Comment Letter on Proposed Regulations for Renders, Collection Centers, Dead Animal Haulers and Transporters of Inedible Kitchen Grease
Update from Greg Kester, CASA Biosolids Program Manager
Today, CASA submitted a commented letter to the California Department of Food & Agriculture (CDFA) regarding the proposed rendering regulations as noted above. CASA is pleased that CDFA has reinserted exemption language for POTWs accepting FOG into anaerobic digestion. However, there is one issue in the regulations on which CASA is requesting a modification. As currently written, CDFA would require a transporter to verify the amount discharged at a receiving facility (including POTWs) by means of a flow meter, scale, or a weighmaster certificate. In reality, it appears that many POTWs do not have flow meters or scales for this discharge and merely assume a truck is filled to capacity when discharging. This is the basis for charging, so it is generally true. CASA has requested that flow meters, etc. not be mandated but rather that CDFA allow the assumption that vehicles are fully loaded at the point of discharge. Please let Greg Kester (email@example.com) know if you have any comments or questions on the letter.