Organic Materials Management Rulemaking (3rd Informal Comment Period)

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Comment From: McKenna Morrigan (McKenna Morrigan)

12/12/25 @ 11:23 PM

Please see comments in attached letter.

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Comment From: Robbette Schmit

12/12/25 @ 11:11 PM

December 10th, 2025
Mr. Chris Fredley
Rules Coordinator, Department of Ecology
300 Desmond Dr SE
Lacey, WA. 98503

Mr. Fredley-

Winton MFG appreciates the opportunity to once again provide comments as part of Ecology's organic materials management...↓

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Comment From: Zero Waste Washington (Heather Trim)

12/12/25 @ 10:21 PM

Please see attached

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Comment From: Restaurant 2 Garden (Joycelyn Chui)

12/12/25 @ 9:13 PM

Restaurant 2 Garden thanks the Washington State Department of Ecology (Ecology) for the
opportunity to comment on the proposed code revision for Chapter 173-350 WAC – Solid Waste Handling Regulations, we respectfully requests Ecology to consider our ...↓

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Comment From: Jay Gordon on Behalf of Variou... (Jay Gordon )

12/12/25 @ 8:02 PM

December 12, 2025
Department of Ecology:
Thank you for the opportunity to comment on the draft language changes to the solid waste guidelines
Our first request in addition to the following comments is that you reach out to our organizations and busi...↓

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Comment From: Michael Mactutis (Michael Mactutis)

12/12/25 @ 7:50 PM

Please find attached the City of Kent comments on the draft rule language for Organics Materials Management.
Sincerely,
Michael Mactutis
Environmental Engineering Manager
City of Kent

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Comment From: Skagit Soils (Troy Lautenbach)

12/12/25 @ 7:04 PM

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Comment From: STEVE VANDER HAAK

12/12/25 @ 6:41 PM

TO: WA Department of Ecology – Solid Waste Section
From: FPE Renewables, LLC.
RE: Comments on Draft 2025 Draft Revisions – Chapter 173-350
As the Operational Manager for FPE Renewables and as a Substrate Service Provider to
several anaerobic digester...↓

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Comment From: City of Mercer Island (Alanna DeRogatis)

12/12/25 @ 5:59 PM

Please reconsider the new 2% standard for inbound contamination. While we are all working to reduce contamination in our waste streams, setting such a limit on inbound contamination is likely to undermine efforts to divert waste from landfill and cou...↓

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Comment From: Coalition for Renewable Natura... (Yanni Psareas)

12/12/25 @ 5:49 PM

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Comment From: Divert, Inc. (Holly Yanai)

12/12/25 @ 5:47 PM

Please find Divert's comments attached. Thank you for the opportunity.

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Comment From: Pierce Louis (Pierce Louis)

12/12/25 @ 5:04 PM

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Comment From: City of Tacoma Solid Waste (Dan Corum)

12/12/25 @ 4:54 PM

The following comments are respectfully submitted in response to the ECY proposed updates to Chapter 173-350 WAC. We encourage Ecology to reconsider the draft language and requirements regarding organic materials pre-processing for three main concern...↓

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Comment From: Cedar Grove (Jay Blazey)

12/12/25 @ 4:22 PM

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Comment From: Republic Services (Wendy Weiker)

12/12/25 @ 3:59 PM

Please see attached letter

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Comment From: Key-Works (Seth Little)

12/12/25 @ 3:36 PM

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Comment From: Rachel Wieme

12/12/25 @ 3:35 PM

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Comment From: Kristin Mansfield

12/12/25 @ 3:32 PM

The Washington Department of Fish and Wildlife (WDFW) supports the addition of language to "...exclude feedstocks when necessary to comply with restrictions to prevent spread of animal diseases such as chronic wasting disease". Composting does not de...↓

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Comment From: Waste Connections (Rick Vahl)

12/12/25 @ 3:31 PM

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Comment From: Public Health Seattle & King C... (Fanny Silverio Gonzalez)

12/12/25 @ 3:11 PM

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Comment From: Sanitary Service Company (Ted Carlson)

12/12/25 @ 3:00 PM

Sanitary Service Company, Inc. (SSC) would like to submit our comments via the uploaded file. Thank you for the opportunity to be part of the process. Ted Carlson, Sanitary Service Company

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Comment From: American Biogas Council (Jonathan Harding)

12/12/25 @ 2:44 PM

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Comment From: Biodegradable Products Institu... (Alexander Truelove)

12/12/25 @ 2:34 PM

The Biodegradable Products Institute (BPI) is North America's leading authority on compostable products and packaging, certifying over 50,000 products from compost collection bags to food containers. For more than two decades, BPI has given consumers...↓ confidence in compostability claims with the backing of science-based standards, while enabling authentically sustainable choices for brands and packagers. BPI champions a systems-wide transition to the circular bioeconomy through rigorous testing, policy advocacy, and industry collaboration, building the infrastructure for "A World Without Organic Waste"—where food scraps and certified compostable packaging become resources. BPI is a non-profit 501(c)(6). To learn more, visit www.bpiworld.org and follow us on LinkedIn.

BPI was a member of the recent statewide Compostable Products Advisory Committee has a long and productive history of working with the Department of Ecology and appreciates the opportunity to engage as it considers updating regulations to support contamination reduction in organics processing facilities according to RCW 70A.205.5401. BPI is committed to supporting the success of residential and commercial food scraps collection programs in Washington, where there are strong examples that show source separated organics, with clear rules on certified compostable products, leads to low contamination, high participation, and profitable composting businesses. The regulatory proposal put forth2 jeopardizes Washington State's leadership in modeling successful organic waste diversion programs, and we fear that the decades of effort invested in Washington communities will be cast aside needlessly.

We have three specific requests regarding definitions:

BPI asks Ecology to update the definition of "organic materials," noting that the historical context for this definition relies on the origin of the raw materials, which is not necessarily limited to plants and animals. The important attribute is that the materials are capable of microbial degradation and ensure a high-quality finished compost product. Products included under the existing definition of "manufactured organics" also meet these criteria and therefore should be explicitly included. It should be noted that "manufactured organics" are regulated under RCW 704A.4553.

"Organic materials" means any solid waste that is capable of microbial degradation. Organic materials include, but are not limited to, manure, yard debris, food waste, food processing wastes, clean wood waste, garden wastes, and manufactured organics. "Organic materials" does not include any materials contaminated by herbicides, pesticides, pests, or other sources of chemical or biological contamination that would render a finished product of an organic material management process unsuitable for public or agricultural use.

BPI attended the webinar on November 54, and we were surprised to hear that Ecology's definition of "source separation" includes food in non-compostable packaging. This, of course, is not correct, as source separation would require non-compostable packaging to be separated at its source. The proposed definition would lead directly to contamination of compost, when compared to actual source separation, considering that depackaging of conventional materials creates persistent microplastics, and potentially introduces chemical contamination from products that are not certified compostable, such as PFAS, heavy metals, or other toxins.5,6 It would also render tons of potentially recyclable packaging unrecyclable and discourage the separation of recyclables and compostables at the bin.

The logic that both valuable food or food waste and conventional materials would be directed to a depackaging process and therefore have the same end of life is flawed. This is critically important if it is the intent of Ecology, as stated in the webinar, to distinguish source separated organics from other streams, and to put the pressure upstream on the generator and not on the composter (or other organics processor). The current definition alleviates the generator of all responsibility to ensure quality feedstocks arrive at the composting facility. This can be solved if Ecology adopts our proposed definition of "organic materials" above, and if additional edits are made to the proposed definition of "source separation".

"Source separation" means the separation of organic materials from different kinds of solid waste at the place where the waste originates. Examples of source separation include but are not limited to a household that places recyclable materials, yard waste, and trash into separate carts, a construction site that places construction debris to be recycled in one container and solid wastes to be disposed in another, a grocery store that places unpackaged food "organic materials" for purposes of recovery within in one container and other solid wastes including packaged food the store generates in separate containers, or a lumber mill that separates wood ash to be disposed at a wood ash landfill in one container and other solid wastes destined for a municipal solid waste landfill in another.

We would also like to see Ecology take the opportunity to update the definition of "manufactured organics" since the subsequent passage of WA's laws on compostable product labeling, which provide strong definitions and stringent labeling requirements. This needs to be corrected to prevent confusion in this sister regulation, and to further bolster the definitions of "organic materials" and "source separation".

"Manufactured organics" means source separated solid wastes, such as product labeled "compostable" in accordance with RCW 70A.455.040. Manufactured organics do not include physical contaminants such as plastics and coated paper products that will not readily decompose under typical composting conditions, or wood derived fuel or wood waste as defined in this chapter.

Finally, we wish to comment on the ultimate impact of the regulations if they proceed as proposed with the requirement that composters are not allowed to accept feedstocks with more than 2% by volume in WAC 173-350-220 (2)(f) and (6)(a)(iii). Instead of creating regulations to support reduction of contamination upstream, this requirement will instead allow a flood of contamination to flow through depackaging systems. The regulation should incentivize high quality source separated organics streams. It is not clear why composters who are capable of making a quality product from source separated organics that meets the physical contamination limits in Table 220-B, would not be allowed to do so. In the end, these provisions may ultimately lead to all organic materials being "mixed waste" organics rather than source separated, sent through depackaging systems. This would generate an unquantified risk to the environment, absolving upstream waste generators of any responsibility to create clean organic streams, and eliminating all value to the state's encouragement of compostable products as a compliance pathway under SB 5284.

As stated on the webinar, Vermont has been looking into the risks associated with depackaging, and has made a number of recommendations7, including that organics should be source-separated; depackaging should have limited use. While Ecology stated on the webinar that Washington is not like Vermont, we find this to be irrelevant and distracting from the regulation at hand. There is a clear distinction between source-separated organics and those that include conventional packaging that must be depackaged. The way that WA decides to regulate this topic will have major impacts on the future of the composting and compostable products value chain for years to come.

Washington has an opportunity to create systems for source separated organic collection and composting programs based on years of success in curbside residential and commercial programs across the state that have managed clean streams with certified compostable food packaging. The state is set to expand these successes with its organic waste diversion laws and new EPR law, but the proposed regulations under review today betray the recommendations made by the Advisory Committee, setting a collision course that will lead to the lowest common denominator. We will continue working with the Department of Ecology in our shared goals and hope you will seriously consider our recommendations and risks of the proposed regulations without changes.

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Comment From: Washington Food Industry Assoc... (Molly Pfaffenroth)

12/12/25 @ 2:16 PM

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Comment From: Energy Vision (Matthew Tomich)

12/12/25 @ 2:12 PM

(Also Attached on Letterhead)

December 12, 2025

Washington State Department of Ecology
Solid Waste Management Program – Organics Rulemaking
P.O. Box 47600
Olympia, WA 98504-7600

Re: Chapter 173-350 WAC – Organics Management Rulemaking

Department ...↓

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Comment From: Natural Resources Defense Coun... (Yvette Cabrera)

12/12/25 @ 1:33 PM

Director Casey Sixkiller

Washington State Department of Ecology

P.O. Box 47600, Olympia, WA 98504-7600

Re: Comment to Support Organic Materials Management Rulemaking in Favor of Source-Separated Organics in Washington State

Dear Casey Sixk...↓

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Comment From: City of Issaquah (Wally Bobkiewicz)

12/12/25 @ 1:23 PM

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Comment From: Sunshine Disposal & Recycling (Reid Johnson)

12/12/25 @ 1:00 PM

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Comment From: WSDA - Livestock Composting Pr... (Sarah Lemon)

12/12/25 @ 12:58 PM

Please see the attached file for comments from the Washington State Department of Ag's livestock composting program.

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Comment From: City of Newcastle (Scott Pingel)

12/12/25 @ 12:36 PM

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Comment From: Washington Refuse & Recycling ... (India Brine)

12/12/25 @ 11:00 AM

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Comment From: State Representative Julio Cor... (Julio Cortes)

12/12/25 @ 10:41 AM

Please see the attached letter for comments on the Organics Management rulemaking. Thank you.

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Comment From: Whatcom County Health and Comm... (Jennifer Hayden)

12/12/25 @ 10:02 AM

See attached comments

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Comment From: US Composting Council (Chris Snow)

12/12/25 @ 8:21 AM

Please see the uploaded file for the USCC's comments. Thank you.

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Comment From: Association of Washington Citi... (Shannon McClelland)

12/11/25 @ 6:15 PM

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Comment From: NW Grocery Retail Assoc. (Brandon Houskeeper)

12/11/25 @ 5:56 PM

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Comment From: Washington State Potato Commis... (Geordy Greene)

12/11/25 @ 1:26 PM

Re: Informal Comments on Draft Amendments to Chapter 173-350 WAC (Organics Management Rulemaking)
Submitted by: Washington State Potato Commission
Date: 12.11.2025

To whom it may concern:

Washington's potato growers sit at the heart of a multi-bill...↓

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Comment From: Woodland Park Zoo (Aarin Wilde)

12/11/25 @ 1:05 PM

December 11, 2025: this comment was previously submitted during the last informal comment session in August 2025. It is resubmitted now to remain part of the record.

This comment addresses a draft concept proposed under the WAC-173-350 Organics R...↓

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Comment From: King County Solid Waste Divisi... (Hannah Scholes)

12/11/25 @ 12:30 PM

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Comment From: City of Everett (Cassie Franklin)

12/11/25 @ 11:57 AM

Please see attached letter

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Comment From: Institute for Local Self-Relia... (Sophia Jones)

12/11/25 @ 10:59 AM

The Institute for Local Self-Reliance (ILSR) is a national nonprofit research and educational organization that advocates for thriving, healthy, self-reliant communities. We respectfully request your consideration of our comments, which are informed ...↓

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Comment From: Snohomish County Health Depart... (Aran Enger)

12/11/25 @ 10:41 AM

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Comment From: Jeff West

12/11/25 @ 10:27 AM

I believe that contamination levels placed upon the inbound volumes of facilities are not practical from a regulatory standpoint. They are not in direct control of the facility operator, do not have a realistic sampling methodology, nor are they enfo...↓

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Comment From: Compost Manufacturing Alliance (Janet Thoman)

12/11/25 @ 10:27 AM

Please see attached comment letter.

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Comment From: City of Vancouver (Matt Bucy)

12/10/25 @ 5:36 PM

Please see the attached file for the City of Vancouver's comments.

Thank you,

Matt Bucy
Matt.Bucy@cityofvancouver.us

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Comment From: Anthony Nathe

12/10/25 @ 11:53 AM

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Comment From: Gina Talt

12/10/25 @ 11:17 AM

As a supporter of the benefits of source-separated organics to ensure quality feedstocks for composting and to not increase the diversion of packaging waste to landfills that could effectively be recycled; I want to register my comments in support of...↓

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Comment From: Margaret Betteley

12/10/25 @ 11:07 AM

I am a compost facility employee for over 12 years, and a supporter of the benefits of source-separated organics to ensure quality feedstocks for composting.

I want to register my comments in support of meeting the intent of the Washington State's ...↓

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Comment From: Madeline Shepard

12/10/25 @ 9:56 AM

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Comment From: Lenz Enterprises Inc. (Edward Wheeler)

12/09/25 @ 2:10 PM

Please see attached comment letter.

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Comment From: Jan Molinaro

12/05/25 @ 12:51 PM

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Comment From: Samuel King

12/05/25 @ 7:41 AM

Hello,

My name is Sam King and I'm a founder of Blue Earth Compost, a food scrap hauling and composting company that was started in Connecticut over a decade ago. Although the rulemaking that you all are positing won't directly affect us in CT, I fe...↓el it is important to comment because, in our nascent industry the rules that are being established now will become precedent for other jurisdictions. I want to make sure that we get it right now, so that the way forward is better for the hard-working people doing the work of composting and waste reduction.

In the Pre-Processing Section (page 61) I ask for the establishment of strong, Vermont-style depackaging standards that maintain source separation and prevent contamination.
Some ideas include:
Inbound contamination limits
Mandatory recovery rate of 90% of accepted materials
Prohibition on accepting easily recyclable materials
Prohibition on sending pure food waste through a depackaging machine

In the Definition Section, remove or revise provisions that rewrite statutory definitions for "organic materials" (page 6), "source separation" (page 53), and shift ownership away from generators (page 8).

Protect and expand compost infrastructure by adopting practical, achievable contamination reduction policies upstream and training requirements for facilities (page 105).

We do not believe that increased compliance burdens and restrictions at the facility without upstream changes (starting on page 75) are the answer.

In section 220 and 225, require training minimums for all organics management facility operators to mirror those they have drafted for compost facility operators.

We have seen the negative impact on the composting and recycling industries in states such as Maine, Massachusetts, and Vermont when non-source-separated organics collection invited large generators (groceries, food distributors, etc) to toss ALL inedible food waste, including previously source-separated organics, into the same dumpsters. This has forced advocates in Vermont to push for what has been a lengthy process in the State of Vermont to reaffirm the intent of its landmark source-separated organics law, yet many composters never recovered, leaving a deficit of compost for healthy soils in that state.

Please work with the State of Washington's composting and recycling industries to ensure that fair and appropriate levels of inbound contamination are fairly set for the composting and depackaging industries; while maintaining the intent to source-separate unpackaged and easily recycled organics for composting.

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Comment From: Cary Oshins Beth Hyde

12/05/25 @ 4:53 AM

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Comment From: Assaf Sadeh

12/04/25 @ 2:11 PM

Does the WA Dept. of Ecology cite a specific analytical test method for the testing of feedstocks for physical contaminants? I have reviewed the draft language for information about test methods. I did not locate any specific references to analytica...↓

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Comment From: Braeden Cohen

12/04/25 @ 12:53 PM

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Comment From: Rene' Skaggs

12/03/25 @ 12:53 PM

In exemption #4 in Table 220-A. If a facility or farm is falling under the maximum cubic yard limits, why must they go through the notice of intent form referenced in the table under: (a) Thirty days prior to operation, facilities must submit a notif...↓

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Comment From: Clark County (Tatum Flowers)

11/24/25 @ 12:31 PM

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Comment From: WA Retail Association (Rose Gundersen)

11/24/25 @ 11:24 AM

The Washington Retail Association appreciates Ecology's work to update WAC 173-350 to reduce contamination in organic waste. Many of our members include food as part of their merchandise and services—such as convenience stores, shopping centers, and ...↓

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Comment From: Tamara Thomas

11/21/25 @ 4:36 PM

Section of comment:
The revision of section 173-350-220 (6)(a)(vi)(A) which sets the requirements for basic compost training was not changed. The new (and old) section states:
"Appropriate compost training can be obtained through organ...↓

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Comment From: Nova E Heaton (Nova E Heaton)

11/20/25 @ 3:28 PM

A 2% contamination threshold is of concern to our city because there is not funding or technology to support this requirement on a wide scale level which could create a significant rate payer increase that would be needed to achieve this ambitious di...↓

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Comment From: Whidbey Compost Collective (Jumanji Oliana)

11/19/25 @ 1:51 PM

Page 29 4th definition:
-We believe the term 'food waste' is not appropriate language. While we transition from a waste paradigm to a resource paradigm, the language we use is paramount. We are not managing waste, we are managing resources, therefor...↓

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Comment From: Snohomish County Health Depart... (Aran Enger)

11/17/25 @ 3:40 PM

The Snohomish County Health Department request a brief extension on the comment period for the proposed code revision. Our team needs additional time to review the changes thoroughly and provide informed feedback. If possible, we would appreciate an ...↓

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Comment From: Lee Alley

11/14/25 @ 6:59 PM

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Comment From: Natallie Williams

11/14/25 @ 4:29 PM

I ask for the establishment of strong, Vermont-style de-packaging standards that maintain source separation and prevent contamination.
Some ideas include: -Inbound contamination limits -Mandatory recovery rate of 90% of accepted materials -Prohibit...↓

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Comment From: Marissa Young

11/14/25 @ 3:02 PM

As a supporter of the benefits of source separated organics to ensure quality feedstocks for
composting and to not increase the diversion of packaging waste to landfills that could
effectively be recycled; I want to register my comments in support ...↓

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Comment From: Black Earth Compost (Andrew Brousseau)

11/14/25 @ 8:23 AM

Hello, I own a compost business in Massachusetts but I have lived and worked in Washington in the Organics Waste Management field. Nationally you need to understand that there is a push by Anaerobic Digesters (AD) with their depackagers to grab all ...↓the food waste feedstock. Yes AD does create a lot of capacity to dispose of food waste, but it is the lowest form of management and often is not even recycling. Any state like Washington will benefit more if the food waste can be used to breakdown yard waste and produce a soil amendment. Soil amendment's improve soils in the state for growing plants. Plants provide us with food, fiber, building material etc. Putting rich organic matter into the soil is like depositiing into the soil bank for future withdrawal of plants.
-AD connected to WWTP's do not achieve this (N is pushed out using energy, P ends up in biosolids which are hard to recycle but WA does a good job, and the K is washed out to the ocean because it is a salt).
-AD connected to a farm is a little better, but the liquid digestate is where all the nutrients land. Digestate does not increase soil organic matter and is often over applied around the farm. The AD's often have to pay the farmer to make the digestate go away, which is a perverse incentive that leads to over application.
-Compost on the other hand is a finished product that people will pay for.

What WA can do:
-Source separation is very important with food waste because we are making a product that goes to our food supply. Single stream with recycling might be ok because we are not eating the products from recycling. Depackagers create microplastics which end up contaminating the final digestate or effluent from the WWTP.
-Despite that, composters can handle contamination better than AD because we get it out while it is still large, rather than macerating the contamination in a depackager. 2% is too low a threshold.
-Source separated organics SSO should not be allowed in plastic bags (sometimes used for collection). This means that SSO must go to a depackager which excludes composters from the market. Composters rarely have depackagers especially smaller ones. Decentralized composting at many small sites provides the most benefits to a state because of reduced trucking and reliance on centralized facilities.
-SSO should not be mixed with packaged food. That takes a clean stream and turns it into a dirty stream. Vermont has a law against this.
-Certified Compostable packaging is a path forwad for the microplastics problem. It has higher standards than existing FDA packaging rules and a depackager would much rather want a compostable microplastic in their effluent than a conventional microplastic that will take much much longer to break down in the environment.
-It is important that you look at this from a lens of the dynamics of competition between AD and Composters. The EPA's highest and best use scale clearly states food waste composting as higher. You need to recognize that incentives within the energy sector (renewable energy credits) create a distortion within the organic waste management sector that drags organics down the EPA's highest and best use scale. If WA crafts laws that also bias towards AD then composters are really stifled from growth. Why should AD get subsidies and laws written for them? Is that fair within the market?
Finally, be very careful of following Californias lead in their rush to get food waste out. This will just lead to an AD future because they have large capacity and the rush does not allow time for the culture of source separation to grow. Instead follow Massachusett's lead of a slow roll out which is allowing composters to compete.
Thank you, I am happy to speak more with you if you have specific questions,
Andrew Brousseau