It’s time to stop spreading sewage sludge on our farms.
SEND COMMENT TO ECOLOGY BEFORE JULY 1
Most people don't know that a lot of the food we eat is grown on fields where municipal sewage is used for fertilizer. When they do find out about this, most people ask, is it legal?
Unfortunately, it is legal, but there are compelling reasons why it should not be legal. How many reasons? Let's start with 352.
According to the U.S. Environmental Protection Agency's Office of Inspector General, the EPA knows of 352 "pollutants" that can be found in municipal sewage sludge (the EPA regulations that govern this practice nationwide only require testing for nine). The Inspector General compared those 352 pollutants to three federally maintained lists of hazardous substances and found this: Of those 61 pollutants, 32 are hazardous wastes under the Resource Conservation and Recovery Act, including four described as acutely hazardous; 35 are EPA priority pollutants; 16 are on the National Institute for Occupational Safety and Health’s list of hazardous drugs.
Your food is grown in this!
“The EPA’s controls over the land application of sewage sludge (biosolids) were incomplete or had weaknesses and may not fully protect human health and the environment.”
– U.S. Environmental Protection Agency's Office of Inspector General, November 15, 2018.
A 2009 U.S. Environmental Protection Agency study concluded that all sewage sludge contains toxic elements. Official estimates of the numbers of toxic contaminants that could be present in any given batch of sludge range into the thousands. You have to think of the hundreds of industrial, pharmaceutical and organic pollutant contaminants that our society flushes down the drain every day. Antibiotic resistant bacteria and mobile antibiotic resistance genes are present in sewage sludge. Micro-plastic is an increasingly common component of sewage sludge and is no good for the soil it's spread on, the creatures that live in that soil or the wildlife that depend on it. Disease-causing bacteria, viruses, protozoa and parasites are never entirely killed off when sewage sludge is treated to be used as fertilizer and can grow back in the nutrient-rich sludge especially in the warm and moist conditions on a farm. You can even find sewage sludge in consumer fertilizer and compost products for home gardens-- the gardens you want your children to play in.
Recently, per- and polyfluoroalkyl substances (PFAS) chemicals are being found in increasing concentrations in sewage sludge. These are the man-made fire-retardant and non-stick chemicals that are now found all over the globe-- even in rain drops! PFAS have already caused havoc on farms all over the country where sludge has been used for fertilizer. Some farms have had to close because of the PFAS from sewage sludge fertilizer getting from the field into their food. Governments are reluctant to test farms extensively, fearing perhaps an iceberg-like national food safety crisis if the problem on farms is confirmed to be widespread. According to a new study by the Sierra Club, PFAS are "a class of widely used industrial chemicals, many of which are toxic to people, that persist for decades in the environment. In most places, industries are currently allowed to flush PFAS-containing waste into wastewater drains that flow to treatment plants. The chemicals are not removed during sewage treatment, and instead settle in solid materials that are separated out from liquids in the treatment process."
PFAS is one family of chemicals that contaminates sewage sludge. There are hundreds more.
Honestly, just the idea of letting sludge anywhere near our food seems crazy. And it is crazy. But it's legal.
You can change that! And you must act fast, because the opportunity is closing on July 5.
The WA Department of Ecology wants to hear from you: Should we continue to issue permits to businesses and agencies that give them permission to spread sewage sludge on farmland and forest land? Tell them "No!" They are taking your comments now. Go here to do that:
Since 1992, the Department of Ecology has regrettably been directed by the state legislature to maximize the "beneficial use" of biosolids ("biosolids" is what defenders of the practice of land application euphemistically call sewage sludge). It's a legislative mandate that runs counter to Ecology's mission. The agency claims it "is committed to considering how agency activities, including permitting, may adversely affect the environment, and health of people, and communities of our state." It's a mission that the agency has been all too eager to ignore as it instead embraced its new biosolids role with aplomb, capitalizing on it and promoting it. This has resulted in decades of state-generated propaganda trumpeting the "benefits" of land application of sewage sludge accompanied by vigorous organized efforts to de-legitimize scientific data that points out the inherent hazards of the practice. Just have a look at the quasi-public "Northwest Biosolids" organization. The Board of Directors is made up of an incestuous amalgam of private waste treatment industry representatives and governmental municipal waste management officials all of whom share a financial interest in the continuation of the industry that has grown up around the land application of sewage sludge (in fact, they share a building on Jackson St. in Seattle with the King County Solid Waste Division). It has an enormous budget to keep pumping out lies about the "safety" of biosolids. It adopts policy positions, lobbys for them and authorizes participation in litigation to defend the industry. You know it's gotta be bad when they have to set up a massive disinformation campaign and hit squad to maintain their ill-gotten privilege. Northwest Biosolids is like the Koch brothers of sludge.
The state's rules for permitting the use of sewage sludge as fertilizer expired in September of 2020 so now the government must go through a public rule-making process to re-authorize the so-called "statewide general permit for biosolids management" for the next five years. They have released a draft for public comment.
They see it as seeking minor adjustments to the existing regulatory framework for disposing of sewage sludge on farm and forest land and expect to rubber stamp it and go on with business as usual.
You should see it as an opportunity to fundamentally question the wisdom, the morality and the science around whether we should be permitting this activity in the State of Washington at all.
Ecology will state again and again, defending the sludge permitting program, that the draft permit language conforms to state and federal regulations (like if a batch of sludge passes tests for the nine contaminants and comes out okay, then it's alright to simply ignore the hundreds of other chemicals the regulations don't bother to mention). But the real question is, does the draft conform to whether or not Washingtonians will tolerate the continued pollution of our lands, waterways and food supply? The answer must be "No!"
So, just one simple sentence is all you have to send to Ecology by way of your comment:
The State of Washington must cease issuing any permit that allows the disposal of sewage sludge in any form on homes, farmland, forestland or parkland.
From there you can get as creative as you want. Ecology says it will "consider all feedback before a final decision is made," and plans to "release a revised statewide permit for final public review later this year," hinting at yet another public comment period and another opportunity to tell Ecology "land application of sewage sludge is just sooooo 2oth century."
Ecology says "the draft permit streamlines some requirements, reducing the regulatory burden for about half of the 375 or so [biosolids] facilities in the state." And that's a good thing? Less regulation: Just what we need when we are faced with hundreds of known contaminants and emerging contaminants of concern.
In fact, the Department of Ecology has had a checkered history managing its biosolids program and enforcing its own regulations. The Agency knew for 20 years that one company it permits to spread biosolids intentionally created a “mixed” product to spread on agricultural fields that sometimes was comprised of as much as 15% of listed hazardous waste. A search of Ecology documents by Yelm-based Preserve the Commons found that much of it was flammable with large quantities of paint thinner. The company has violated regulations on several occasions and been slapped on the wrist repeatedly by Ecology, but Ecology allows the outfit to continue operations at full bore. Other applicants have submitted erroneous and incomplete environmental impact assessments required under the State Environmental Protection Act (SEPA). Ecology has accepted flawed “SEPA checklists” and went ahead and approved those biosolids applications. Only concerted public outcry has ever caused Ecology to reject an errant SEPA checklist. Apparently, it’s too much trouble for the agency to check the accuracy on its own. Environmental assessments of potential biosolids-receiving farms, primarily left up to the applicant but really the responsibility of the agency, have routinely been cursory, bordering on negligent. In some cases, assessments failed to identify existing wells and drinking water springs in the affected area or failed to make note of critical aquifer recharge area designations of potential sites. Post-application monitoring of biosolids disposal sites (farms, etc.) is non-existent-- No mandated groundwater testing-- No mandated soil testing-- No mandated crop tissue analysis.
Science backs up banning the land application of sewage sludge even if the regulations don't. It's a new era. Let's go with science.
Please comment on the renewal of Ecology's dirty business before the July 5 deadline. Go here to comment:
For more information on the hazards of the land application of sewage sludge, here are some resources:
Sludge in the Garden: Toxic PFAS in Home Fertilizers Made From Sewage Sludge, 2021, by the Sierra Club and the Ecology Center
Sierra Club Wastewater Residuals Team: The Sierra Club national Board of Directors have adopted policies clearly stating that the Sierra Club opposes the use of contaminated toxics and/or pathogen containing waste as a compost ingredient and the application of municipal sewage sludge as a fertilizer.
Sierra Club of Washington State Sewage Sludge Free Washington: "It is your right to know what is in your food and compost. Compost and food may contain sewage sludge"
The Northwest Toxic Communities Coalition: Comprised of non-profit groups from EPA Region 10 areas which address local hazardous substances and environmental health issues. "There are alternatives to handling this waste to that of releasing toxic effluents into water bodies and allowing the land spread toxic sludges to seep into groundwater and run into surface water bodies."
Toxic Free Future (based in WA): "Sludge from municipal treatment plants should be tested for PFAS chemicals, beginning with biosolids applied to dairy and other farms in our state. Farms and other lands where biosolids have been applied should also be tested. Alternative disposal methods should be investigated to keep PFAS off of farms and other lands. These actions are vital to prevent continual recontamination of our food and bodies with PFAS."
Protect Mill Canyon Watershed: In 2017 Protect Mill Canyon Watershed, an ad hoc citizens' committee, organized and successfully prevented sewage sludge from being spread on farmland adjacent to where organizers lived, farmed and obtained drinking water. Protect Mill Canyon Watershed wants the state of Washington to stop allowing sewage sludge to be dumped on farmland. Their website is a repository for hundreds of scientific documents and articles about the hazards of sewage sludge.
Preserve the Commons: Another local citizens’ committee working to ban the spreading of sewage sludge in Washington. Based in Yelm.
"Biosolids Hit The Fan," by By Joel Preston Smith in the Sound Consumer, newsleter of the Puget Consumer Co-op (PCC). The article is from 2012. It's high time we ended the practice.