Spokane, WA – In 1992, the Washington State legislature deemed “biosolids” to be a beneficial resource and mandated that the Washington State Department of Ecology promote its use on soil, including on farms where crops for human consumption are grown and forest lands (the practice is called “land application.”). “Biosolids,” a made-up, euphemistic trade name, is the non-liquid sewage sludge byproduct of municipal wastewater treatment plants that is filtered out before the treated watery effluent is discharged into rivers.
This year, the Department of Ecology proposes to re-issue a five-year Statewide General Permit for Biosolids Management which expired in September, 2020. Notice has been published in the State Register. Ecology is accepting public comments until 11:59 PM July 1, 2021. Ecology will host public hearings on the proposed Statewide General Permit for Biosolids Management on June 22nd (10:00 AM) and 24th (7:00 PM).
Environmental, food and agriculture organizations around the state oppose the land application of sewage sludge. The Sierra Club, Seattle-based Toxic Free Future, and the Northwest Toxic Communities Coalition are among the organizations seeking an end to the practice, beginning with Washington State. PCC Community Markets, the nation’s largest co-op grocery retailer with 13 stores and more than $288 million in revenue, also seeks an end to land application of sewage sludge. These groups cite multiple peer-reviewed studies and government reports which clearly demonstrate that sewage sludge is highly contaminated with industrial and pharmaceutical wastes, microplastics, pathogens and other pollutant contaminants– including the alphabet soup of ubiquitous super toxins identified as Per- and PolyFluoroAlkyl Substances (PFAS). A 2009 U.S. Environmental Protection Agency study concluded that all sewage sludge contains toxic and hazardous contaminants. In 2018, the EPA’s Office of Inspector General concluded that EPA hasn’t the means to prove “biosolids” safe, yet the practice remains legal, is practiced throughout the country and in fact is actively promoted by government agencies and private trade organizations. Some of the pollutant contaminants in sewage sludge are known to be taken up in plant tissue. At least one dairy farm in Maine was forced to close in 2016 when the milk being produced there was found to be tainted by PFAS that had been brought onto the farm as biosolids to “fertilize” the cow pasture where the cows ate. State inspectors in Michigan ordered a halt to the practice of spreading biosolids in 2017 after learning the material was laced with one of the potentially harmful chemicals known collectively as PFAS. PFAS contamination has been detected in the Marinette and Peshtigo areas of Wisconsin (‘The Dairy State’) in soil, sediment, groundwater, surface water, private drinking water wells and biosolids prompting the state to develop a PFAS Action Plan.
Opponents of land application are encouraging the public to send a clear message to Ecology: 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. They oppose the re-issuance of the Statewide General Permit for Biosolids Management.
Those opposing the land application of sewage sludge are primarily concerned that federal EPA “biosolids” regulations, which Washington State bases its program on, only require testing for nine heavy metals, nitrogen and selected pathogens. That leaves the many other toxic contaminants, known and unknown entirely unexamined (for every batch of sewage sludge will contain a different chemical cocktail). There is also great concern since the treatments that sludge receives to reduce pathogen populations never completely eradicate them, it is possible that pathogenic organisms can reproduce in the moist, nutrient-rich substrate and become a hazard to humans and wildlife. This is especially a concern in the case of retail consumer products containing sewage sludge that might harbor infectious pathogens. Families gardening with their children could become sick, or be exposed to other chemical toxins from the sludge.
Land application of sewage sludge is heavily promoted by Ecology as free fertilizer for farmers, as well as by a quasi-public trade group based in Gig Harbor known as Northwest Biosolids. One of several citizen organizations in the state, Protect Mill Canyon Watershed, reports that Ecology staff are very aggressive in pursuit of their “partnership” (Ecology caseworker’s term) with one of the state’s main land application companies, Fire Mountain Farms. FMF has been repeatedly slapped on the wrist for code violations like storing chemical wastes in the same piles of “biosolids” that it land-applies around the state. FMF 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 a Yelm-based group, Preserve the Commons, found. Much of it was flammable with large quantities of paint thinner.
In 2016, a permit was issued by Ecology to spread sewage sludge on nearly 1000 acres of wheat fields adjacent to Mill Canyon in Lincoln County. Mill Canyon is home to commercial organic food and medicinal herb producers and a natural spring that supplies many neighbors’ drinking water directly downhill from one of the targeted wheat fields. The community living in the canyon was very concerned about the migration of toxins through flooding, leaching to groundwater, wind storms and the fact (established by USDA soil maps) that most of the targeted land was classified as “HEL,” Highly Erodible Land. They organized Protect Mill Canyon Watershed and succeeded in blocking that land application after a long grassroots campaign.
Ecology says “the draft permit streamlines some requirements, reducing the regulatory burden for the [biosolids industry] in the state.” This mirrors a complaint expressed (at a public meeting) by one of the officers of FMF that “there is too much paperwork.” FMF has submitted blatantly inadequate and incorrect boiler plate language in the required environmental analyses (SEPA checklists) and now seeks even less oversight with the “streamlined” requirements proposed, opponents say.
Almost weekly, new studies come out around the world condemning the practice of conditioning soil with sewage sludge as dangerous folly. Advocates for banning land application would like to see Ecology push back against the unscientific and politically-motivated legislative mandate that instructs the agency to violate its own 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.” Ecology must instead begin to rely on the plethora of independent current science around sewage sludge, not outmoded, baseless claims as to its “beneficial use.” If “beneficial use” means putting all the pollutants that Washington tax payers have spent millions of dollars to keep out of the environment, right back into the environment, opponents say, that’s anything but beneficial. They also call on the state to seriously research alternative methods of disposal such as pyrolysis, gasification or extraction of useful materials which are increasingly being employed by other countries around the world.
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 of 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.
PCC Community Markets’ letter to Ecology dated January, 2020. “Application of biosolids to agricultural lands, unfortunately, presents significant risks to both aquatic and land-based ecosystems through introduction of potential toxins and potential pathogens. Overall, we do not believe that biosolids application to agricultural lands should continue or be permitted— especially with the increasingly fragile state of our local environment and species, such as Chinook salmon.”