No. The proposed microbial standards for treated biological soil amendments in §
112.55 are not meant as lot-by-lot microbial testing requirements. Rather, they are
intended to provide the standard against which treatment processes would be required
to be validated. A validated process, when properly implemented and monitored, would
be expected to meet the listed microbial standards. The person applying the treatment
process would need to monitor the physical parameters of the process (e.g.,
temperature of a compost pile) to ensure that they meet the conditions under which the
process was validated. Farms would be able to use treatment processes that are
validated to meet the relevant microbial standard without needing to test the end
products of their treatments to confirm that the microbial standard was achieved.
