Terms and conditions for laboratories appointed to undertake the testing of compost under the Compost Certification Scheme aligned to PAS 100 and the

Transcription

1 Terms and conditions for laboratories appointed to undertake the testing of compost under the Compost Certification Scheme aligned to PAS 100 and the Compost Quality Protocol Renewable Energy Assurance Limited Compost Certification Scheme Version 2 Issued: January 2018 Come into effect: January 2018

2 1 INTRODUCTION INDEPENDENCE CONTRACTING WITH AN APPOINTED LABORATORY QUALITY ASSURANCE AND CONTROL APPOINTMENT PROCESS INDEPENDENT ASSESSMENT OF CONFORMITY WITH THESE T&CS TERMINATION OF APPOINTMENT SUB-CONTRACTORS UKAS ACCREDITATION FEES COMPOST SAMPLING AND ANALYSES REQUEST TEMPLATES REPORTING TO COMPOST PRODUCERS AND REPORT FORMAT REPORTING TEST RESULTS TO REAL PRE-ARRANGED INTER-LABORATORY TRIALS SPOT LAB CHECKS METHODS OF TEST FOR COMPOST SAMPLES LABORATORIES SAMPLE PREPARATION, STORAGE AND TRANSIT CONDITIONS APPOINTED LABORATORIES LIST REAL S RESPONSIBILITIES

3 Foreword Renewable Energy Assurance Limited (REAL) has established these Terms and Conditions (T&Cs) for laboratories appointed to undertake testing under the Compost Certification Scheme (CCS). These terms and conditions set out the respective responsibilities of REAL and the appointed laboratories. These latter include: performance and compliance criteria provisions for samples transport, storage, and preparation participation in inter-laboratory trials, spot checks and proficiency testing schemes reporting of test results When appointed by REAL, a laboratory agrees to comply with all the terms and conditions set out in this agreement at all times. A laboratory s appointment will be dependent on the laboratory s compliance with all the terms and conditions set out in this agreement. If REAL should have evidence that a laboratory has not complied with these terms and conditions, its appointment may be terminated immediately on written notice. 3

4 1 INTRODUCTION The Compost Certification Scheme (CCS) is administered by Renewable Energy Assurance Limited (REAL). REAL is a wholly-owned subsidiary company of Renewable Energy Association (REA). The CCS assesses and verifies compost producers conformance with: the latest edition of the British Standards Institution (BSI) s Publicly Available Specification (PAS) for Composted Materials (BSI PAS 100) the Quality Protocol for the production and use of quality compost from sourcesegregated biodegradable waste (the CQP, adopted in England, Wales and Northern Ireland); REAL Scheme Rules (latest version); and SEPA s Composting Position Statement (latest version). The CCS requires participating producers to send samples for testing to appointed laboratories (Appointed Laboratories) only. Responsibility for appointing laboratories to test samples under the CCS can be found in section 17 of this document and rests with REAL. A list of Appointed Laboratories (List) can be found at 2 INDEPENDENCE In order to ensure the credibility of the CCS, an Appointed Laboratory is required to be impartial in testing and reporting the quality of compost samples. An Appointed Laboratory must declare any commercial or corporate link with a compostproducing organisation, compost-producing organisation, or other conflict of interest, and demonstrate how it can guarantee impartiality. If a commercial or corporate link should arise during the term of appointment the Appointed Laboratory must inform REAL as soon as it becomes aware of it. 3 CONTRACTING WITH AN APPOINTED LABORATORY Appointed Laboratories must inform REAL of any changes to their contact details so that REAL can promptly update the List. 4

5 4 QUALITY ASSURANCE AND CONTROL 4.1 Laboratory s management system The Appointed Laboratory must develop, implement and maintain a management system for its testing and calibration activities in line with the requirements of EN ISO/IEC 17025: Laboratory s quality control Routine procedures for quality assurance and control must be in place at the Appointed Laboratory and any sub-contracted laboratory it uses to ensure the quality of the results reported by the laboratory. Internal quality control measures must be monitored and acted upon to improve data variability within an expected margin of error. The principles of quality control monitoring described in NS 30 (A manual on analytical quality control for the water industry) must be followed 1. The manual describes all necessary actions and procedures needed to maintain control for data reporting. These include: ensuring sample homogeneity, representative sub-sampling, use of validated methodology for the appropriate test matrix, use of blanks, replicates and control samples and monitoring of this data using Shewhart control charts. This applies to standard methods and parameters but excludes Scheme-specific, non-standard methods. Quality control is a measure of precision, or how well the measurement system reproduces the same result over time and under varying operating conditions. Laboratory quality control material must be run at the beginning of each shift, after an instrument is serviced, when reagent lots are changed, after calibration, and whenever results seem inappropriate. Quality control material should approximate the same matrix as that required to be tested, taking into account its physical chemical properties. Interpretation of quality control data must include graphical and statistical methods (e.g. Control Charts). Laboratories should produce a dried bulk internal reference, or control sample, that should be included in all test batches except for physical contaminants, stability, and plant growth testing. Certified reference materials (CRMs) can be used for routine quality control purposes where possible. Control charts like Shewhart charts must be set up to record the results of the internal reference or control sample to provide a continuing check on analytical performance. These charts are used to identify random step changes or longer term data trends that may be due 1 Please note that NS30 is based on a test medium (water) which is very different from composted products as it has much fewer degrees of variability between aliquots of the same sample than composted products. What is important is the principles set out in the manual. 5

6 to equipment maintenance or failure. Regular monitoring of these charts will ensure prompt remedial action. 4.3 Technical competence The staff of an Appointed Laboratory must be competent to provide the requisite testing services, to perform the relevant test methods and to produce technically valid data and results. The Appointed Laboratory will be responsible for the competence and behaviour of its staff, and for the staff of those acting on its behalf. 4.4 Internal audits An Appointed Laboratory (and any sub-contractors it may use) must conduct and record internal audits at planned intervals, at least annually, or sooner if required, to determine whether: the correct procedures are being followed, any changes need to be made to improve accuracy, repeatability and reproducibility, equipment performance and efficacy, and the terms and conditions set out in this document are being complied with. The Appointed Laboratory must make these records available to REAL when requested. 4.5 Standard Operating Procedures An Appointed Laboratory (and any sub-contractors it may use) must have Standard Operating Procedures (SOPs) setting out instructions on how to carry out the required tests using the specified methodologies. The SOPs must not deviate from the test methodologies specified in PAS 100, test methodologies approved by REAL where equivalence to PAS 100 tests has been demonstrated or any other instructions specified by REAL. 4.6 Validation of test methods Each test method carried out by an Appointed Laboratory (and any sub-contracted laboratory) under REAL appointment must be initially validated for the specific test matrix (compost). The responsibility for validating a test method and using an appropriate validation method lies with the Appointed Laboratory. Method validation seeks to quantify the likely accuracy of results by assessing the magnitude of both systematic and random effects (see NS30). Typically this is undertaken on a selection of representative samples which would comprise: (i) a blank sample (to facilitate estimation of the method limit of detection); (ii) two standard solutions or samples at the lower and upper range of interest,(iii) a sample and a spiked sample (where possible) to facilitate estimation of recovery and precision on real samples. Typically an experimental 6

7 design of 11 batches analysed on a separate occasion in duplicate for each sample is required (DWi, 2012) 2. ISO covers procedures suited to microbiological analysis. 4.7 Re-validation of test methods/procedures An Appointed Laboratory (and any sub-contractor it may use) must re-validate the specified test methods it uses should there be a change to it (for example, a change to the test method specified in PAS 100 or an improvement to the test method made by the method owner). The responsibility for validating the test method and using an appropriate validation method lies with the Appointed Laboratory. See recommended procedures described in section 4.6. An Appointed Laboratory must inform REAL every time it changes the specification of the equipment it uses to carry out a test method and, in such a circumstance, it may be required to re-validate the test method. An Appointed Laboratory may be required to take part in inter-laboratory trials as part of the re-validation of the test method or new equipment or, if appropriate, to take part in one or more proficiency scheme testing rounds, as may be defined by REAL from time to time. 4.8 Complaint procedures An Appointed Laboratory must follow a process to identify if a corrective action is required or not and, if required, implement any necessary corrective action following any complaints or concern expressed by any interested parties, including operatives, customers, clients, certification bodies, the Scheme Owner or regulatory authorities about the quality of their services. An Appointed Laboratory must record: a) name and contact details of the person who expressed concern or made a complaint; b) specific subject(s) of the concern or complaint; c) date and time communicated to the lab and name of the person to whom it was communicated; d) nature and date(s) of any actions and checks and who carried them out; e) nature and date of any response to the person who expressed a concern or made the complaint; and f) name of the person who communicated the response. 2 DWi, Guidance on the Implementation of the Water Supply (Water Quality) Regulations 2000 (as amended) in England, version 1.1, March 2012, Appendix A, Section

8 An Appointed Laboratory must provide REAL with regular updates on investigations into complaints raised through the REAL laboratory complaints procedures. The Appointed Laboratory must also inform REAL of the outcome of the complaint investigation. 4.9 Testing capacity An Appointed Laboratory is required to keep records of testing capacity throughout the year. These records must document the maximum number of samples that can be tested within a given week. These records must include testing capacity for PAS 100 samples sent for certification purposes and non-pas 100 samples sent for testing using the non-standard methods. These records must be provided to REAL and the Independent Auditor on request. 5 APPOINTMENT PROCESS Laboratories that wish to be appointed must provide a completed application form, a set of test results for three full suites of tests, and undergo an initial assessment by an auditor. All laboratories must perform a full suite of PAS 100 tests on 3 compost samples. These test results will be used to populate data records and demonstrate to the auditor how the laboratory complies with these T&C s. Laboratories must undergo an initial assessment by an auditor appointed by REAL. The auditor will provide REAL with a report of the initial assessment, and a recommendation on whether the laboratory should be appointed. Laboratories may only become appointed when REAL are satisfied that the laboratory has demonstrated they have the capability to deliver testing under the scheme. The initial appointment will be for a period of six months. If continued, the appointment will be renewed on an annual basis subject to passing a full annual audit. Further guidance on the application and appointment process can be found on the BCS website. 6 INDEPENDENT ASSESSMENT OF CONFORMITY WITH THESE T&CS The laboratory s initial appointment or appointment renewal is conditional upon demonstrated evidence of compliance with these T&Cs. Appointed Laboratories must inform REAL at the beginning of the 12 month renewal phases the locations in which testing of compost under the Compost Certification Scheme takes place and the test methods used for analyses. Appointed Laboratories must inform REAL promptly of any decision to change the testing location or test methods. 8

9 6.1 Annual audits For initial appointment and each 12 month renewal phase thereafter, REAL s assessment of conformity with these T&Cs shall include an independent assessment of the Appointed Laboratory. This assessment will include at least one visit to the premises of the Appointed Laboratory and of any sub-contractor it may use (unless this is already audited as an Appointed Laboratory). An audit report will be supplied by the independent auditor to the Appointed Laboratory following the independent assessment listing any non-conformances and any other relevant observations/comments. The type of non-conformity assigned against any of these T&Cs shall be based upon evidence and observations made during the evaluation, whether done before the audit, during that visit, or afterwards when corrective action evidence is being evaluated. Within a week from receiving the audit report the Appointed Laboratory must supply to the independent auditor a list of corrective actions that will be taken to address any nonconformity and indicate the maximum timescale for the completion of such corrective actions. Non-conformities must be addressed in a timely manner and within a maximum of 28 days from the audit date. Depending on the type and nature of the non-conformity the independent auditor may request that the Appointed Laboratory takes corrective actions immediately or may establish that 28 days is not sufficient to complete the required corrective action and therefore extend the maximum allowed timescale. Depending on the type and nature of the non-conformity and whether this affects the validity of the test results, the independent auditor may contact REAL to discuss the nonconformity and if in agreement, the independent auditor and REAL may suspend testing until the non-conformity has been fully resolved. Appropriate actions and maximum timescales for completion of such actions may also be identified by the Appointed Laboratory or required by the Independent Auditor in relation to observations or comments made by the Independent Auditor that are not reported as non-conformities. 6.2 Spot check visits REAL reserves the right to carry out one or more extra audits if these are required to verify that any non-conformity has been addressed by the Appointed Laboratory and any subcontractor it may use. The costs associated with any additional visits carried out shall be borne by the Appointed Laboratory, but shall be kept as low as reasonably possible. 9

10 An Appointed Laboratory (and any sub-contractor it may use) must agree to co-operate with any planned or unannounced spot check external audits carried out by REAL or an external organisation appointed by REAL. 7 TERMINATION OF APPOINTMENT REAL reserves the right to terminate an Appointed Laboratory s appointment if it the Appointed Laboratory is in breach of any of the requirements specified in these T&Cs. If non-conformities have not been addressed within a maximum of 28 days from the audit date, or within the timescales specified by the independent auditor, the Appointed Laboratory will be informed by REAL in writing that the appointment will be terminated in 28 days from receipt of the notice letter. The laboratory will have the right to re-apply but it would not be readmitted until it could demonstrate that the non-conformities had been adequately addressed. 8 SUB-CONTRACTORS An Appointed Laboratory may sub-contract testing of one or more parameters to another laboratory, provided the sub-contracted laboratory complies with all requirements specified in these terms and conditions. Appointed Laboratories must require any laboratories they sub-contract with to comply with these terms and conditions and this must be an express term of the sub-contract. The Appointed Laboratory will be responsible for ensuring that these T&Cs are met at all times. A written contract must be in place between the Appointed Laboratory and the sub-contracted laboratory. The sub-contracted laboratory is responsible for informing the Appointed Laboratory if testing capacity will be exceeded. An Appointed Laboratory will be responsible for carrying out annual audits at any of its subcontracted laboratories it uses to ensure that these Terms and Conditions are adhered to. The outcome of such audits must be recorded. 9 UKAS ACCREDITATION An Appointed Laboratory must inform REAL if it or any sub-contracted laboratory it uses is not accredited by UKAS for Escherichia coli and/or Salmonella spp. of relevant matrices (i.e. compost, growing media etc.). 10 FEES 10.1 Laboratories fees An Appointed Laboratory must inform REAL of the guide fees it will apply for carrying out each parameter test, for each suite of tests and for the analysis of multiple samples when 10

11 REAL requests it. REAL may aggregate such information with that from other Appointed Laboratories and use it in an anonymised form as the basis of scheme guidance on typical fees charged by Appointed Laboratories for compost testing in accordance with PAS 100 and the CQP REAL s annual fees REAL will require Appointed Laboratories to pay an appropriate annual fee. This fee will be a flat rate, calculated so as to cover the costs of: arranging inter-laboratory/ring trials and spot checks; appointing a suitably-qualified contractor to analyse the results of any trials; evaluating the results and writing recommendations following the inter-laboratory trials; appointing an auditor to check the Appointed Laboratory s compliance with these terms and conditions. This assessment will include at least one visit to the premises of the Appointed Laboratory and of any sub-contractor it may use (unless this is already audited as an Appointed Laboratory) 3 ; and evaluating the outcome of the auditor s checks and carry out any further checks required to verify that corrective actions have been taken by the Appointed Laboratories. The flat rate will be based on the assumption that all PAS 100 test methods are carried out at the Appointed Laboratory. REAL reserves the right to charge an appropriate fee to recover the cost associated with auditing any sub-contracted laboratories, when this is required. Where the Appointed Laboratory sub-contracts tests to another Appointed Laboratory, a separate audit of the sub-contractor may not be required. In the event that a planned inter-laboratory trial shows that results precision, trueness, intra-laboratory repeatability and/or inter-laboratory reproducibility is inadequate, REAL reserves the right to charge an extra fee to cover for any additional assessment required to check the laboratory s performance. 3 Note that the time spent by the independent auditor in carrying out the independent assessment and the associated fee will take into account the number and type of tests carried out at the appointed lab and whether any sub-contracted laboratory is already a laboratory appointed by REAL in its own right. 11

12 11 COMPOST SAMPLING AND ANALYSES REQUEST TEMPLATES 11.1 Compost sampling and analysis request templates accompanying routine samples Test results must not be reported to the compost producer unless the sample is accompanied by the relevant PAS 100 Compost Analysis Request Form template correctly completed. In the event of this record template not being provided by the compost producer with the sample or being only partially completed, the Appointed Laboratory must advise the compost producer that the associated results will not be reported until the fully completed record template has been supplied. In the event of receipt of the previous versions of the Compost Sampling and Analysis Request form template, the Appointed Laboratory should confirm with the producer whether the sample was sent for certification purposes. If the sample was sent for certification purposes, then the producer should be advised to complete the new PAS 100 Compost Analysis Request Form with all necessary details. If the sample was not sent for certification purposes, then the test results must not be uploaded to the REAL CCS database Compost sampling and analysis request templates accompanying spot and independent samples The CCS has introduced a programme of independent sampling and spot sampling. As a result, an Appointed Laboratory may occasionally receive spot or independent samples which are accompanied by a clearly identified Independent Sampling and Analysis Request form or a Spot Sampling Analysis Request form. For any clarification on spot or independent samples and associated analysis request forms, the appointed laboratory should contact REAL. An Appointed Laboratory should not seek such clarification or any instructions from the compost producer that is the subject of independent sampling or spot sampling Charges for independent and spot samples An Appointed Laboratory will charge the compost producer who was the subject of independent sampling at the standard rate, unless otherwise specified in the Independent sampling and analysis request form. This needs to be part of the contract / agreement between lab and compost producer. In a similar way, an Appointed Laboratory will charge the organisation indicated in the Spot sampling and request form at the standard rate. This may be either REAL or the compost producer that was the subject of the spot sampling. Spot samples will normally be tested as a part of an investigation into a complaint concerning the quality of the compost sampled. 12

13 12 REPORTING TO COMPOST PRODUCERS AND REPORT FORMAT REAL requires each Appointed Laboratory to use its Analysis Report ~ Composted Material template document, or to modify its reporting system in such a way that the format and information is presented as shown in the REAL s template. An Appointed Laboratory must always provide test results in a PDF format alongside any other format requested by the compost producer (e.g. excel or data files (.cav) for inclusion in bespoke databases). For any parameter test not carried out on a compost sample but shown on the report template, the report s corresponding result cell should display N/A, meaning not analysed. An Appointed Laboratory must retain test reports supplied to the compost producer for a minimum of three years. 13 REPORTING TEST RESULTS TO REAL An Appointed Laboratory must collate all PAS 100 test results generated for certification purposes related to the compost producers and supply them to REAL by uploading the reports to the REAL CCS database. These may include test results obtained for: For initial validation purposes; On-going testing to verify the continued efficacy of the PAS 100 quality management system and compost compliance with PAS 100 minimum quality criteria and any other criteria specified and agreed with the customer; Archive samples that have been tested to verify compliance with PAS100; and Re-sample test results that have been tested to verify corrective actions efficacy. PAS 100 test results generated for certification purposes should be uploaded to the REAL CCS database as soon as reported or no later than two weeks from that date. 14 PRE-ARRANGED INTER-LABORATORY TRIALS In addition, REAL reserves the right to carry out inter-laboratory trials at any time to check Appointed Laboratories performance. In particular, inter-laboratory trials will be designed to check the test results repeatability, reproducibility and trueness. Participation in such trials will be compulsory. An Appointed Laboratory is required to bear the following costs: The cost of sampling by a suitable sampling provider appointed by REAL; The cost of testing, reporting and implementing any required corrective actions; and The cost of the time spent by REAL s staff in setting up and project managing the trial, evaluating the ring trials results and checking the implementation of any corrective actions. 13

14 The above costs are already included in the fees outlined in section 9.2. REAL will carry out inter-laboratory trials approximately every two years, unless participation in proficiency schemes is regarded as sufficient to assess Appointed Laboratories performance. An Appointed Laboratory must implement at its cost and within the prescribed timescales any recommendations or corrective actions identified as a result of inter-laboratory trial. An Appointed Laboratory must record any corrective action or improvement made by the laboratory. Inter-laboratory trials are announced, unlike spot inter lab checks referred to in clause SPOT LAB CHECKS REAL reserves the right to carry out an unlimited number of unannounced spot checks at the Appointed Laboratory and any laboratory it sub-contracts. 16 METHODS OF TEST FOR COMPOST SAMPLES The test methods used by the Appointed Laboratories must be those specified in the latest version of the PAS 100. Appointed Laboratories must follow the instructions specified in the test methods and any additional instructions specified in the laboratory s own validated standard operating procedures. Appointed Laboratories may subcontract one or more tests to another laboratory. In such scenario the Appointed Laboratory will be responsible for ensuring these T&Cs are met at all times E.coli An Appointed Laboratory must be registered on and participate in the VLA QAS Proficiency Scheme PT0164 for E.coli ( Vetqas@ahvla.gsi.gov.uk). If an Appointed Laboratory is removed from the PT0164, it shall notify REAL within 5 working days and will no longer remain appointed by REAL to carry out E.coli testing. REAL is set by the VLA as a viewer, this is allowed to view the proficiency scheme test results and associated VLA reports. When a VLA QAS tabulation of the E.coli test results shows that incorrect values have been reported by an Appointed Laboratory, this laboratory shall carry out an investigation to 14

15 understand why it happened and apply corrective actions to ensure incorrect results are not reported in future distributions. A record of the investigation shall be made and kept by the laboratory and provided to REAL when requested. The record shall include: Reference to the VLA QAS sample distribution period; The reason for the incorrect reported result; and The action/s taken by the laboratory to address the cause of the incorrectly reported result. The VLA QAS will send a repeat set of samples for E.coli to ensure the laboratory s corrective actions have been effective. REAL reserves the right to suspend the lab appointment to carry out E.coli testing in the event the Appointed Laboratory fails to meet the requirements set out above. REAL reserves the right to require any appointed laboratories in future to participate in an alternative proficiency scheme, if this is regarded as more suitable than the one specified above Salmonella An Appointed Laboratory must participate in the VLA QAS Proficiency Scheme PT0164 for Salmonella ( Vetqas@ahvla.gsi.gov.uk). If an Appointed Laboratory is removed from the PT0164, it shall notify REAL within 5 working days and will no longer remain appointed by REAL to carry out Salmonella testing. REAL is set by the VLA as a viewer, this is allowed to view the proficiency scheme test results and associated VLA reports. When a VLA QAS tabulation of the E.coli test results shows that incorrect values have been reported by an Appointed Laboratory, this laboratory shall carry out an investigation to understand why it happened and apply corrective actions to ensure incorrect results are not reported in future distributions. A record of the investigation shall be made and kept by the laboratory and provided to REAL when requested. The record shall include: Reference to the VLA QAS sample distribution period; The reason for the incorrect reported result; and The action/s taken by the laboratory to address the cause of the incorrectly reported result. The VLA QAS will send a repeat set of samples for Salmonella to ensure the laboratory s corrective actions have been effective. 15

16 REAL reserves the right to suspend the lab appointment to carry out Salmonella testing in the event an Appointed Laboratory fails to meet the requirements set out above. REAL reserves the right to require any appointed laboratories in future to participate in an alternative proficiency scheme, if this is regarded as more suitable than the one specified above Stability Within laboratory precision for this parameter achieved during the development of this test method (Llewelyn, 2005) is to 2.0 mg CO2/g VS/day Potentially Toxic Elements An Appointed Laboratory must participate in any proficiency scheme specified by REAL for PTEs. Indicative precision and bias limits for heavy metals are: 7.5% precision, and 10% bias. These values are in line with the precision and bias limits for metals specified in the Environment Agency s Performance Standard for Laboratories undertaking Chemical Testing of Soil (March 2012, Version 4) All other parameters specified in the PAS 100 or the Compost Quality Protocol REAL appointed laboratory or its sub-contracted laboratory shall register and participate in any proficiency scheme specified by REAL for the above parameters. Such a proficiency scheme is not available at the time of writing. If and when such a proficiency scheme becomes available, REAL reserves the right to extend this agreement to require appointed laboratories to participate in a proficiency scheme Re-testing at appointed labs When the analytical procedure that has been used to test a sample at the appointed lab returns a test failure, a replicate of the same sample shall not be re-tested for the failed parameter, unless the laboratory is confident that a failure in the analytical procedure has occurred, resulting in an invalid result. Even when the laboratory is confident that a failure in the analytical procedure has occurred, a replicate of the sample shall only be re-tested if this has been stored according the conditions and the maximum timescales specified in clause

17 17 LABORATORIES SAMPLE PREPARATION, STORAGE AND TRANSIT CONDITIONS 17.1 Storage conditions and max timescales An Appointed Laboratory must test samples as soon as possible after arrival for stability, plant response, weed seeds, E.coli and Salmonella parameters. SALMONELLA AND E.COLI: Appointed Laboratories must ensure that the time between the test samples arriving at the Appointed Laboratory and the start of the test procedures does not exceed 48 hours. ALL PAS 100 PARAMETERS OTHER THAN MICROBIAL PATHOGENS: Appointed Laboratories shall endeavour to start the test procedures within 48 hours from the time the test samples arrive at the Appointed Laboratory. In no circumstances shall the time between the test samples arriving at the Appointed Laboratory and the start of the test procedures (at the Appointed Laboratory or its sub-contracted Laboratory) exceed one week. For all parameters (including Salmonella spp. and E.coli) an Appointed Laboratory must not freeze samples. It must store them in a refrigerator or in cool conditions in a similar contained, dark space in order to minimise any changes to the characteristics of the sample over time Transit conditions and max timescales When an Appointed Laboratory arranges for the samples to be collected from the compost producer s premises, the laboratory must provide cool boxes and ice packs to facilitate suitable and sufficient storage and handling of the sample prior to being received at the lab. When an Appointed Laboratory sub-contracts another laboratory, transit of compost samples from the main appointed laboratory to the sub-contracted laboratory shall never exceed the timescales specified in clause Samples must be delivered to the sub-contracted laboratory in cool, darkboxes with ice packs, to facilitate suitable transport and handling of the sample prior to being received at the sub-contracted lab and to minimise any changes in sample characteristics over transit. The laboratory must check upon receipt of the sample that the compost sample has been transported in the correct conditions and within the maximum specified timescales 4. If 4 Each sample tested in order to demonstrate compliance with PAS 100 shall be sent by the composter to an appropriate laboratory within 1 working day after the sample was taken. REAL strongly recommends that the composter uses a service that will deliver the sample to 17

18 samples are not delivered in the correct conditions or have not been sent by the composter within the correct timescales, the laboratory must highlight this on the test report. Any courier transporting ABP derived compost to be tested for Salmonella and E.coli must be registered AB117 for the transport of ABP material, unless the producer is approved under Article 24 of Regulation (EC) No. 1069/2009 with APHA. ( When the laboratory arranges sample collection on behalf of the composter, it shall agree with the composter in writing the timescales for compost sample collection in compliance with this clause and agree actions in the event the compost sample collection has been missed or has not taken place within the agreed timescales Sub-sampling and sample preparation Laboratory sub-sampling and sample preparation is an essential process that underlies all subsequent work and final test results reliability. Laboratory sub-sampling and sample preparation procedures must ensure that the sample subject to the analytical procedure is representative of the original sample provided by the composter. The Appointed Laboratory s management system, and that of any sub-contracted laboratory it uses, must describe sub-sampling and sample preparation procedures and demonstrate that these meet the objectives stated above. This can be attained through sample receipt and handling Standard Operating Procedures (SOPs). Sample preparation for all test parameters must be done in accordance with BS EN 13040, Soil improvers and growing media Sample preparation for chemical and physical tests, determination of dry matter content, moisture content and laboratory compacted bulk density Replicate numbers The number of replicates tested when performing a test method must be as set out in the relevant test method. An appropriate document within the Appointed Laboratory s management system must state the number of replicates routinely tested when performing the test method. When the minimum number of replicates is not set out in the test method instructions, in addition to specifying the minimum number of replicates used, the the laboratory within 48 hours. Samples should be delivered to the laboratory in a cool box with icepacks and in dark, to minimise any changes in sample characteristics over transit. 18

19 laboratory s management system must justify the basis on which the number has been chosen and demonstrate how this will ensure that reliable results are obtained. 18 APPOINTED LABORATORIES LIST REAL s public list of its appointed laboratories and their sub-contractors shall be in the format shown below and contains as a minimum the following information: Laboratory s name Laboratory s address Laboratory s main contact and associated details 19 REAL S RESPONSIBILITIES REAL is responsible for: Make a list of Appointed Laboratories publicly available and keep the list up to date Carry out or appoint an independent competent organisation to carry out external audits to ensure the Appointed Laboratories comply with all T&Cs in this agreement Update the Appointed Laboratories on the scheme on changes to standards, scheme rules, test methods and associated documentation. 19