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Spotlight Shines on Sewage Sludge as Likely Source of PFAS Food Contamination. Problem Likely Widespread. What Will Washington State Do?

Chrys Ostrander

Truck slinging sewage sludge on a farm field with a "NO" symbol superimposed.

It's time to tell the Washington State Legislature to abandon its ill-conceived declaration that sewage sludge as fertilizer is "beneficial" and accept the science that tells us, land application of sewage sludge has no place in a green 21st century.

Contact your state legislators now. Tell them:


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.

Find your legislators:

PFAS in Food in the News

"Pollution from PFAS—notoriously dubbed 'forever chemicals'—has been linked to multiple cancers, diabetes, and a wide range of other health problems. Their presence in the environment and in our bodies is now considered such an important issue that last fall, the Biden administration announced a plan involving at least six federal agencies to combat PFAS in air, water, and food.

"In Michigan [January, 2022], beef from a small cattle farm was found to contain PFAS after the farmers fed the animals crops grown with fertilizer made from wastewater byproducts tainted with the chemicals [sewage sludge]. And in Maine [also in January, 2022], an organic produce farm growing heritage grains and vegetables for local communities stopped selling its products after finding high levels of PFAS in the farm’s produce, soil, and water. Tests showed Songbird Farm’s well water had PFAS levels 400 times higher than the state’s legal limit for drinking water. The contamination was also tied to wastewater sludge that had been applied to the land in the early 1990s, more than two decades before Adam Nordell and Johanna Davis established the farm [note: sewage sludge is prohibited in certified organic agriculture]."
Civil Eats: The Field Report: PFAS Is Contaminating the Food Supply, February 2, 2022

In 2016, Maine dairy farmer Fred Stone discovered that his cows were producing PFAS-tainted milk which brought financial ruin to the century-old family business.

"The chemicals on Stone’s farm likely came from biosolids, or nutrient-rich sewage from municipal utilities, that he spread across his fields, according to a report [in 2018] by Maine’s Department of Environmental Protection. The chemicals are known as perfluoroalkyl substances, or PFAS – some of which have been linked to cancers, liver damage, low birth weight and other health problems."
Reuters: The curious case of tainted milk from a Maine dairy farm, March, 2019

"Given the scale of the problem, advocates and lawmakers are calling for action in states and at the federal level. In Maine, Songbird’s farmers testified at a hearing for a bill that would curb the practice of spreading contaminated sludge. In Washington, the Environmental Protection Agency (EPA) will monitor some PFAS chemicals in drinking water starting next year, and the Biden administration’s plan includes U.S. Department of Agriculture (USDA) research on contamination in the food system and expanded FDA testing of PFAS in food. But it’s unclear whether all these efforts will be enough to halt the practice, how the existing, and likely wide-spread, contamination should be remediated, or what will happen to the farmers and eaters who have been affected. At a House Agriculture Committee Hearing today, Congresswoman Chellie Pingree (D-Maine) promised she will ask 'how NRCS [the Natural Resources Conservation Service] can help farmers test and respond to PFAS contamination.'”Civil Eats: The Field Report: PFAS Is Contaminating the Food Supply, February 2, 2022

In Washington State, what in years past (since 1992) has been a rubber stamp regulatory exercise has bogged down. The quinquennial process of renewing the Statewide General Permit for Biosolids Management (the regulations regarding the spreading of sewage sludge on farms and in forests) that began in May, 2021 is stalled and overdue. Conveniently, the state has allowed itself to continue the program full bore even though the current General Permit is expired. Try that with your driver's license and see how far it gets you. A public comment period on the renewal ended way back in July, 2021 and as of February, 2022, the Department of Ecology has yet to release the final regulations and a report in which it responds to public comments which they promised to complete last year.

Why the delay? Two major reasons:

1) In November, 2021, The Department of Ecology released its Per- and Polyfluoroalkyl Substances Chemical Action Plan (CAP) in response to the emerging PFAS crisis. Though criticized as being full of very poorly researched and asserted information, the Action Plan specifically addresses sewage sludge that is applied to land which the industry likes to call biosolids. Since the report was compiled, the spotlight has shone ever more brightly on biosolids as a major source of PFAS contamination. What makes this contamination from biosolids so concerning is the fact that the PFAS toxins are readily taken up into the food grown on these farms that is destined for human consumption. No wide-spread testing of farms and foods has begun nationally.

The Chemical Action Plan only puts forth recommendations that may or may not be implemented later by action of the state legislature or by Ecology. The recommendations around biosolids include

• Establish biosolids and soil sample collection and handling methods for PFAS
• Accredit Washington labs for EPA-validated analysis methods.
• Use EPA-validated analysis methods for biosolids and soils.
• Conduct credentialed third-party review of raw mass spectrometer PFAS data.
• Investigate land application sites where procedures mimic rates and practices under
current state rule (Chapter 173-30821 WAC).
• Evaluate realistic exposure pathways.
• Evaluate risk modeling using realistic input values.
• Collaborate with stakeholders to get accurate and precise biosolids data. Initial
results should remain anonymous.
• Compile analysis data with statistical review.
To conduct this work, Ecology will collaborate with municipalities managing WWTPs.
Per- and Polyfluoroalkyl Substances Chemical Action Plan P. 29

It is possible that Ecology is amending the final regulations to address some of these recommendations.

2) Sixty-five percent of the public comments received by Ecology by the end of the comment period in July, 2021 were opposed to the continued land application of sewage sludge (biosolids). Responding to this overwhelming showing of support for ending the practice might also be playing a role in the delay of the release of the final regulations.

Could it be that the prominence of bioslolids as a source of human exposure coupled with the unprecedented public call for banning land application sparked a conversation within Ecology to begin the process of backing out of its decades-long love affair with sewage sludge as fertilizer?

If the past is any indication, probably not. The more likely scenario is that Ecology will continue to thread the needle so that land application of sewage sludge can continue with very little modification of current practices. Under orders from the state legislature that waved a magic wand back in 1992 and proclaimed municipal sewage sludge to be a beneficial resource, it mandated that the Washington State Department of Ecology *promote* its use on soil. The Department rose to its new role with aplomb. It helped create an entire industry of sludge haulers and sludge storage facilities handling hundreds of thousands of tons of sewage sludge every year. Ecology cooperated with the establishment of Northwest Biosolids that promotes land application, lobbies policy-makers to maintain the status quo, and spends copious resources trying to denigrate emerging science that indicates land application of sewage sludge is not as safe and benign as they would like to have you believe. NW Biosolids says they spend $200,000/yr. on sludge research more to their liking. Their chief propagandist, Sally Brown, an Associate Professor at the University of Washington, has just been appointed by the U.S. Secretary of Agriculture to the USDA Urban Agriculture Advisory Committee, a troubling development that signals an effort to normalize the use of toxic municipal sewage sludge in urban agriculture such as community gardens which predominantly are utilized by low-income people of color to augment their food supply.

For decades Ecology has heard from environmentalists calling for banning land application of sludge. For decades Ecology has largely ignored them. The U.S. Environmental Protection Agency sets the baseline regulations for the land-application of biosolids and those regulations are woefully inadequate compared to the mounting evidence of the multiple toxic contaminants present in sewage sludge. Even the EPA's own Inspector General agrees. In November, 2018, the EPA’s Office of Inspector General issued a report of an audit of the EPA’s Biosolids Program.  “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. The EPA consistently monitored biosolids for nine regulated pollutants. However, it lacked the data or risk assessment tools needed to make a determination on the safety of 352 pollutants found in biosolids ... [including] sixty-one designated as acutely hazardous, hazardous or priority pollutants in other [Federal] programs” the report states.

That's correct, the EPA only requires testing for nine pollutants. Every time concerned citizens have pleaded with Ecology to understand the importance of testing for a wider array of pollutants or to put a moratorium on land application based on the potential risks, Ecology's response is to hide behind the EPA regulations and claim they are adhering to the requirements.

The Per- and Polyfluoroalkyl Substances Chemical Action Plan overtly perpetuates this approach by throwing the precautionary principle to the wind and declaring "it is premature to add or change regulatory limits given the absence of [PFAS] data from Washington biosolids." What you don't know can't hurt you, right?

It remains to be seen how Ecology will proceed from here. One thing is certain, if the renewal process for the Statewide General Permit for Biosolids Management is finalized in a way that keeps sludge haulers busy dumping sludge on farmland, environmentalists are gearing up to appeal.

It's time to tell the Washington State Legislature to abandon its ill-conceived declaration that biosolids as fertilizer is "beneficial" and accept the science that tells us, land application of sewage sludge has no place in a green 21st century.

Contact your state legislators now. Tell them: 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.

Find your legislators:

February, 2022