Local Enforcement Agency Correspondence

CIWMB follow-up plans in response to Department of Health Services report: "Bioaerosols and Green-Waste Composting in California"

As you may know, the Department of Health Services (DHS) recently released a report entitled "Bioaerosols and Green-Waste Composting in California," dated June 1999. The report updates and complements information provided in California Integrated Waste Management Board’s (CIWMB) Local Enforcement Agency (LEA) Advisory Number 6, "Aspergillus, Aspergillosis, and Composting Operations in California," issued December 16, 1993.

We wish to thank DHS for conducting this important literature review and for working diligently to incorporate our comments during drafting of the document. As part of our discussions with DHS, CIWMB agreed to provide follow-up training on this and related issues. We are writing today to let you know that CIWMB plans to develop additional technical materials and training for LEAs and operators during the next year. Our outreach efforts will focus on many organic materials compost issues including managing bioaerosols. We view the provision of these additional materials and training as critical in supporting the development of a safe and vibrant composting industry.

Dealing with bioaerosol issues is not a simple matter. Dose-response data linking demonstrated health effects to emissions from green material composting operations are lacking; furthermore, regulatory standards against which to assess monitoring data are lacking, rendering such data exceedingly difficult to use for enforcement purposes. Due to these gaps in our scientific and regulatory frameworks, and because of related needs regarding odor management, CIWMB has contracted with the California Polytechnic State University at San Luis Obispo to:

• Develop a Resource Guide for enforcement agencies and organic material site operators that describes best management practices -- specific to organic material processing sites in California -- for preventing and mitigating public health and nuisance problems;

• Develop and implement a research study to investigate airborne bioaerosol levels from organic materials processing sites; and

• Develop and implement a statewide study to gather accurate information on odor occurrences in California and successful operations, mitigation, and/or prevention methods, which have been successful at California sites.

At the same time, CIWMB will examine potential changes to the current composting regulations; prepare, as required by SB 675, recommendations regarding odor management for our Board’s consideration; and pursue revising LEA Advisories related to these issues. These efforts link together to provide the subject matter for materials and training referenced above. They also will be subjects of discussion at the upcoming "SB 675/Organics" workshops that CIWMB plans to hold in September 1999. You should be receiving a workshop registration brochure in the near future.

CIWMB is committed to developing a framework of regulations and associated interpretive and training materials that better protects public health and safety and, at the same time, increases business opportunities for organic materials processing. We look forward to your participation in the September workshops, your input on amending the composting regulations, and your input and participation in subsequent training related to both bioaerosols and odor management. We hope that developing this array of activities and information will help LEAs implement effective enforcement strategies and help organic material site operators run safe and efficient operations.

cc: Sandra McNeel, Department of Health Services
     Richard Kreutzer, Department of Health Services
     Board Members, CIWMB
     Ralph E. Chandler, Executive Director, CIWMB

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