Tom's dog biscuit factory

Tom decided to build a dog-biscuit factory.

Dog thought this was an excellent idea and immediately volunteered for Quality Control.

The plans were impressive.

They showed the truck entrance, weighbridge, loading bay, stormwater drains, storage shed, office, parking spaces and screening trees. The fence colour had been selected to suit the rural landscape.

The biscuit smell had been modelled.

The truck noise had been modelled.

There was even a procedure for what to do if a reversing forklift upset a wallaby.

Bill studied the drawings.

“Where do you make the biscuits?”

Tom pointed to a large square in the middle.

It said:

BISCUIT MAKING AND PRODUCT STORAGE

“What happens in there?” Bill asked.

“We blend the ingredients and biscuitise them.”

“How?”

“With a biscuitiser. Or possibly a biscuit granulator.”

“Which one?”

“That’ll be decided during detailed design.”

“What ingredients go in?”

“Grain, meat meal, minerals and whatever else the biscuit process requires.”

“What else might it require?”

“That’ll be decided during detailed design too.”

Bill looked again at the drawing.

Inside the biscuit-making square there was nothing.

No mixer.

No press.

No oven.

No grinder.

No tanks.

No screens.

No place for biscuits that failed to become biscuits.

Just a box.

“That’s not a process,” Bill said. “That’s a rectangle.”

“It becomes a process once it’s approved,” said Tom.

The approval arrived with fifty-three conditions.

It limited truck movements, noise, dust, operating hours and stormwater.

It specified where the finished biscuits would be stored.

It did not define what could happen inside the biscuit-making box, because nobody had defined what the biscuit-making process was.

Construction began.

The gate arrived.

The weighbridge arrived.

The Monument Grey shed arrived.

Then, after approval, came the biscuit machinery.

A grinder.

A mixer.

A steam conditioner.

A press.

Two screens.

Several conveyors.

A dust collector.

And a stainless-steel tank with a yellow warning label.

Bill pointed at it.

“What’s in that?”

“Binder.”

“Was binder in the application?”

“It’s part of biscuit making.”

Another tanker arrived.

“What’s that?”

“Conditioning agent.”

“Was that assessed?”

“It’s part of biscuit making.”

Then came drums of oil, bags of white powder and another tank labelled PROCESS ADDITIVE.

Bill watched them cross the yellow line around the biscuit area.

“So anything can go inside the box?”

“Not anything,” said Tom. “Only things required to make biscuits.”

“And what things are required?”

“Whatever the process requires.”

“And what process was approved?”

“Biscuit making.”

Bill nodded.

“That’s a very tidy circle.”

Commissioning began on Tuesday.

The first batch came out as warm gravel.

Tom screened it and sent it back through.

The second batch produced dust and several hard lumps.

Tom crushed the lumps and sent them back through.

The third batch made twenty-seven proper biscuits, half a tonne of fines and one large object shaped like Tasmania.

Dog ate the twenty-seven biscuits before they could be tested.

The failures went back through again.

Soon the mixer was receiving yesterday’s biscuits, last week’s dust and several black lumps that had completed more circuits of the factory than the night-shift operator.

Tom called them process seeds.

Bill called them scats.

Dog tried one and declined further involvement.

The product shed gradually filled with material that was not quite biscuit but was not being called waste either.

“What happens if it never becomes biscuit?” Bill asked.

“It stays in the process.”

“For how long?”

“Until it becomes biscuit.”

“And if it doesn’t?”

“We improve the process.”

“With what?”

Tom glanced towards the chemical tanks.

“Process aids.”

A compliance officer eventually visited.

He inspected the gate, checked the stormwater pond and reviewed the truck records.

Then he stood beside the biscuit-making box and looked at the tanks, grinder, screens, rework piles and conveyor carrying failed biscuits around in a large circle.

“Is all this approved?” he asked.

Tom pointed to the drawing.

“It’s inside the biscuit-making area.”

The officer checked the approval.

The drawing said BISCUIT MAKING AND PRODUCT STORAGE.

It did not list the machinery.

It did not list the chemicals.

It did not define the biscuit.

It did not say what happened when biscuit making failed.

“What exactly happens inside this box?” the officer asked.

“Biscuit making,” said Tom.

The officer looked at the plan.

“That’s what it says.”

He signed the inspection sheet and left.

Late that afternoon, Bill and Tom sat outside the shed.

Behind them, the conveyors carried failed biscuits in circles while another chemical tanker reversed through the approved gate.

“At least the factory was properly assessed,” Tom said.

Bill looked at the detailed drains, the subdued fence and the Monument Grey walls.

“No,” he said. “The shed was assessed.”

Something heavy rolled off a conveyor and landed with a thud.

Dog lifted his head.

Bill put his hat back on.

“Good news, Tom.”

“What?”

“You’ve made another future biscuit.”

What Bill Learned

Bill learned that approving a factory is not the same as understanding how the factory will work.

In Tom’s dog-biscuit factory, nearly everything outside the biscuit-making box was carefully described. The trucks, shed, drains, noise, operating hours and storage areas were all shown on the plans.

But the most important part—the place where the ingredients became the final product—was just a box labelled “Biscuit Making and Product Storage.”

That was the problem.

The product-making stage matters

The Glan Devon proposal says dried biosolids will be mixed with mineral fertiliser and then put through a “pelletiser or granulator.”

Those words sound simple, but they do not describe one clear process.

A pelletiser might squeeze a prepared mixture through a die. A granulator might build larger particles using water, steam, binders or liquid chemicals. Other systems might coat a biosolids pellet with mineral fertiliser or chemically react the materials before forming the final product.

These processes need different machinery, storage tanks, chemicals, drying systems and pollution controls.

Until the process is chosen and described, it is difficult to know what factory is actually being approved.

The black box has no clear boundary

The proposal includes an approval for chemical manufacturing. But the application does not clearly identify what chemicals might be used in the pellet-making stage.

The final system might need:

• binders to hold pellets together;

• water or steam;

• oils or dust suppressants;

• acids or alkaline materials;

• liquid fertilisers;

• coatings;

• hardeners;

• cleaning chemicals.

The important point is not that these substances will definitely be used. The problem is that the application does not clearly say which ones are allowed, how much could be stored, or what processes they would be used in.

That leaves a broad black box.

Later, a new tank, chemical or machine could potentially be described as part of ‘fertiliser manufacturing’, even though it was not clearly assessed in the original application.

A planning approval should set a boundary around the proposed activity. It should say what may happen, what may be used and what limits apply.

A label such as “pelletising” does not provide that boundary.

Making good pellets is not automatic

Mixing two solid materials does not guarantee that every pellet will have the same composition.

Dried biosolids and mineral fertiliser may have different:

• particle sizes;

• densities;

• moisture levels;

• hardness;

• strength;

• chemical composition.

A successful process would need to prepare, mix and bind these materials carefully.

The finished product would also need to survive:

• conveyors;

• screening;

• storage;

• truck transport;

• unloading;

• loading into farm machinery.

If the pellets break apart, the smaller pieces may behave differently from the larger ones.

Some fragments might contain more biosolids. Others might contain more mineral fertiliser.

That could cause uneven application of nutrients when the product is used.

It could also cause PFAS, metals or microplastics to be unevenly distributed if those contaminants are more concentrated in certain parts or particle sizes.

A single average laboratory result may not reveal that problem.

What happens when a batch fails?

Factories do not produce perfect material every time.

Some pellets may be:

• too small;

• too large;

• too weak;

• too wet;

• too dusty;

• chemically outside specification.

The application should explain what happens to those materials.

They might be crushed and returned to the process. They might be mixed into another batch. They might need to be stored, treated or disposed of as waste.

Repeatedly returning failed material can create a circulating load.

This is similar to material going around a mining crushing circuit without becoming a saleable product. More and more material stays inside the plant, increasing wear, power use, dust and storage needs.

Some hard or unsuitable material may continue going around without ever becoming acceptable product.

The plant therefore needs a controlled way to remove failed material from the circuit.

Without that escape route, the process can slowly fill with yesterday’s failures.

When does waste become a resource?

The proposal depends on turning regulated biosolids into a useful fertiliser product.

But calling something fertiliser does not automatically make it a resource.

It must meet the relevant End of Waste requirements and be used in the approved way.

That raises important questions.

What is the legal status of:

• dried biosolids;

• the mixed feed;

• finished pellets;

• broken pellets;

• dust;

• oversized lumps;

• rejected batches;

• material recycled through the plant many times?

A failed batch that cannot be sold or lawfully used may still be waste.

The application should clearly show when the material becomes a resource and what happens if it fails to meet that standard.

Bill’s main lesson

The central problem is not that every pipe, bolt and machine must be selected before approval.

Detailed engineering can come later.

But the application should still describe the basic process, permitted inputs, chemicals, wastes, product standards and failure controls.

Otherwise the approval is being asked to cover a factory whose central manufacturing stage remains undefined.

Bill learned that the drains, fences and truck routes can all be carefully assessed while the most important part of the development remains a vague promise.

Or, as Bill might put it:

“They approved the biscuit shed. They still don’t know how to make the biscuit.”

Read more detail here

© 2026. All rights reserved.