Must I continue to audit if 50% is reached during PP

Hi Blair, the Recertification Guidance (October 2013) says that a waste audit needs to be performed only once every 5 years if MRc7 (aka 50% diversion) was earned. So you should be fine if you've done one audit between your initial certification and when you submit your recertification application, since you earned certification in 2010.

I think I get what you're saying, but bear with me if I get it wrong! Essentially, the outcome of the waste audit doesn't matter. What does matter is if you earned MRc7 by diverting 50% during the performance period. Since you did divert 50% in the initial certification, you only have to do one waste audit every 5 years. So since you did a couple audits you will be just fine and don't need to do another one this year. And for MRc7, you'll have to demonstrate ongoing diversion of at least 50% to earn that credit. Doing the waste audit (or not) doesn't affect compliance with MRc7. Does that help? Let me know if we're still not quite on the same page here!

Hi Blair, thanks for clarifying! This is making more sense and I have a couple of thoughts. First I think that if you're now achieving 50% diversion, you should be able to skip the fifth waste audit, since you’ve improved performance to the point where MRc7 is attainable (which is the whole point of doing an audit annually). Second, since MRc7 wasn’t pursued in the original application, you’re allowed to use a 3-month performance period for that credit in the recertification application. Of course you can provide more than 3 months worth of data if it helps you to show that you met the 50% threshold. But that rule might help you to slice and dice the data in the best way to demonstrate that you're achieving MRc7. I hope this helps!