Information on Analysis Requirements for Non-Agricultural Source Materials
This document includes the following information:
The information contained in this Information Sheet is not authoritative. It is derived from the NMA and O. Reg. 267/03 and is for informational purposes only. Efforts have been made to make it as accurate as possible, but in the event of a conflict, inconsistency or error, the requirements set out in the NMA and O. Reg. 267/03 take precedence. Please refer to E-Laws for what the NMA and O. Reg. 267/03 actually provide. The Government of Ontario assumes no liability for any inaccurate or incomplete information nor for any actions taken in reliance thereon. Prior to implementing any changes to your operations, it is strongly recommended that you review the NMA and O. Reg. 267/03 directly and seek any advice you consider appropriate from a qualified person.
This document provides information on the various analyses that are required for Non-Agricultural Source Materials (NASM) to be applied to agricultural land under the Ontario Regulation 267/03 – General, as amended (Regulation), made under the Nutrient Management Act, 2002, S.O. 2002, c. 4, as amended.
NASM are treated and recycled materials from non-agricultural sources like leaf and yard waste, fruit and vegetable peels, food processing waste, pulp and paper biosolids and sewage biosolids. A material cannot be categorized as a NASM unless it can be shown to have a benefit for the soil and to crops grown on that land.
Accurate sampling and analysis of NASM and soils is critical. A NASM must be of an acceptable quality to be applied to agricultural land, the land must meet certain criteria to receive NASM, and the application rates of NASM to land must not exceed maximum allowable rates as specified in the Regulation.
Requirements for testing NASM and soil receiving NASM are detailed in the Regulation and in the Sampling and Analysis Protocol. Part IX of the Regulation specifies the sampling frequency and testing parameters for soil and NASM. The requirements depend on the category of NASM.
New NASM Categories
Quality-based standards have been introduced for NASM, allowing the materials to be classified under one of three categories. Each of the categories can be applied to agricultural land, providing valuable nutrients to soil and crops and potentially saving farms money:
- Category 1: Unprocessed plant material (e.g. vegetable culls).
- Category 2: Processed plant material (e.g. organic waste materials from a bakery).
- Category 3: Animal-based NASM (e.g. organic residual material from meat processing plant, pulp and paper biosolids and municipal sewage biosolids).
The land application standards in O. Reg. 267/03 vary based on the category and quality of NASM being applied.
A list of common NASM are presented in Appendix A.
If Category 1 NASM is applied to land at a rate of less than 20 tonne wet weight per hectare per calendar year, no NASM sampling or analysis is required.
Analysis requirements for Category 1 NASM applied at rates greater than 20 tonne wet weight per hectare per calendar year, and for Category 2 and 3 NASM, are summarized in Table 1. Pathogen analysis requirements are addressed in another section in this document.
There are some Category 2 and 3 NASM which have additional testing requirements for various contents, including sodium (Na), fats, oil and grease (FOG), and/or boron. The types of NASM that need such additional testing are identified in Appendix A. The Ministry of Agriculture, Food and Rural Affairs (OMAFRA) can request generators of Category 2 or 3 NASM to test the material for additional parameters prior to approving their land application.
Sampling and analysis requirements under the Nutrient Management Regulation are in addition to any other sampling and analysis that the generator may be required to do under another authority such as a Certificate of Approval. All soil and NASM analysis must be completed by laboratories in accordance with the "Sampling and Analysis Protocol". Summaries of acceptable analytical methods are presented in Section 4 of the Protocol, which is posted online.
The NASM Plan Developer must calculate the plant available nitrogen, plant available phosphate and plant available potash to determine whether the NASM meets the beneficial use criteria. The lab may facilitate these calculations by providing an analysis of TKN, ammonium & ammonia-N, nitrate & nitrite-N and total P as either mg/kg dry weight for a solid NASM or mg/litre for liquid NASM. OMAFRA defines a solid as a material with greater than or equal to 18 per cent total solids, or a slump of 150 millimetres or less using the Test Method for the Determination of Liquid Waste (slump test) (as set out in Schedule 9 to Revised Regulations of Ontario, Regulation 347 – General – Waste Management, as amended, made under the Environmental Protection Act, R.S.O. 1990, c. E. 19, as amended (EPA).
The 11 regulated metals referred to in Table 1 are:
- Arsenic (As)
- Cadmium (Cd)
- Cobalt (Co)
- Chromium (Cr)
- Copper (Cu)
- Lead (Pb)
- Mercury (Hg)
- Molybdenum (Mo)
- Nickel (Ni)
- Selenium (Se)
- Zinc (Zn)
In the Regulation, NASM are further categorized based on concentration of regulated metal. There are two sub-categories of regulated metals: CM1 and CM2.
- "CM1" means that the regulated metal content of a NASM does not exceed the concentration set out in Table 2 for aqueous or non-aqueous CM1 material, whichever applies.
- "CM2" means that the regulated metal content of a NASM exceeds that of CM1 NASM but does not exceed the concentration set out in Table 2 for aqueous or non-aqueous CM2 material, whichever applies.
If any one, or more, of the metals exceed the CM1 level then the material is designated as a CM2. If any one or more metals exceed the CM2 level then the material cannot be land applied as a NASM.
1 TS denotes total solids.
2 dw denotes dry weight.
Similar to the regulated metals, there are two sub-categories of NASM based on the level of pathogens: CP1 and CP2. Given their origins, Category 1 and 2 materials are assumed to be CP1 and are not required to be sampled and tested for pathogens.
Category 3 materials are assumed to be in the sub-category CP2. Under the Regulation, sewage biosolids and any other Category 3 materials containing human body waste must be analysed for E.coli and must demonstrate levels lower than 2 million CFU per 100 ml for an aqueous NASM, or 2 million CFU per gram of total solids dry weight for a non–aqueous NASM. Sewage biosolids, or materials that contain human body waste, cannot be land applied if E.coli level exceeds these maximum levels.
Table 3 summarizes the sub-categories of NASM based on typical pathogen levels for such material.
A generator or receiver who wishes to demonstrate that a Category 3 material falls under the CP1 sub-category, must have the material analyzed for specific pathogens. The analyses that are required depend on whether or not the material is sewage biosolids or contains human body waste;
- if the Category 3 NASM is not sewage biosolids and does not contain human body waste, it must be tested for E. coli, Salmonella, Giardia, and Cryptosporidium;
- if the Category 3 NASM is sewage biosolids or does contain human body waste, it must be tested for E. coli, Salmonella, Viable Helminth ova and Total culturable enteric virus.
If Category 1 material is applied to land at a rate of less than 20 tonne wet weight per hectare during a calendar year, no sampling or analysis of the receiving soil is required.
Soil receiving Category 1 NASM applied at rates greater than 20 tonne per hectare during a calendar year (on a wet weight basis) or Category 2 or 3 NASM must be sampled and analyzed within five years prior to the planned application date of the NASM. The samples must be tested for:
- Soil pH,
- Available phosphorus,
- Available potassium, and
- Eleven (11) regulated metals.
The concentration of each regulated metal in the soil sample must be reported in milligrams of metal per kilogram of total solids, calculated on a dry weight basis. The maximum allowable metal concentrations in soils intended to be receiving NASM are presented in Table 6.
1 dw denotes dry weight.
All soil and NASM analysis must be completed by laboratories in accordance with the "Sampling and Analysis Protocol". Summaries of acceptable analytical methods are presented in Section 4 of the Protocol, which is posted online.
The Sampling and Analysis Protocol also provides details about the following laboratory analysis requirements:
- Laboratory Quality Management
- Laboratory Method
- Method Working Range
- Method Detection Limit (MDL)
- Recommended Laboratory QC/QA Procedures
- Reporting Detection Limit (RDL)
- Data Acceptance Criteria
- Data Reporting
Table 7 provides information on the type of containers to use for submitting a NASM or a soil sample for analysis of various parameters and a summary of other field quality control procedures that must be used. The laboratory must ensure that NASM samples or soil submitted for analysis are packaged in the appropriate container and that the NASM generator or NASM Plan Developer are aware of the Field Quality Control Procedures. The analysis is a critical component of the development of a NASM Plan. More information on how to sample NASM and soils is provided in section 2 of the Sampling and Analysis Protocol.
*Please note that E. coli (Method E3433) does not confirm presence of pathogenic E. coli.
List of Material for Each Category of Non-Agricultural Source Materials - Schedule 4 of the Regulation
|Item||Materials||Additional parameters to be analyzed|
|1.||Culled fruit and vegetables, other than cole crops and onions, but only if the fruits and vegetables have been processed without any use of chemicals, other than food grade chemicals used only to clean the food, the processing equipment and the surrounding area.|
|2.||Peels and pomace produced from fruits and vegetables, other than cole crops and onions, but only if the fruits and vegetables have been processed without any use of chemicals, other than food grade chemicals used only to clean the food, the processing equipment and the surrounding area.|
|3.||Leaf and yard waste that has not been composted.|
|4.||Organic waste matter derived from the drying, cleaning and processing of field and nut crops.|
|5.||Waste products from animal feeds listed in Classes 1, 2, 3, 4 and 5 of Part 1 of Schedule IV to the Feeds Regulations, 1983 (SOR/83-593) made under the Feeds Act (Canada), excluding any materials that contain an animal product.|
|7.||Organic waste matter derived from the production of ethanol (plant based mash).|
|8.||Any mixture of materials listed in Items 1 to 7.|
|9.||Anything listed in Items 1 to 8 that is mixed with agricultural source materials, commercial fertilizer, or compost that meets the Compost Guidelines|
|Item||Materials||Additional parameters to be analyzed|
|1.||Leaf and yard waste that has been composted, but does not meet the requirements for compost set out in the Compost Guidelines.|
Organic waste matter that contains no meat or fish and is derived from food processing at,
Washwater, including materials containing food-grade cleaners, from cleaning the processing equipment and the surrounding area of,
|4.||Culled cole crops and onions, and peels and pomace from cole crops and onions, but only if the cole crops and onions have been processed without any use of chemicals, other than food-grade chemicals used only to clean the food, the processing equipment and the surrounding area.|
|5.||Fruit and vegetables, and peels and pomace from fruit and vegetables, that have been processed with the use of chemicals other than as described in Item 4.||
|6.||Fruit and vegetable processing water that contains no chemicals other than food-grade chemicals.||
|7.||Any mixture of materials listed in Items 1 to 6.|
|8.||Anything listed in Items 1 to 7 that is mixed with agricultural source materials, Category 1 NASM, commercial fertilizer, or compost that meets the Compost Guidelines.|
|Item||Materials||Additional parameters to be analyzed|
Washwater, including materials containing food-grade cleaners, from cleaning the processing equipment and the surrounding area in a facility for processing,
|Fats, oils and grease (FOG) and sodium;|
|3.||Organic waste matter derived from the production of biodiesel.|
|4.||Organic waste matter from grease traps and interceptors.||FOG and sodium;|
|5.||Organic waste matter produced in a dissolved air flotation process used for the treatment of wastewater from food or feed processing or preparation facilities.||FOG and sodium;|
|6.||Waste products from animal feeds listed in Classes 1, 2, 3, 4 and 5 of Part 1 of Schedule IV to the Feeds Regulations, 1983 (SOR/83-593) made under the Feeds Act (Canada) that may contain an animal product.|
|7.||Organic waste matter from the processing of fish.||FOG;|
|8.||Washwater, including materials containing food-grade cleaners, from cleaning the processing equipment and the surrounding area in a fish processing facility.|
|9.||Cooked pet food manufacturing waste.||FOG;|
|10.||Pulp and paper biosolids.||Boron;|
|11.||Sewage biosolids or any other material, other than untreated septage, that contains human body waste.|
|12.||Any NASM that is not listed in Table 1 or 2.|
|13.||Any mixture of materials listed in Items 1 to 12.|
|14.||Anything listed in Items 1 to 13 that is mixed with agricultural source materials, Category 1 or Category 2 NASM, commercial fertilizer, compost that meets the Compost Guidelines, or any other nutrient.|
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