Monday 10 February 2020

Open Letter to Minister George Heyman and the CRD's Board of Directors

Open Letter to Minister George Heyman and the CRD's Board of Directors

Minister George Heyman, in a recent letter, outlines that Victoria's biosolids strategy must include, in the long-term  "a range of beneficial uses including, but not limited to forestry (for example fertilizer / soil conditioner), reclamation (for example mines), landfill closure and agriculture." In the short-term, Heyman states that Victoria's strategy may include "applying biosolids to the land." He says that the present policy in place for the region "unnecessarily limits the options available for beneficial use."  (He is reacting to CRD's very wise ban against land disposal of biosolids - voted and passed several years back). Heyman goes on to state that, "it is the ministry's position that the land application of biosolids ... will benefit the environment and potentially reduce costs to the taxpayer."

This position is at odds with recent science. Biosolids is a pollutant-rich material, and spreading it on soils, whether on forests, farms, or flower gardens, means making those pollutants available to the terrestrial environment.

This past week alone three articles were published which dramatically encapsulates these concerns.  The Telegraph ( ) published an article - "Microplastics making their way to British farms in human sewage fertilizer" - in which they warn, "microplastics could harm soil ecosystems or crops either directly or through hormone-disrupting substances, and contain chemicals that could be released slowly as they break down over hundreds of years" Interestingly, the Canadian Government published its "Draft science assessment of plastic pollution 2020" this past week, where it states that - "It is estimated that 99% of microplastics are removed from the influent but are retained in sewage sludge ... Microplastics can therefore enter terrestrial environments through the application and use of sewage sludge as fertilizers for agriculture or landscaping purposes"  ( ). 

Another Important new scientific study just came out on a related topic - "Pharmaceutical and Personal Care Products: From Wastewater Treatment into Agro-Food Systems"
( ) In this, the scientists demonstrate that "Use of biosolids in agriculture leads to soil contamination with PPCPs and their metabolites, providing a route for accumulation in food produce, which poses potential risks to environmental and human health" and that  "The extensive use of biosolids in agriculture introduces PPCPs and other contaminants of emerging concern to arable soil and has the potential to contaminate food produce, constituting a route for human exposure"  It is worth pointing out that the OMRR guidelines that Heyman and his government rely on to "assure safety" do not test for microplastics or pharmaceuticals - or other  CECs (contaminants of emerging concern) for that matter - sadly, out of the tens of thousands of pollutants known to be in biosolids, they test for barely a dozen!

A third major article was published this week by Greenpeace - "Secret Environment Agency report finds sewage sludge (biosolids) destined for English fields contaminated with microplastics, weedkiller, and "persistent organic pollutants" ( ). The article notes that - "Investigators commissioned by the agency found sewage waste destined for English crops contaminated with dangerous "persistent organic pollutants" like dioxins, furans, and polycyclic aromatic hydrocarbons at "levels that may present a risk to human health". They also reported evidence that these sludges, which are routinely spread as fertilizer on hundreds of farms, were widely contaminated with microplastics that could ultimately leave soil "unsuitable for agriculture".

There have been many more damning studies published in just the past year. Here are just three more that might serve as an overview of this problematic practice - 

1. Root uptake of toxins -
2. Germination and growth issues after biosolids application -
3. Grazing animals affected by biosolids pollutants -

Minister Heyman assures us that government guidelines will protect the public. Many do not agree. The David Suzuki Foundation on the topic of "biosolids"  has made the following statement - "The David Suzuki Foundation does not support the dumping of sewage sludge, treated or otherwise ... sewage sludge can contain a brew of nutrients laced with PCBs [polychlorinated biphenyls - in low levels]; dioxins and furans (again, generally in low levels); chlorinated pesticides [such as DDT Aldrin, endrin, chlordane, indane, mirex, etc..); polybrominated diphenylethers (PBDE's - Flame retardant chemicals); hormone mimicking compounds like Phthalates and nonylphenols and their ethoxylates: carcinogenic polycyclic aromatic hydrocarbons [PAHs]; heavy metals ( in particular arsenic, cadmium, copper, lead, mercury, selenium, and zinc); bacteria, viruses, parasitic worms, and fungi; industrial solvents; asbestos; and petroleum products ... All of these chemicals can, and do contaminate the soil and can contaminate the crops grown in those soils.  There is also the associated problem of these contaminants running off treated fields and into local water courses when it rains." 

So too, The Sierra Club  has stated that it "opposes the land application of municipal sewage sludges as a fertilizer and/or soil amendment because the current policies and regulations governing this practice are not adequately protective of human health."

These views are also shared by enlightened European governments, and their Environmental agencies. For instance - 

Switzerland has completely banned the use of biosolids on agricultural soils because of "the risk of irreversible damage to the soil, the danger to public health and possible negative effects on the quality of the food farmers produce"

The Swedish Government - "since biosolids contain environmental and health hazardous substances, drug residues and microplastics, our task force will propose a ban on spreading sewage sludge on farmland"

Norwegian Scientific Committee for Food and Environment - "biosolids application may be causing persistent, pernicious and almost totally ignored contamination of agricultural land" 

The German Environment Agency - "With the precautionary principle and in light of the pollutants found in biosolids, we deem the agricultural use of biosolids to be a serious public health & environmental hazard & advocate that this practice be phased out"

(It should be noted that in the EU, UK and Scandinavia, the allowable pollution levels are generally more strict than those listed in the OMRR guidelines that Heyman relies upon to "assure safety").

Those in favour of "land application" see merely organic matter along with some plant nutrients like nitrogen and phosphorus, and presumably, because it contains some human fecal matter, they see it as a form of manure. This limited view utterly ignores the actual make-up of this waste material. It is after all, the "stuff" taken out of the wastewater within these treatment facilities, in order to CLEAN the water - purify it of its pollutants as much as possible, before the water is released back into the environment. This "stuff" therefore represents the collected and concentrated toxic waste eliminated from the liquid stream. It is a mirror of modern urban life - a goulash comprised of myriad pollutants - the remains of everything we flush away - cleaners, pharmaceuticals, dyes, solvents, microplastics and microfibers, fire retardants - you name it.  As Prof. Murray McBride, of Cornell University, says, it is "a material containing unknown concentrations of thousands of chemicals with undetermined toxicities."

The sludge pushers will say that sewage sludge and "biosolids" are very different things. Not true. The minimal "processing" done to the sludge - be it adding lime, or woodchips, and composting it - anaerobic or aerobic digestion, pelletizing it, or liquefying it - all of these are superficial treatments. The problematic constituents within this matrix of pollutants remains primarily the same. As numerous studies, including those of the US Geological Survey, have shown - thousands of chemicals remain in these so-called "biosolids" ... for instance - 

Microplastics? - Still present - ( "43% of microplastics that go down the drain eventually end up applied to agricultural land as biosolids." ) Nanomaterials? -Still present - (Uptake of Nanomaterials see - ). Endocrine disruptors like flame retardants? - Still present - (The U.S. Geological Survey scientists confirmed that rainfall mobilized chemicals (including detergents, fire retardants, plasticizers, and antibacterials) from municipal biosolids-amended agricultural fields, directly to runoff. Most (14 of 17) of the chemicals examined were present in edge-of-the-field runoff and not depleted in concentration after three 100-year rainfall events For more on this see - ). Prions? - Still present - ( "if prions were to enter municipal wastewater treatment systems, most of the agent would partition to activated sludge solids, survive mesophilic anaerobic digestion, and be present in treated biosolids.'' see - ) In fact some problems like superbugs - antimicrobials, may even get worse through these processes (Antibiotic residues and antibiotic-resistant bacteria - - "spreading of sewage sludge leads to a significant increase of ARG in the soil" )

This practice of land disposal is NOT "green" or "sustainable" or "recycling" or indeed "beneficial" -  it is merely a cheap way of shifting our cities' pollutants.  As Dr. Sierra Rayne has noted - "The science doesn't support the disposal of sewage sludge across the landscape. The supposed benefits are more than offset by the risks to human and environmental health. An unimaginably large number of chemical and biological contaminants exist in these materials, and they persist in the product up to, and after, land disposal. Scientific investigations have identified only a tiny fraction of the total contaminant load. Governments are playing Russian roulette with sewage sludge. Over time, there is a high probability this game will be lost at the public's expense." (

It is so disappointing to hear Minister Heyman aping the language of the sludge disposal industry when he uses phrases like "beneficial use" ! Perhaps he could explain exactly what is "beneficial" about loading our soils with microplastics, endocrine disrupters, antibacterial resistant bacteria and myriad other pollutants? Beneficial for whom? ...certainly for the sludge industry, and governments that merely search out cheap short-term strategies! It is decidedly NOT "beneficial" for the public - and not for future generations who will depend on healthy soils for years to come.

For the reasons set forth above, I believe that in the public's best interest, the ban on land disposal of biosolids within the CRD should remain in effect.

To dive more deeply into the issues 

To see what experts from leading institutions have to say about "biosolids" - go here - To see other new scientific studies on "biosolids" - go here - To see more information around the faulty "risk assessment" practices (used by this government and the sludge industry) for "biosolids" - go here - To see what alternatives there are to land disposal of "biosolids" - go here -

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