GrubTubs, Inc.

Odor Management
Quality Assurance (QA) &
Continuous Quality
Improvement (CQI) Strategic
Plan
Documentation
 6/25/19

[Author: Peter M. Black BSc., MSc.]

[Chief Operating Officer]

Version #1

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 Reviewed and Approved by:

Farm Operations Manager Date

Chief Operating Officer Date

Founder and Chief Technology Officer Date

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Introduction

GrubTubs is a small privately owned farm whose mission is to reduce the amount of food waste
going to landfills by processing it through various techniques to subsequently produce animal
feed for farmers at a lower price than traditional commercial feed. A brief video with an
overview of the company can be found here: https://vimeo.com/272586259. GrubTubs’
processes are designed so as to conform to the latest scientific procedures, and both state and
federal laws. As such, within our Quality Assurance (QA) program, we utilize Continuous Quality
Improvement (CQI) techniques to control potential odor on our farm located at Black Colony
road. This begins with our pick-up of the food waste from restaurants using patented
hermetically sealed and sanitized tubs, through transport and handling that minimizes exposure
of the content of the tubs to outside air, to the sanitary cleaning of the tubs using both an
Ozone gas and a Chlorine wash method which allows the tubs to go back to our customers for
usage in their restaurant kitchens without any odor.

Given that we subscribe to both CQI and QA principles, we are continually seeking to improve
our processes. These quality principles serve as a foundation for the commitment of our
company to both continuously improve the quality of our work product and be good citizens
and neighbors in the Buda community. Given the passage of Buda City Ordinance 2019-07, we
are incorporating further preventive measures through multiple processes and procedures as
well as enhancing existing processes to reduce the potential for odors from the farm in through
our existing QA program through a CQI plan. This plan will first briefly describe our overall CQI
philosophy and framework, including Senior management oversight of the CQI initiatives, and
then the specific additions to existing farm procedures, as well as new procedures, that have
been put in place post-ordinance to reduce the potential for odor.

Through our CQI program, GrubTubs continuously strives to ensure that:

o The company incorporates evidence-based, effective practices in our work;

o Procedures, treatments and service are provided in a timely and efficient manner, with
appropriate coordination and continuity across all phases of our operations;
o The standardization to best practices;
o Working with our neighbors, clients, and vendors, in a holistic ecosystem; &
o Listening to our neighbors in the community in which we reside (ask@grubtubs.com)

Quality Improvement Principles. Quality improvement is a systematic approach to assessing

services and improving them on an ongoing basis. Given the new Buda ordinance - 2019-07 The
GrubTubs approach to quality improvement is based on the following principles:

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  Customer Focus. High-quality organizations focus on their internal and external
customers and on meeting or exceeding needs and expectations.
 Leadership Involvement. Strong leadership, direction and support of QA/CQI activities
by Senior management are key to performance improvement. This involvement of
organizational leadership assures that quality improvement initiatives are consistent
with provider mission and/or strategic plan.
 Data Informed Practice. Successful CQI processes create feedback loops, using data to
inform practice and measure results. Fact-based decisions are likely to be correct
decisions.
 Prevention Over Correction. Continuous Quality Improvement programs seek to design
good processes to achieve excellent outcomes rather than fix processes after the fact.
 Continuous Improvement. Processes must be continually reviewed and improved.
Small incremental changes do make an impact, and providers can almost always find an
opportunity to make things better.

Quality improvement activities emerge from a systematic and organized framework for
improvement. This framework, adopted by the senior management is understood, accepted
and utilized throughout the GrubTubs organization as a result of continuous education and
involvement of staff at all levels in performance improvement. Quality Improvement involves
two primary activities:

Leadership & Organization

One of the keys to the success of the CQI process is company leadership. The following
describes how the Senior Management of our company provides support to the quality
improvement activities of which reducing the possibility of any odors from our farm processes
is a key component.

GrubTubs has a CQI team that provides ongoing operational leadership and oversight of CQI
activities at our farm. This committee is comprised of: the Chief Technology Officer, Chief
Operations Officer, Farm Manager and individual Shift Foreman. Continuous feedback from
farm staff is sought and considered on relevant farm processes, which are reviewed and
updated regularly.

The responsibilities of the Committee include but are not limited to:

o Establishing measurable objectives based upon priorities identified through the use of
established criteria for improving the quality of our processes and reduce, for example,
the possibility of odor issues;
o Developing indicators of quality on a priority basis (e.g., daily checklists for critical
process checks);
o Periodically assessing information based on the indicators (e.g. neighborhood feedback
through channels such as (ask@grubtubs.com) and taking action as evidenced through

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 quality improvement; initiatives to solve emergent problems and pursue opportunities
to improve quality;
o Establishing and supporting specific quality improvement initiatives (such as the new
and enhanced initiatives listed below);
o Meeting on a weekly basis to assess any emergent issues such as odor complaints;
o Review, and if needed, derive Action Plans based on inspection reports from relevant
regulatory authorities (e.g., TCEQ, Hays County, etc.)
o Revising Farm training for existing and new staff especially in processes to reduce any
potential odor this will include creating written Standard Operating Procedures (SOPs)
which will be strictly adhered to by farm personnel.

CQI Initiatives
As previously noted, while following GCP principles for processes at our farm given both the
new ordinance and concern from neighbors, GrubTubs decided to initiate further measures to
reduce potential odors at the farm. These efforts, in concert with the oversight of the CQI team,
comprise two basic modalities:1 enhancing existing preventive measures and; 2. introducing
new “state of the art” measures in out processes suggested by an outside consultant with
technical expertise in this area. The initial analysis for deriving these additions to our work
processes was based upon the segmentation of our work into three basic processes: 1. removal
of food from the hermetically sealed containers; 2. actual composting of the food; and 3.
cleaning of the tubs for re-use by the restaurants.

I - Tub Emptying

The emptying of the tubs prior to the composting step is now done in an enclosed greenhouse
which reduces potential odor dispersal and vaporization via wind.

Date implemented - June 18, 2019

II - Lactobacillus Spray Treatment

Lactobacillus is a probiotic compound that releases lactic acid that has been shown to reduce
the growth of most odor-causing bacteria and has been successfully used in many industries
including the food industry.

We have started to use a Lactobacillus spray for:

1) The tub emptying enclosure at the end of every food removal and rinse cycle;
2) Anywhere on the farm that a rare occurrence of spillage might take place;
3) Over any areas on the ground that show signs of anaerobic decomposition;

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 4) Spraying the inside of our trucks that transport tubs.

Date implemented - June 22, 2019

III - Aeration of Compost Piles

While not always needed in the composting business we are presently mechanically aerating
the static compost piles. Aerating compost produces an aerobic composting process and
magnitudes of less odorous compounds than anaerobic decomposition which is usually used. By
aerating we maintain an aerobic decomposition process that optimizes the quality of the
compost and prevents odorous compounds from initially forming (see Appendix A for prototype
recording form).

Date implemented - May 16th, 2019

IV - Extra Compost Coverage

As with many composting techniques we cover the compost with mulch and or finished
compost. This not only keeps the moisture in the compost pile for the needed composting
processes to occur but also helps seal the pile so odors cannot readily escape. Good
Composting Practice for our type of composting work suggests the use of 2-4 inches of mulch
on the compost pile. We have increased this to 4-6 inches to insure a tight seal and in the last 3
months, we have used ~7000 cubic yards of mulch coverage (see Appendix A for a prototype
recording form).

Date implemented – May 15, 2019

V - Tub Washing Station Reconfiguration

Relocation and reconfiguration of the tub cleaning equipment so as to reduce the possibility of
water pooling on property. Also, all wash water is now redirected and reused to help maintain
adequate moisture in the Static Pile Aerated compost system. This not only prevents odors in
the water but speeds up the composting process so less potential odor-causing compounds are
generated in our process.

Date implemented - June 10, 2019

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VI - Ozonation and Chlorination of Tubs

The tub washing process that is used to clean the tubs and return to the restaurants is an
unlikely source of odor given the nature of the cleaning. However, as a precaution and a final
step before the buckets are left to dry, we have added both a chlorine washing step and a
special treatment with ozone gas. Of the 200 restaurants that we service (the tubs are used in
the kitchen prep areas) none have noticed/reported any untoward odors emanating from the
buckets when in use in their kitchens. Given these containers are used in active food
preparation areas, if there was an issue this would definitely have been reported. Given this, we
feel that odors are not produced by tubs drying at the farm.

Date implemented - Ozone Treatment June 3, 2019

Date implemented - Chlorine Wash June 7th, 2019

VII - Further Planned Initiatives

Given the nature of the CQI process in that it emphasizes the concept of “continuous” other
initiatives will be added to the program and documented in further versions of the present
plan. Some that are presently being considered are:

- Implement various channels to reach out to the Buda community and neighborhoods. This can
take a number of forms such as educational presentations to various community groups about
how our work at the farm will ultimately help the small farmer.

- Either a potential “Hotline” to farm personnel or more visibility for our askgrubtubs.com link
where people can ask questions or report concerns.

- Tracking of tubs via a barcode or other technology so that time from use by the customer and
processing is minimized.

CQI Plan Evaluation

CQI initiatives are, by nature, continuous works in progress. Grubtubs historically has utilized a
QA Program since its inception, and the CQI initiatives associated with our Program are

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constantly revised to meet the needs of our constituents and neighbors. Where possible,
Grubtubs will document and maintain records of quantifiable CQI actions. For example,
Grubtubs may document the number of cubic yards of mulch, type of mulch, and location of
use, in accord with Item IV under CQI Initiatives. Where quantifiable data may not be available,
such as with the report of an odor from a neighboring community member, Grubtubs will
nonetheless seek to document as much qualitative information as possible, and will incorporate
this information as much as practicable within this evaluative model.

Otherwise, CQI initiatives, as well as the greater QA Program, are governed by the Deming Cycle
of continuous improvement. The Deming Cycle is also known as a PDCA process, with PDCA
standing for: Plan, Do, Check, and Act. In practice, the Deming Cycle allows for the
incorporation of new data and information into existing best practices, and encourages regular
care and attention to the systems that a business such as Grubtubs relies upon to be a
successful, productive, and mindful organization within the greater community it serves.

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 Appendix A

Item III: Aeration of Compost Piles

Date Location Additional Notes

Item IV: Extra Compost Coverage

Date Location Type of Mulch Amt Used (cu yds)

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