30, 2025 - All facilities with an EDOP must update their sampling plans to reflect the new testing requirement.
Compliance: EDOP revisions will be verified during inspections, and do not need to be submitted to the Division for review.
Section 14.6 (J) Finished Compost Storage
Facilities: Class I, II, and III
Revision: Finished compost may only be stored in areas designated by the facility's operation plan.
Schedule: March 30, 2024 - The EDOP/Operations Plan must be updated to include a map or a description of where finished compost is to be stored.
Compliance: EDOP/Operations Plan revisions will be verified during inspections, and do not need to be submitted to the Division for review.
Sections 14.2.4(K)(1), 14.3.5(K)(1), and 14.4.5(K)(1) Certified Operator Training
Facilities: Class I's accepting food waste, Class II, Class III
Revision: These compost facilities must now have at least one employee on staff that has completed a nationally recognized or equivalent training on compost operations.
Schedule: March 30, 2025 - A certified operator must be on staff with a record of certification maintained in the facility's records, and the EDOP/Operations Plan should be updated to include this as a required training for at least one staff member.
Compliance: A facility may go no longer than 12 months without a certified operator. EDOP/Operations Plan revisions will be verified during inspections, and do not need to be submitted to the Division for review.
Note - A typical compost operator training is a weeklong course. If you have questions about the validity of a training course, please reach out to me.
Please note that all EDOP changes associated with these regulatory revisions will be reviewed during inspections, and do not need to be submitted to the Division for review.