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Food-Safe Compost and Manure Use
17 Plays4 years ago
This episode features Kristin Esch, a produce safety specialist with the state of Michigan, and Brad Morgan, president and CEO of Morgan Composting. They discuss the best ways to treat, handle, and store compost or manure with regards to produce safety.
Funding for this podcast was made possible in part by the Food and Drug Administration through grant PAR-16-137. The views expressed in the posted materials do not necessarily reflect the official policies of the Department of Health and Human Services, nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.
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Transcript
00:00:00
Speaker
Hello
Introduction to Food Safety and Composting
00:00:01
Speaker
and welcome to the Agri-Food Safety Produce Bites podcast, where we discuss all things produce safety and dive into the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule. Today we have Kristin Esch and Brad Morgan here, and they're going to be talking a little bit about food safe compost and manure use.
00:00:21
Speaker
My name's Kristin Esch and I'm the Produce Safety Specialist with the state of Michigan. I work primarily to deliver education and outreach regarding the produce safety role to farms. I'm Brad Morgan, President and CEO of Morgan Composting Incorporated. Our role here is to design, create, and alternative fertilizers as well as compost for
00:00:49
Speaker
pretty much a mixed bag of every crop grown as far as I know.
The Birth of Morgan Composting
00:00:54
Speaker
So Brad, how did you get into the business of making compost? Well, most everybody knows that I had a dairy farm for multiple years and we was one of the first
00:01:04
Speaker
first in the state of Michigan to actually start buying our, all of our feed, which allowed me an opportunity to realize that I had a manure problem. So the manure problem was then turned into Morgan composting. And currently today we have five composting sites in the state of Michigan. Awesome.
Understanding Biological Soil Amendments
00:01:25
Speaker
So Kristen, do you want to explain a little bit about biological soil amendments of animal origin and what it means to be treated versus untreated?
00:01:34
Speaker
Sure. So when we talk about biological soil amendments of animal origin, that is the term that FDA uses, the Food and Drug Administration uses in the new produce safety rule. And they use that term and not just manure, because it encompasses everything, including things like blood meal, feather meal, quite frankly, bodies of dead animals, all that is encompassed in this. So it's not just manure that we're talking about.
00:02:06
Speaker
But a BSAAO is treated, and this is basically from the rule, if it's been processed to completion to adequately reduce microorganisms of public health significance. So basically it's making sure that you're using a, it's usually a heat process to kill those organisms that may cause
00:02:35
Speaker
health issues in humans. And the untreated BSAO is something that's basically not processed to completion under a scientifically valid process. And that's of significance because
00:02:54
Speaker
Composting is an active process. It's not something where you can just put manure in a pile for a year or so and call that composted because that's not killing the organisms in a proper way that we need to.
00:03:08
Speaker
Also, if a composted product has come into contact with a raw product after it was done, a lot of people may add raw product throughout the process. That's also not going to be a scientifically valid processing. And if you're not doing temperature checks or turnings or properly maintaining the compost pile, that would still be considered untreated.
Safe Handling and Storage of Compost
00:03:39
Speaker
So this question is for both of you. With regards to food safety, is there a best way to handle and store compost? Definitely. And it's probably not really easy, is it, Brad? You know what, though? It's necessary. There's no cutting corners. So go ahead, Kristin, and you explain. And then what I'll do is summarize our process. OK.
00:04:05
Speaker
So when you have a compost, a finished product, you want to make sure that you keep things in mind to minimize any risk of recontamination. So making sure that if you do have to use the same tools, that you are cleaning and sanitizing those tools in between uses with treated and untreated. Same with storage. You want to make sure that you're storing that in locations where you're going to minimize risks.
00:04:34
Speaker
And when you only have, if you have rakes and that's how you're going to do it or shovels, it might be a little bit easier to buy a second set of tools and that way you could definitely keep things separated. But if you have larger equipment, it's maybe one Bobcat or something, that'd be very difficult to make sure that you're keeping things clean. Difficult, but doable. So you want to make sure that you separate
00:05:01
Speaker
tools and making sure that you're keeping things cleaned and sanitized in between use. From our standpoint, one of the things that we look at is from start to finish all the way through. So we've established a procedure that, number one, always bases on a recipe to start with.
00:05:19
Speaker
From there, then there's a procedure and we've adapted it for all of our operators to basically have a hand-held device that they can answer specific questions as far as what their operational procedure is.
00:05:34
Speaker
And we've done a very good job of implementing that from start to finish. But as Kristin's talking about is for us, one of the things that I think a lot of composters or people miss is even if you have 100% efficient equipment, there's always touch points in a compost operation that are overlooked or forgotten. One is that bottom one inch of material at the bottom of a compost windrow.
00:06:02
Speaker
that if you don't manage properly or flip or can reincorporate, we have found that there is a potential for contamination within that system.
Composting Protocols and Safety Measures
00:06:13
Speaker
The other is the ends of the windrow where they taper off. Sometimes the moisture will dry out so much that you actually dry them out and they don't actually hit temperature, so you have to constantly be folding them back in.
00:06:26
Speaker
Some of them little details that we've done over the past 22 years, I think are probably a measurement of our commitment to what we're trying to do in food safety that maybe most composters don't understand.
00:06:42
Speaker
or won't take the time to do. And then it goes right from there to not only testing for nutrient to know what we have available for a marketable product, but then what we're really finding is the biological stuff that we're testing, not only with Marisol and their staff, but through Ward Labs as far as understanding what biology we're creating.
00:07:06
Speaker
So our process is very much geared towards thermophilic composting. That means by day two, by day three, we should have 140 degree temperatures if everything's right. And over the course of 30 days, turning every three days, we make certain that all of the above are met.
00:07:27
Speaker
But what we've really found is to enhance our success for not only food safety, but if you're touching it and it's running through equipment, you actually want to screen it early enough in the system to where it actually can reheat in your static piles. So there's some things that we're doing that we're monitoring that might be kind of interesting
00:07:52
Speaker
in the future of how that whole thing. And then at the end, you have to test it. You have to be able to make sure there's no E. coli salmonella or the lotharia in it, and you have to be able to validate it. So all of the little things that seem to be minor, over 22 years, we've established a protocol, a process that makes certain that we are where we want to be. Does that make sense?
00:08:18
Speaker
Yeah, that's that's really good. I like that you have a protocol developed for that helps your employees, I'm sure, understand what they need to do throughout the process too. And I was wondering, Brad, do you have if something happens, do you have a cleaning sanitizing protocol? Absolutely.
00:08:37
Speaker
The other thing we have is enough equipment to where when we're working on raw manure, that equipment is not the same equipment. I shouldn't say that. It could be the same equipment, but if they move from raw manure to moving to making a finished product, we have a sanitizing plan, but also we try not to even use the same equipment in the same area. We're putting up a building
00:09:05
Speaker
I don't know if you knew it, but we're putting up a very large building, 120 by 250, and it is specifically for that type of a situation. So there's constant progress being made within our system that should allow more opportunity for us to do the right things all the way through.
00:09:27
Speaker
I don't know if I answered your question, Kristen, did I? Yeah, you sure did. Thank you. All right. So speaking of manure.
00:09:38
Speaker
How do you safely apply manure to crops?
Manure Use in Crop Production
00:09:41
Speaker
And what are some other food safety considerations when it comes to manure? Go ahead, Preston. Well, according to the produce safety rule, there are expectations when applying raw manure, untreated manure.
00:09:59
Speaker
Basically, you don't ever want to contact any kind of fresh produce with manure. That actually starts at the beginning when the plant starts to flower. Once you get that flowering, the rule doesn't allow for you to apply any manure that would touch that product.
00:10:23
Speaker
Now, you can apply manure on the ground if it's not root crops. But things you want to think about, though, are people walking through that area? Will they then use a ladder? Do they climb a ladder to pick the product? Those kind of things you have to think about when you do apply manure. But the big overall message here is never apply manure where it would contact fresh produce.
00:10:49
Speaker
We, we personally, we have all the tools and what I mean by that is they have the option of being able to use compost, a processed feather meal, blood meal. We have a lot of tools for them not to be forced into using straight manure. So we kind of recommend that manure should be used ahead of any risk.
00:11:13
Speaker
All right. Why take the, our logic is why do we need to take the risk of using manure? If there's a risk, if we have compost, if we have the right tools, then, then just give them choices. And for us, we can't, I don't know, we can't be the moral conscious of everybody, but we really do recommend that for instance, in front of corn, soybeans, wheat, you have a timeframe. But if you're doing into vegetable production,
00:11:42
Speaker
If you're going to apply manure, we recommend you apply manure in the fall, use a cover crop, and that way by spring, the risk factors are gone. So we just try to encourage people to do the manure application because realistically, using chicken manure in general is kind of a no-brainer when you think about the economics of where it fits in for fertility. But the best way to do it is if you can do it in the fall,
00:12:09
Speaker
Especially if you can use a cover crop, especially if you can make a plan ahead of time. And it just, to me, that's the benefit of where we can use layer manure in that system. Yeah. And to build on that, the rule and guidance says that they would recommend that you follow the national organic standards, which is 120 days.
00:12:31
Speaker
prior to harvest. So we do recommend, as Brad said, same thing. If you are going to apply it, it would probably be best to apply in the fall. And if a farmer does not have a choice, then you can become more detailed. But the reality of it is most of the farms today have a choice. So if they can think ahead and make that plan ahead of time, it just takes all the risk factors away. And I shouldn't say,
00:13:00
Speaker
My assumption, it takes all the risk factors away. Would you agree, Kristen? Yeah, it certainly brings them down. And again, though, we want to make sure that even if you do apply in the fall, that you're still cognizant of different things. And I think this is the next question that we're coming up to is, like I said before, the ladder use, or we do see quite frequently where they'll use buckets or bins and they'll be placed on the ground.
00:13:27
Speaker
And then those bins will be stacked inside of each other. So those are just different food safety considerations when you're applying any kind of manure. Most of our manure is handled in large scale bulk. You know what I mean? Semi-load quantities. The other thing I would emphasize is when you think about handling manure, think about application rates.
00:13:55
Speaker
A little as good, a lot's got to be better. In farming in general, we have that tendency to think more is always better. But even with manure, there's a point in time where managing it like you would any kind of a fertility program and then making certain that you value it accordingly just makes sense, not only for food safety, but for economics. Agreed, yeah.
00:14:21
Speaker
Brad, what are your time, temperature, and turnings when making
Aligning Composting Methods with FSMA
00:14:25
Speaker
compost? How did you come up with that method? Well, years ago, when I first started this, I come to the conclusion that if I was going to make a compost, we was going to make the best compost that we knew how to make. I spent quite a bit of time. We hired a guy by the name of Joe Stringer.
00:14:45
Speaker
and joe was very anal about if we're going to make a compost it's going to be the best quality and we're going to take no risk we're going to have no risk of making this and if at some point in time anybody that knows joe or knows his direction would know that he would guide into making that well the more i learned from joe the more i wanted to learn the more i seen what kind of success we could have we became very adamant about
00:15:13
Speaker
developing the very best products that we could. So we immediately started out by doing thermophilic compost and I went to a
00:15:24
Speaker
seminar in Illinois with Edwin Blosser. We've taken that to the extreme. I will not deny that. We're very anal about every detail. But I think if we're going to be focused on recycling, if we're going to be focused on composting, if we're going to be refocused on making certain that we're utilizing all of our resources, they have to become a product. They can't just become a throwaway. How do we get rid of it? How do we throw it in the pile and make it disappear?
00:15:53
Speaker
Once we got to the point where we started making compost, we just automatically implemented every three-day turning cycle.
00:16:01
Speaker
we automatically implemented a temperature, a CO2 meter, you know, all of the tools to make certain that we was doing everything we knew how to do. And today we've actually modified that and now we've brought it in because as you get bigger, what happens is you're counting on your employees to do things right too. So for us, we had to implement a procedure that the employees could follow and then it had to measure up to the economics of how we was gonna make it happen.
00:16:31
Speaker
So then, Kristin, what does the FISMA Produce Safety Rule have to say about time, temperature, and turnings? So in the Produce Safety Rule, there's actually two types of composting processes that is actually codified within the law. The first one is the static pile. But when we talk about static, it still is an active process. It has to be oxygenated.
00:16:56
Speaker
The temperature must come up to a minimum of 131 degrees Fahrenheit for three consecutive days, then allowing for a curing process. The other is the one that Brad generally does is the windrows are turned compost and the law indicates that it has to get up to 131 degrees Fahrenheit minimum.
00:17:19
Speaker
for 15 days, but those days do not have to be consecutive. And there has to be a minimum of five turnings. And then again, the curing process. So that's what's codified within the law. There are other ways to make compost that are safe, but they must meet certain microbial requirements that are in the rule if you're going to use other than the two that are in the law.
00:17:47
Speaker
Kristin, now I think I can explain. What we do is we do both. Our objective is
00:17:55
Speaker
to meet 140 degree temperatures within the first 48 hours. And we want to maintain that temperature all the way through for a minimum of 30 days. In that 30 days, we will flip the base of the windrows, tuck the ends into all of them. So we have documentation on all the windrows and we have, I'm going to say a minimum of 10 to 15 turning times, depending on the materials and what we're doing.
00:18:21
Speaker
And then what we do is we run it through a screening plant and then we put it into a static pile for curing.
00:18:27
Speaker
And that temperature will also go back up to 140 degrees, and it will slowly break down to the point of 120, 110, and so forth. So what we found is our fungal activity really don't start, because now we're getting mycorrhizal fungi within the system. But we're getting most of that in the static pile after the thermophilic process.
00:18:53
Speaker
So there are some things that we're actually able to test now that we're seeing. So in a roundabout way, Kristin, we actually use both processes, if that makes any sense. Yeah, it does. One more question for you, if you don't mind.
Biosolids: Use and Public Perception
00:19:09
Speaker
Do you guys use any biosolids? We do, but we keep them isolated to one operation. Okay. And the reason is because of polymers.
00:19:21
Speaker
It isn't because I can't make a good compost and it isn't because it's not a good product, but for organic certification, it becomes an issue of making certain that that product has to go into a conventional system. But biosolids, I'm not afraid of biosolids and I think it's going to be something that's going to have to be part of the long-term plan. So I don't know what your thoughts are on that. I'd love to hear them.
00:19:48
Speaker
But I think biosolids is something that could be utilized in this source. But I think we've got to either learn how to adapt the polymers to fitting the organic certification, or we have to isolate them into a place where we know where they're going to be and they're not. Yeah. So I worked in the livestock industry for quite some time before this. And so I don't consider manure or biosolids or anything a waste. To me, they're a good organic product that needs to be utilized.
00:20:16
Speaker
And you can use, uh, biosolids in a fresh produce production. But like you said, we need to make sure we're doing it, doing it in the best, safest manner possible. Um, but yeah. Years ago, do you remember Eagle, Ottawa, leather tannery? One of the very first composting operations that we worked with was over in Walkerville and they did all the biosolids from the Eagle, Eagle, Ottawa, leather tannery. Now since then they've shut that operation down.
00:20:45
Speaker
But we was exposed to doing that process and working with that company for quite a few years. And we learned an awful lot on composting biosolids. But there's just enough gray area in biosolids that we want to know where they're coming from, what they're about. And we want to make sure that we don't jeopardize our marketing and our, how do I word it, image.
00:21:11
Speaker
per se. Yeah, it's perception. Bio-salads have a bad perception. So we're very cautious of what we take, where we take them and how we handle them. But I would love to share what we're doing with you and eventually I think it could be used into most any kind of operation.
FSMA Documentation for Produce Buyers
00:21:29
Speaker
So lastly, in terms of documentation, what might buyers ask for from Brad in order to be FSMA compliant?
00:21:36
Speaker
So with the produce safety rule for fresh produce farmers that fall under the rule, they have to have documentation to show their inspector. And they have to get documentation at least once per year that the process used was a scientifically valid process and has been handled, stored, and conveyed in a manner that minimizes risk of contamination.
00:22:02
Speaker
So if they're buying from you, a firm would just need that information provided to them annually. Thank you guys so much for coming out and being a part of this episode. Yeah, we appreciate it.
00:22:16
Speaker
Links or definitions to anything referenced in this episode are provided in our show notes, which can be accessed on the website at c-a-n-r dot m-s-u dot e-d-u slash agri-food underscore safety. Thank you to everyone for listening and don't forget to tune in next month for another episode of our Produce Bites podcast.