Improved NASM Framework for Food Processing Wash-Water and Solid Residuals

Research was conducted on non-agriculture source material (NASM) data and legislation to identify knowledge gaps and limitations associated with the regulatory framework within Ontario. The framework for NASM land application on farm fields is set out in Ontario Regulation 267/03 under the (Nutrient Management Act, 2002, S. O. 2002, Chap. 4. https://www.ontario.ca/laws/statute/02n04 ). Currently, Category 2 NASM (including waste and wash-water from processed fruits and vegetables) and Category 3 NASM (including dairies, abattoirs, and sewage biosolid facilities) have stringent requirements that agri-food processors must follow when looking into land application disposal. Agri-food processors have suggested that the regulations are overly burdensome for smaller facilities due to the cost for ongoing sampling, documentation, and reporting requirements, which hinders their economic expansion. Following the requirements set out in Ontario Regulation 267/03, agri-food processors have identified that their food processing wash-water samples rarely exceed the regulatory limits for heavy metals under Ontario Regulation 267/03. Thus, processors are questioning why they need to continue analyzing for these constituents as this is a repetitive cost to their business, and if any improvements can be made to the regulatory framework to make it more economically feasible without harming the environment. Overall, this project looked at identifying possible improvements to the Ontario Regulation 267/03 framework to assist agri-food processors with cost-effective land application, with a focus on heavy metal sampling requirements. In the first phase of the project, data was collected and summarized from wash-water facilities to characterize the NASM they produced. The NASM data from various agri-food facilities showed that most of the samples were routinely below the lowest threshold for concentration (CM1 level) and always below CM2 levels, a higher concentration but still within the allowable regulatory limits. Next, a thorough jurisdiction scan of North American standards gave insight into possible improvements to Ontario's land application framework. Findings show that Ontario has established one of the best systems for land application to protect the public and the environment. However, it is evident that this regulatory framework is overly burdensome for non-variable food processing sources and hinders the feasibility of diverting this beneficial organic matter in the form of NASM from landfills. Recommended improvements include decreased sampling frequencies for heavy metals if there is an evidence of low metal occurrence and increased application timeframes if the weather permits.