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Message I Page 1 of 1 <br /> Michael Kith [EH] <br /> From: Gebrehawariat, Tadese [tgebreha@CIWMB.ca.gov] <br /> Sent: Wednesday, October 10, 2007 10:51 AM <br /> To: Michael Kith [EH]; Karl, Christine <br /> Cc: Robert McClellon [EH]; Karl, Christine; Poulson, Zane <br /> Subject: RE: compost temperature and turning <br /> Hi Michael & Robert- My reading of the regulation for the requirement of pathogen reduction is that the 15 days at 55 degrees <br /> Celsius (131 degrees Fahrenheit) are continuous days and the 5 turnings of the windrows are within those 15 days. The operator <br /> shall keep a record of the time, temperature, and turnings for review by the LEA and other regulatory agencies. <br /> To confirm that my reading of the regulation is consistent with the practice out in the field, I contacted an LEA who has had a long <br /> experience in the matter, and he confirmed that my reading is correct. Thanks for discussing the matter with us and we hope you <br /> find our response helpful. <br /> From: Michael Kith [EH] [mailto:mkith@sjcehd.com] <br /> Sent: Tuesday, October 09, 2007 10:55 AM <br /> To: Gebrehawariat, Tadese; Karl, Christine <br /> Cc: Robert McClellon [EH] <br /> Subject: compost temperature and turning <br /> Hello, <br /> Can you please clarify the 15 days of 131 F temperature and 5 turns requirement in T14CCR17868.3(b) (3) for windrow <br /> composting process? Does it have to be 15 continuous day$? Does the 5 turns has to be within that 15 days? <br /> I have found the publications, Compost: Matching Performance Needs With Product Characteristic, Guidelines for Writing <br /> Compost or Mulch Procurement Specification, and Composting Reduces Growers' Concerns About Pathogens on CIWMB/organic <br /> website. In Guidelines for Writing..., it stated, "...A minimum internal temperature of 57 C shall be maintained for at least 15 <br /> continuous days during the compost process. The compost shall be thoroughly turned a minimum of 5 times during the compost <br /> process and shall go through a minimum 90-days curing period after the 15-day thermophilic compost process has been <br /> completed..." In Composting Reduces.., it stated, "..Turned windrow systems must be maintained at 131 F or higher for 15 days. <br /> During this period, windrows must be turned at least five times..." <br /> During my routine inspection, I had found that the operator had windrows for approx. 5 months; during that 5 months, the windrow <br /> temp were above 131 F most of the time, but they turned only once or twice per month. Is that acceptable? <br /> If you have more questions please contact via this email or at 209-468-3444. <br /> Thank you, <br /> Michael Kith <br /> San Joaquin County <br /> Environmental Health Department <br /> 10/10/2007 <br />