Analysis requirements for non-agricultural source materials
Learn about the various analyses that are required for non-agricultural source materials (NASM) applied to agricultural land. This technical information is for Ontario producers.
Overview
Various analyses are required for non-agricultural source materials (NASM) before applying to agricultural land under O. Reg. 267/03, of the Nutrient Management Act, 2002 (NMA) and in the sampling and analysis protocol.
NASM contains 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 is shown to have a benefit for the soil and 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 the land must not exceed maximum allowable rates as specified in Part IX of O. Reg. 267/03. The requirements depend on the category of NASM.
NASM categories
NASM standards are quality based, allowing the materials to be classified under 1 of 3 categories. The NASM in each of the categories can be applied to agricultural land, providing valuable nutrients to the soil and crops and potentially saving farms money:
- Category 1: unprocessed plant material (for example, vegetable culls, leaf and yard waste that has not been composted)
- Category 2: processed plant material (for example, organic waste matter that contains no meat or fish and is derived from food processing at a bakery)
- Category 3: animal-based NASM and others (for example, organic residual material from meat processing plant, pulp and paper biosolids and municipal sewage biosolids)
The Ministry of Agriculture, Food and Agribusiness (OMAFA) fact sheet, Determining odour categories of non-agricultural source materials describes the 3 methods used to classify NASM into odour categories.
The land application standards in the regulation vary based on the category and quality of NASM being applied.
A list of common NASM is found in Appendix A.
NASM testing requirements
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 Category 3 NASM, are summarized in Table 1. Pathogen analysis requirements are addressed in Tables 4 and 5.
| NASM category | NASM analysis requirements |
|---|---|
| 1 |
|
| 2 |
|
| 3 |
|
Note: The 11 regulated metals are:
- Arsenic (As)
- Cadmium (Cd)
- Cobalt (Co)
- Chromium (Cr)
- Copper (Cu)
- Lead (Pb)
- Mercury (Hg)
- Molybdenum (Mo)
- Nickel (Ni)
- Selenium (Se)
- Zinc (Zn)
Source: s. 97 to s. 98.0.5 of O. Reg. 267/03
There are some Category 2 and Category 3 NASM which have additional testing requirements for various parameters, including Na, FOG and/or B. The types of NASM that require additional testing are identified in Appendix A. OMAFA can request generators of Category 2 or Category 3 NASM to test the material for additional parameters prior to approving their land application.
Sampling and analysis requirements under the regulation are in addition to 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 analyses 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.
Analysis reporting
The NASM plan developer must calculate the plant available nitrogen, phosphate and potash to determine whether the NASM meets the beneficial use criteria. The laboratory may simplify these calculations by providing an analysis of TKN, ammonium and ammonia-N, nitrate and nitrite-N and total P as either mg/kg dry weight for a solid NASM or mg/L for liquid NASM.
OMAFA defines a solid as material with greater than or equal to 18% total solids, or a slump of 150 mm or less using the Test Method for the Determination of Liquid Waste (slump test) (as set out in Schedule 9 of Regulation 347 – General – Waste Management, as amended, under the Environmental Protection Act, 1990 (EPA).
In O. Reg. 267/03, NASM is further categorized based on the concentration of regulated metal. There are 2 sub-categories of regulated metals:
- 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.
| Parameter | CM1 aqueous material <1% TS (mg/L) | CM1 non-aqueous material (mg/kg dw) | CM2 aqueous material<1% TS (mg/L) | CM2 non-aqueous material (mg/kg dw) |
|---|---|---|---|---|
| As | 0.13 | 13 | 1.7 | 170 |
| Cd | 0.03 | 3 | 0.34 | 34 |
| Co | 0.34 | 34 | 3.4 | 340 |
| Cr | 2.1 | 210 | 28 | 2,800 |
| Cu | 1.0 | 100 | 17 | 1,700 |
| Pb | 1.5 | 150 | 11.0 | 1,100 |
| Hg | 0.008 | 0.8 | 0.11 | 11 |
| Mo | 0.05 | 5 | 0.94 | 94 |
| Ni | 0.62 | 62 | 4.2 | 420 |
| Se | 0.02 | 2 | 0.34 | 34 |
| Zn | 5.0 | 500 | 42.0 | 4,200 |
Source: Schedule 5 of O. Reg. 267/03
Similar to the regulated metals, there are 2 sub-categories of NASM based on the level of pathogens: CP1 and CP2. Given their origins, Category 1 and Category 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 analyzed 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.
| NASM category | Pathogens |
|---|---|
| 1 | CP1 (assumed) |
| 2 | CP1 (assumed) |
| 3 | CP2 (assumed but may be tested to confirm CP1 status). Sewage biosolids and anything mixed with human body waste are required to test for E. coli |
Source: s. 98(3) and s. 98.0.1(3) of O. Reg. 267/03
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 required analyses 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.
The requirements to demonstrate that a Category 3 NASM meets CP1 quality standards are summarized in Tables 4 and 5 for both aqueous and non-aqueous materials.
| Pathogen | Level in aqueous material | Level in non-aqueous material |
|---|---|---|
| E. coli | 1,000 CFU per 100 mL | 1,000 CFU per gram of total solids, dry weight |
| Salmonella | 3 CFU or MPN per 100 mL | 3 CFU or MPN per 4 grams of solids dry weight |
| Giardia | No detectable level in 100 mL | No detectable level in 4 grams of total solids, dry weight |
| Cryptosporidium | No detectable level in 100 mL | No detectable level in 4 grams of total solids, dry weight |
Source: Schedule 6 of O. Reg. 267/03
| Pathogen | Level in aqueous material | Level in non-aqueous material |
|---|---|---|
| E. coli | 1,000 CFU per 100 mL | 1,000 CFU per gram of total solids, dry weight |
| Salmonella | 3 CFU or MPN per 100 mL | 3 CFU or MPN per 4 grams of solids dry weight |
| Viable Helminth ova | No detectable level in 100 mL | No detectable level in 4 grams of total solids, dry weight |
| Total culturable enteric virus | No detectable level in 100 mL | No detectable level in 4 grams of total solids, dry weight |
Source: Schedule 6 of O. Reg. 267/03
Soil analysis requirements
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 Category 3 NASM must be sampled and analyzed within 5 years prior to the planned application date of the NASM. Test the samples for:
- soil pH
- available phosphorus
- available potassium
- 11 regulated metals
The concentration of each regulated metal in the soil sample must be reported in mg of metal per kg 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.
| Metals | Maximum metal concentrations allowed in soil receiving NASM (mg/kg soil, dw) |
|---|---|
| As | 14 |
| Cd | 1.6 |
| Co | 20 |
| Cr | 120 |
| Cu | 100 |
| Hg | 0.5 |
| Mo | 4 |
| Ni | 32 |
| Pb | 60 |
| Se | 1.6 |
| Zn | 220 |
Source: s. 98.0.12 of O. Reg. 267/03
Analytical method and reporting requirements
All soil and NASM analyses 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.
The sampling and analysis protocol also provides details about the following laboratory analysis requirements:
- laboratory quality management
- bias
- laboratory method
- method working range
- method detection limit (mdl)
- recommended laboratory QC/QA procedures
- reporting detection limit (rdl)
- data acceptance criteria
- precision
- data reporting
Containers for collecting samples and other field quality control procedures
Table 7 provides information on the type of containers used for submitting a NASM or a soil sample for analysis of various parameters and a summary of other field quality control procedures. The laboratory must ensure that NASM samples or soil submitted for analysis are packaged in the appropriate container and the NASM generator or NASM plan developer is aware of the Field Quality Control Procedures. The analysis is a critical component in 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.
| Type of sample | Nutrients composite | Metals composite | Organics composite | Pathogens* composite |
|---|---|---|---|---|
| Container | Plastic, glass | Plastic, glass with plastic or Teflon lined lids | Solvent rinsed, amber glass with foil or Teflon lined lids | Sealed, sterile plastic bags/appropriate sterile containers |
| Field QC samples | Recommend that QC program uses duplicates. | Recommend that QC program uses duplicates. | Recommend that QC program uses duplicates. | Recommend that QC program uses duplicates. |
| Storage | For nitrogen, in field keep cool and out of sun and refrigerate <10°C for storage | N/A | In field keep cool and out of sun and refrigerate <10°C for storage | In field, keep cool and out of sun and refrigerate at 4 ± 3°C for storage, without freezing. |
| Additional requirements | N/A | N/A | No contact of sample with plastics during sampling or storage | N/A |
*Note that E. coli (Method E3433) does not confirm presence of pathogenic E. coli
Source: section 2.4 of the Sampling and Analysis Protocol
Appendix A
List of materials for each category of NASM - Schedule 4 of O. Reg. 267/03
| Item | Materials | Additional parameters for analysis |
|---|---|---|
| 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. | N/A |
| 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. | N/A |
| 3 | Leaf and yard waste that has not been composted. | N/A |
| 4 | Organic waste matter derived from the drying, cleaning and processing of field and nut crops. | N/A |
| 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. | N/A |
| 6 | Aquatic plants. | N/A |
| 7 | Organic waste matter derived from the production of ethanol (plant-based mash). | N/A |
| 8 | Any mixture of materials listed in Items 1 to 7. | N/A |
| 9 | Anything listed in Items 1 to 8 that is mixed with agricultural source materials, commercial fertilizer, or compost that meets the Compost Guidelines | N/A |
| Item | Materials | Additional parameters for analysis |
|---|---|---|
| 1 | Leaf and yard waste that has been composted but does not meet the requirements for compost set out in the Compost Guidelines. | N/A |
| 2 | Organic waste matter that contains no meat or fish and is derived from food processing at:
| N/A |
| 3 | Washwater, including materials containing food-grade cleaners, from cleaning the processing equipment and the surrounding area of:
| N/A |
| 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. | N/A |
| 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. | Na |
| 6 | Fruit and vegetable processing water that contains no chemicals other than food-grade chemicals. | Na |
| 7 | Any mixture of materials listed in Items 1 to 6. | N/A |
| 8 | Anything listed in Items 1 to 7 that is mixed with agricultural source materials, OC1 NASM, commercial fertilizer or compost that meets the Compost Guidelines. | N/A |
| Item | Materials | Additional parameters for analysis |
|---|---|---|
| 1 | Washwater, including materials containing food-grade cleaners, from cleaning the processing equipment and the surrounding area in a facility for processing:
| FOG and Na |
| 2 | Paunch manure. | N/A |
| 3 | Organic waste matter derived from the production of biodiesel. | N/A |
| 4 | Organic waste matter from grease traps and interceptors. | FOG and Na |
| 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 Na |
| 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, 1985 (Canada) that may contain an animal product. | N/A |
| 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. | N/A |
| 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. | N/A |
| 12 | Any NASM that is not listed in Table 1 or 2. | N/A |
| 13 | Any mixture of materials listed in Items 1 to 12. | N/A |
| 14 | Anything listed in Items 1 to 13 that is mixed with agricultural source materials, OC1 or OC2 NASM, commercial fertilizer, compost that meets the Compost Guidelines, or any other nutrient. | N/A |
Disclaimer
The information in this document is provided for informational purposes only and should not be relied upon to determine legal obligations. To determine your legal obligations, consult the relevant law. If legal advice is required, consult a lawyer. In the event of a conflict between the information in this fact sheet and any applicable law, the law prevails.