Sludging Farms in Italy

Here is a very recent short documentary video on sewer sludge disposal on Italian agricultural lands. Some very good reporting here, and eye-opening footage of this disgraceful practice (thank you to fellow sludge fighter Aldo Agosta for providing this, and doing the subtitles!! )

Why we must end the land-disposal of sewer sludge aka “biosolids”

Switzerland has completely banned the use of sewer sludge aka "biosolids" on agricultural soils. They took this stand 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 precautionary principle has absolute priority in soil protection." … "Soil is a limited, ecologically and economically valuable non-renewable resource. Along with water and air, it is essential for life.”  We must stop the sludge industry from calling this toxic goulash a “soil amendment.”  As Dr. Caroline Snyder has noted - "Land-applied municipal sewage sludge (biosolids) is a highly complex and unpredictable mixture of biological and chemical pollutants. Biosolids generated in our large industrialized urban centers is very likely the most pollutant- rich waste mixture of the 21st century."

Safety testing, by biosolids scientists, looks merely at single chemical toxicity amounts. This is faulty, simplistic, and outdated. As the scientists taking part in the Halifax Project have shown, it is the exposure to a variety of toxins in low-dose that can cause cancer. (The Halifax Project took place between 2012 and 2015 and it involved more than 350 cancer researchers and physicians from 31 countries …  focused on the carcinogenic potential of low dose exposures to mixtures of chemicals in the environment - see http://www.gettingtoknowcancer.org/taskforce_environment.php) The absurd situation is that we have soil specialists, agronomists etc. determining the safety of something they are utterly unqualified to make such pronouncements about - this is the purview of chemists, doctors/oncologists.

Ignoring this problem may be a very grave mistake indeed. As Dr. Rayne has noted – “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 … You are not going to find a problem if you don't look for it. Of course, over time, that problem may also come looking for you … 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.” (see http://bit.ly/1sb2qOP )

The sludge industry has co-opted much of the language of sustainability. This however is an unwarranted annexation. Land disposal is not "recycling"; it is simply transferring a complex mixture of toxic chemicals and pathogens from our large industrialized urban centers to farms and forests. The spreading of a city’s toxic burden onto rural areas can’t be seen as “green” in any way. The constant trucking of thousands of tons of sewage waste into the countryside represents a huge CO2 release into our already compromised environment. Imagine the savings if a gasification plant were to be situated directly beside the waste water treatment facilities!

The issue of Prions in Biosolids represents such a grave danger that the precautionary principle must apply. A recent and alarming publication by Valerius Geist, Professor Emeritus, University of Calgary David Clausen, (former) Chair, Wisconsin Natural Resources Board Vince Crichton, (former) Co-Chair, Canada’s National Wildlife Disease Strategy Darrel Rowledge, Director, Alliance for Public Wildlife) made the following observations - "Normal sewage treatments do not degrade or inactivate prions: “most would partition to activated sludge solids, survive mesophilic anaerobic digestion, and be present in treated biosolids."  … “CWD is certainly the most contagious prion infection, with infected animals shedding prions from every orifice." … "CWD has been shown to persist and remain infectious in the environment. CWD prions adhere to minerals such as montmorillonite (Mte) in clay-based soils that can dramatically increase infectivity, up to 680 times" … "Transmission of CWD has been shown to occur: animal to animal, soil to animal, plants to animal, soil to plants to animal" … "This underscores the very essence of the precautionary principle, and nowhere is it more requisite than with respect to infectious pathogens. Inadequate policy or regulatory failures can result in pandemics that kill thousands or even millions of people or other animals, causing enormous damage on economies and ecosystems.”  (http://www.apwildlife.org/publications/)

Superbugs are emerging as a serious threat and they are found in these waste residuals. Sewage sludge/biosolids contain a  largely unknown number of bacterial and viral pathogenic organisms, protozoan and other parasites as well as prions. What is often never discussed in the pro-sludge and biosolids literature is the fact that ALL sewage treatment plants in the world, including all secondary and tertiary treatment plants breed Superbugs or multi-drug resistant bacteria, (Y. Luo et al, Environmental Sci. Technol. Lett. 2014, 1, 26-30; A. McGlashen, Sci.Am. 2017, 01/18.) The reason is simply the fact that antibiotics end up in sewage and during the treatment process with bacteria, the bacteria that acquire antibiotic resistance will get selected in the presence of antibiotics in the sewage. These and other Superbugs make their way into the sewage treatment plants from the hospitals, homes and industrial facilities and so it makes sense that we should not spread them or plasmids containing the genes for this resistance on the land where they can further contaminate and multiply their resistance genes. (see also "Deadly superbugs from hospitals get stronger in the sewers" http://www.latimes.com/business/la-fi-superbug-sewers-20160307-story.html )

We have better methods of dealing with our cities’ toxic sewage waste. Gasification / pyrolysis is by far the best, cleanest option to date. As Yale professor Jordan Peccia has noted, gasification “can destroy pathogens and mineralize persistent organic chemical contaminants, while producing energy and concentrating valuable metals and inorganic chemicals.” These units have been up and running for well over a decade in Austria, Italy, Germany, Thailand, Korea, Sweden, and the USA.

Rarely has there been a less regulated toxic substance. Every aspect of the process, from site selection to application procedures, to the toxic composition of the sludge itself — all of it is woefully under-supervised. In fact, to a great extent it relies on self-regulation. OMRR guidelines (and the EPA's) are simply inadequate to deal with emerging environmental issues or ensure public safety. If the product is as the gov’t says, “stringently regulated”, then why out of the thousands of toxins and chemicals in biosolids are only about a dozen tested for? How, if it is so “stringently regulated,” did the Suzuki Foundation recently find very toxic components in the bisosolids delivered to the Nicola Valley from the Lower Mainland? If biosolids are deemed to be “safe” then why do major food producers like Campbells, DelMonte and Whole Foods reject any produce raised with Biosolids? Because they rightly fear the levels of toxicity, that’s why! The Water Utilities do a great job of separating the dangerous chemicals out of the water, so that water can be returned to Mother Earth. Why would we ever think it a good idea to turn around and put those collected and concentrated toxins back into the environment we just took them out of? It is reckless and short-sighted.

ike the Halifax Project with its 300+ cancer doctors) are trying to get the world to acknowledge. The absurd situation is that we have soils specialists, agronomists etc determining the safety of something they are utterly unqualified to make such pronouncements about - this is the realm of chemists, doctors, oncologists ...ike the Halifax Project with its 300+ cancer doctors) are trying to get the world to acknowledge. The absurd situation is that we have soils specialists, agronomists etc determining the safety of something they are utterly unqualified to make such pronouncements about - this is the realm of chemists, doctors, oncologists ...

Dr. Thomas Maler – “it seems obvious that application of sewage sludge/biosolids on the land is not the answer to dispose of these toxins and pathogens … Not putting this toxic soup on the land is the only way of protecting our environment and that’s the primary reason for treating our sewage in the first place.” (see http://bit.ly/2zXeXwo for Dr. Maler's overview of the issues) 

Dr. Richard Honour - "Few in any governments appreciate that nearly all chronic diseases are caused by long-term exposure to low levels of environmental contaminants and pollutants. We should be trying to minimize this exposure, not amplifying it. It is time to end land disposal of Toxic Sewer sludge, and look at cleaner, greener alternatives - gasification / pyrolysis."

Swiss Protect their Soils & Ban Biosolids from Agriculture

The Swiss have totally banned "biosolids" from agriculture and developed other policies to protect its soils! 

Switzerland has completely banned the use of sewer sludge aka "biosolids" on agricultural soils.

They took this stand 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 precautionary principle has absolute priority in soil protection."

"Soil is a limited, ecologically and economically valuable non-renewable resource. Along with water and air, it is essential for life."

"All human activities affecting the soil must always take into account that it is scarcely possible to generate new soil because soil formation takes a very long time. Soil is an inert medium that takes a long time to respond to exogenous influences, which means that problems are only recognised later and often too late. Soil is the final repository for pollutants, which means that chemical pollution is often irreversible. That is why only structurally intact soil can function properly."

"Precautionary measures must be taken to protect fertile soil - irrespective of its use - from physical, chemical and biological pressures."

"Like water, air, and forests, soil is a common good, which may be used but not destroyed by its owner. Anyone who uses the soil is also responsible for protecting it."

"Chemical soil contamination impairs soil fertility. It leads to defects in plant growth and causes health risks for humans and animals through the consumption of contaminated harvested products, polluted groundwater and direct contact with soil (e.g. by playing children)."

For more on the Swiss concepts of soil protection see - https://www.bafu.admin.ch/bafu/en/home/topics/soil/info-specialists/soil-protection-measures.html

For more on the original ban on biosolids see - https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-1673.html 

A note on "EQ - Class A Biosolids"

A note on "EQ" "Class A" "Biosolids"

From sludge industry player Lystek -

“In Class A biosolids, pathogens must be reduced to virtually non-detectable levels and the material must also comply with strict standards regarding metals, odours and vector attraction reduction (VAR) as specified in the US EPA, Part 503 Rule. VAR refers to processing which makes the biosolids less attractive to vectors, which have the potential for transmitting diseases directly to humans or can play a role in the life cycle of a pathogen, as a host. Examples of vectors are flies, mosquitoes, rodents, birds, etc. Various processes can be utilized to achieve Class A designation such as anaerobic digestion, lime stabilization, composting and thermal hydrolysis. This designation means the material meets U.S. EPA guidelines for land application with no restrictions. Thus, Class A biosolids can be legally used as fertilizer on farms, vegetable gardens, and can be sold to home owners as compost or fertilizer. The term Class A EQ (Exceptional Quality) is used to describe a biosolids product that not only meet, but exceed, all Class A pathogen reduction metals and VAR requirements.”  (http://lystek.com/what-are-class-a-class-b-biosolids/)

“EQ, Class A, and Biosolids” – these are not scientific terms – they are PR terms cooked up to generate sales. They are simply “putting lipstick on a pig”!  -- A very toxic pig at that.

Note that only 10 metals and pathogens are tested for to qualify as "EQ" (along with odour and vector reduction). There are thousands of toxins in sewer sludge aka “biosolids” – and here are just a few of them (none tested for) that may be found in your so-called “EQ” compost - dioxins ,acetone, anthracene, barium, beryllium, carbon disulfide, 4-chloroaniline, diazinon, fluoranthene, manganese, methyl ethyl ketone, nitrate, nitrite, phenol, pyrene and silver. Worrying too is that prions, microplastics, fire retardants, hormones and synthetic hormones, pesticides, pharmaceuticals, and plasticizers may all be found in biosolids of ALL classes.

Safety testing, by biosolids scientists, looks merely at single chemical toxicity amounts. This is faulty, simplistic, and outdated. As the scientists taking part in the Halifax Project have shown, it is the exposure to a variety of toxins in low-dose that can cause cancer. (The Halifax Project took place between 2012 and 2015 and it involved more than 350 cancer researchers and physicians from 31 countries …  focused on the carcinogenic potential of low dose exposures to mixtures of chemicals in the environment) See this link for more on their findings -  http://www.gettingtoknowcancer.org/index.php


The use of sewer sludge / “biosolids” in farming or home gardening means exposing people to a myriad of potentially dangerous toxins. The precautionary principle must apply!

The minimal "processing" done to the sludge - be it adding lime, or woodchips, and composting it - anaerobic or aerobic digestion, pelletizing it, or liquifying 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" … 

 Microplastics? - Still present - ( https://bit.ly/2Sngwd2 "43% of microplastics that go down the drain eventually end up applied to agricultural land as biosolids." ) Nanomaterials? -Still present - (Uptake of Nanomaterials see - https://rsc.li/2WfDdCA ). 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 - https://on.doi.gov/2Eisa4M ). 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 - https://bit.ly/2GznGZJ ) In fact some  problems like superbugs - antimicrobials, may even get worse through these processes (Antibiotic residues and antibiotic-resistant bacteria - https://bit.ly/2KM7xj5 - "spreading of sewage sludge leads to a significant increase of ARG in the soil" )

To see this sludge then as a "soil amendment" is to make an absurd leap - both in logic and in language! The purveyors of this sludge, those in the biosolids business, have "greenwashed" the language, BUT there is simply no way that present-day science can "wash" away these thousands of chemicals. It is a waste product rich in pollutants. 

For more insight into these issues from arm’s length scientists please see  -


"Polluting for Profit"-The "Biosolids" Business  https://bit.ly/2DKNpff
Biosolids dangers- bit.ly/2EuAP3K
USA Scientists- https://bit.ly/2VRnush
UK Scientists - https://bit.ly/2noyE7s
Canadian Scientists- http://bit.ly/1sb2qOP
The Guardian- https://bit.ly/2LPWNSM


For more on “biosolids” being used in compost for gardening, please see –

 Gardening with Toxic #biosolids =
 http://healthjournal.life/human-sewage-sludge-in-compost-its-really-a-thing-and-beware/
 https://www.focusforhealth.org/beware-toxic-organic-compost/
 https://www.planetnatural.com/compost-sewage/
 http://biosolidsbattleblog.blogspot.ca/2016_09_01_archive.html

We Should Expect More out of Our Sewage Sludge

Below are some of the highlights from this important, recent assessment of land disposed Sewer Sludge - in the end, the conclusion these independent professors come to is simple: “ We do not advocate the continuation of land application”

Professors - Jordan Peccia*† and Paul Westerhoff‡

† Department of Chemical and Environmental Engineering, Yale University, Mason Laboratory, 9 Hillhouse Avenue, P.O. Box 208286, New Haven, Connecticut 06520, United States ‡ School of Sustainable Engineering and The Built Environment, Arizona State University, Box 3005, Tempe, Arizona 85287-3005, United States - Environ. Sci. Technol., 2015, 49 (14), pp 8271–8276 DOI: 10.1021/acs.est.5b01931 Publication Date (Web): June 24, 2015 Copyright © 2015 American Chemical Society

Hazardous Chemical and Pathogen Content

Words that start with the letters “slu” do not usually connote something with a positive public image. Sewage sludge is no exception. Sludge is a record of what society excretes. This includes any pathogen that is contained in human feces, urine, and vomitus. A recent study found more than 27 different forms of human viruses in the sewage sludges of five large U.S. cities, ranging from Adenovirus to Corona virus to HIV.(1) Antibiotic resistant bacteria and antibiotic resistance genes are common in wastewater and biosolids.(2, 3) Stabilization is meant to reduce this pathogen load, usually by 1–2 orders of magnitude for class B treatments. Microbial risk analyses, which have typically shown limited risk to residents for Salmonella spp. and Enterovirus(4) have recently suggested significantly increased risk of infection due to emerging viruses such as Norovirus.(6) Metals and organic chemicals that resist biological mineralization can sorb to solid particles and also accumulate in sludge. These include polybrominated flame retardants, pharmaceuticals like Prozac and Tagamet, human hormones such as estrogen, antibiotics, narcotics including cocaine, and the metabolites of these compounds.(8, 9) Class B land application can include spreading tons of sludge per acre of land, producing a strong odor and attracting disease vectors. The chemical and microbial content and sludge odor are important drivers to the public resistance to land application.(10) Land application disputes are a large source of litigation and hundreds of human health complaints from residents living near land application sites have been logged.(11) More so than regulations, costs, or environmental concerns, those that manage biosolids land application programs cite concerns from neighbors, environmental groups, and others as the top pressures on their programs.(7)

Converting Infrastructure to Extract Value from Sludge

Sludge is the receptor of wastewater’s contaminants. It may not ever be feasible to treat the product to a level that contains no pathogens, no toxins, no hazardous chemicals, and no odors, and can be spread back into the environment with no public objections. Based on the above analysis, the more economical, socially acceptable, and environmentally sustainable approach may be to exploit sewage sludges for metals, nutrients, and energy.

Energy Recovery

One approach capable of achieving several treatment and recovery goals for biosolids would be combustion-based technologies associated with incineration, gasification or liquifaction. Combustion can destroy pathogens and mineralize persistent organic chemical contaminants, while producing energy and concentrating valuable metals and inorganic chemicals.

Conclusions: We Should Expect More

Sludge management is a central component of water quality engineering. Regardless of the approach to treating wastewater, primary and secondary sludge will be produced. A future that is concerned with economics, water usage, energy conservation, beneficial reuse, recycling and environmental health will demand more of sewage sludge. We do not advocate the continuation of land application, as it has limited social and economic sustainability

The whole paper can be read here - http://pubs.acs.org/doi/full/10.102...

Dr. Richard Honour reflects on TSS (Toxic Sewer Sludge) after the "Biosolids" Forum in BC

Land-Disposed Toxic Sewage Sludge:            The Great Public Health Hazard Cover-Up

It’s a scary world out there, and even scarier now with the current global explosions... of cancer and infectious diseases, two self-imposed global public health hazards that recognize no borders or demographic boundaries.

A quick investigation of the world’s view on what may be the greatest public health hazards of our time reveals some ignored or otherwise missing dangers. Health agencies worldwide reveal new information on toxics, but lo and behold, with no mention of Toxic Sewage Sludge as a considerable, universal and inescapable hazard to public health.

The literature is filled with messages of risk, threat and harm (aka, death) associated with anything nuclear or radiological, or about cigarettes, opioid drugs or terrorists, or about industrial, medical or household toxics on a one-by-one basis, but little is presented about the obscure but pervasive killer known as Toxic Sewage Sludge, and even less about the on-going planned and intended route to constant human exposure via Land-Disposed Toxic Sewage Sludge.

More amazing is that government agencies, academic institutions and industry lobbyists (biosolids management associations and sludge disposal firms, as examples) continue to promote broad-scale contamination of our air, soil, food and water with Toxic Sewage Sludge, under a variety of product names, supposedly ‘treated’ by any of several methods promoted to render such toxics as being ‘safe’ or ‘in compliance.’ To them, human life has little value, while the value they ascribe to the sludge disposal industry is based on the value they place on their own selfish and personal interests.

Odd thing is, not one of them has ever performed a safety/toxicology test on a single sample of Toxic Sewage Sludge, so who guides and permits their behavior, and who then will be held personally liable for the resulting harm, injury and death? Their days of hiding are numbered.

Are we missing something, or are we are letting something sinister go by unnoticed, perhaps by plan and intent? Not necessarily so.

At a most excellent conference last week in Kamloops (Interior Scientific Forum on Biosolids, Thompson Rivers University, Kamloops, BC, Canada) multiple speakers presented lists and charts of hundreds (illustrative examples of thousands) of chemicals and infectious agents known to be in any and all Toxic Sewage Sludges, and at the same time we were presented with other lists of toxics known to be carcinogens, among their other adverse toxic characteristics. Curiously, when superimposed, the lists are nearly the same; the toxics known to be contained in Land-Disposed Toxic Sewage Sludge are generally the same toxics that cause cancer and so many other chronic diseases, with little exception.

The sources of the toxics are common municipal, medical and industrial sewage sludge, plus the leachates from solid waste landfills and stormwater runoff - the most toxic sources of all. While all of it is subjected to some superficial processing to achieve marginal or questionable compliance, none of it is treated to achieve Safety - none! Matters of Public Health and Safety, and of Human and Environmental Health, garner no appreciation in matters of the disposal of Toxic Sewage Sludge.

It is a criminal act to dispose of Toxic Sewage Sludge in our forests, farms, rangelands, foods, air and waters when the Safety (antonym of Toxicity) of the thousands of chemicals and pathogens in Toxic Sewage Sludge has never been tested or assured. No one has shown that individually or in combination (or through the near-infinite permutations of the combinations of toxics) that Toxic Sewage Sludge-borne toxics do not present risk or threat of harm to human or environmental health, meaning that such toxics must therefore be safe, a bold contradiction in terms, for sure.

Simply by invoking the Null Hypothesis, i.e., that Sewage Sludge is Toxic, it would be revealed (by validated toxicological testing methods) that if all possible tests are performed to show that Sewage Sludge is Toxic, but if said toxicity were not observed, then the Null Hypothesis would be rejected, and Sewage Sludge would be determined to be non-toxic (or Safe). Absent such testing, it must be concluded that Toxic Sewage Sludge is Toxic, and it must be asserted well that any person who produces, transports, spreads, promotes, authorizes or allows the Land Disposal of Toxic Sewage Sludge must be held criminally liable and personally responsible for any resulting injury or harm, near- or long-term, no matter the reason or cause for such toxic waste disposal.
Toxic Sewage Sludge is Toxic Waste.

There are alternatives for the proper treatment of Toxic Sewage Sludge, which are not only clear, but could represent a profit to the Toxic Sewage Sludge disposers. Thermal Conversion by any of several advanced technologies and methods, such as by gasification, as one example, easily converts Toxic Sewage Sludge into heat energy, yielding syngas for fuel, plus valuable ash and biochar for beneficial reuse, and then an absence of Toxic Sewage Sludge that inevitably kills us all. There are available alternatives, yet we watch the death rate climb, while such alternatives are being contemplated.

We cherish our forests, rangelands, wetlands, air, food and waters, which give us sustenance and peace, and now they are violated, for no good cause or reason. It is time to abolish all land disposal of Toxic Sewage Sludge.

Richard Honour, February, 2017.

An Overview of the Dangers of Sewer sludge (Biosolids) by Thomas Maler, Ph.D.

Application of Sewage Biosolids on Land

The 2004 National Water Quality Inventory by the US EPA reported that 44 % of surveyed rivers and streams were impaired by pathogens and organic enrichment, and the top source of these impairments was from runoff from agriculture activities. In addition, 30 % of surveyed bays and estuaries were considered impaired by pathogens and organic enrichment, with municipal discharges/sewage listed among the top three sources of the impairment (US EPA, National Water Quality Inventory Report to Congress, 2004 Reporting Cycle, Jan. 2009). Also in 2004 approximately 60 % of total “biosolids” produced in the US were applied to land, (NEBRA, A National Biosolids Regulation, Quality, End use and Disposal Survey—Preliminary Report, April 14, 2007). Since 2004 more stringent effluent discharge requirements and sewage treatment plant upgrades have resulted in significant increases of sludge production and hence the need to dispose of it in an acceptable manner. Public doubts regarding the efficacy and safety of land application have been supported by scientific research that indicates commercial chemicals, pharmaceuticals, personal care products, engineered nanoparticles and innumerable contaminants of emerging concern (COEC) are having a greater impact on the environment and public health than previously assumed (Abstracts of Presentations, “Environmental Protection in a Multi-Stressed World: Challenges for Science, Industry and Regulators,” 25^th Annual Meeting of SETAC, 2015, Barcelona). Further studies and alternative methods of extracting and processing the components of sewage and disposing of the sludge are required. There is potential for reducing the life cycle costs of sewage treatment plants, recovering energy and destroying or immobilizing harmful components instead of being applied to land, (Biosolids Management Strategies: An Evaluation Of Energy Production As An Alternative To Land Application, Environmental Science and Pollution Research International, Jul 2013).

Composition of sludge/biosolids.

Sewage sludge, when treated in an anaerobic digester or further treated with heat or alkali is now called biosolids in order to make it sound more acceptable for “beneficial” uses such as spreading on farmland. The sludge/biosolids contains nutrients useable for plant growth, however they also contain in addition to human and animal wastes, 30,000 or more different toxic chemicals from pharmaceuticals, hospital, household and industrial waste, bacterial, viral and other parasitic biological pathogens, multi-drug resistant bacterial/Superbugs and prions, heavy metals, micro-plastics and micro-fibres. One class of these thousands of chemicals in sludge/biosolids is called PPCPs or Pharmaceuticals and Personal Care Products and these compounds are taken up by plants in hundreds of micrograms per kg of plant tissue and nothing is known about the effect of this on the plants and on the animals that consume them including humans. The uptake and metabolism of these thousands of different compounds varies greatly with their composition. (M. Bartrons, J. Peñuelas, TRPLSC 1514, 12, 2016, p.10).

Health Effects

Damage to DNA from environmental chemicals is likely a major cause of cancer, birth defects, and this uptake may contribute to heart disease and other health effects. Genetic defects get carried over to future generations; exposure to mutagens is from natural sources but increasingly from synthetic chemicals such as industrial chemicals, pesticides, hair dyes, cosmetics and pharmaceuticals, (Bruce N. Ames, Dept. of Biochemistry, UC Berkley).

When substances have a similar mode of action, their concentrations can be added together to predict their combined effect. This includes concentrations below levels of concern and the toxicity effect is larger than the sum of the components. Although antagonistic and synergistic effects occur, the additive effect of toxicity is generally what occurs (Environmental Toxicology and Chemistry, Dick de Zwart and Leo Posthuma, Vol 24, Issue 10, Pg 2397-2713 – Modeling of single and multiple chemicals in the environment).

Environmental oestrogens in wastewater treatment effluent are well established as the primary cause of reproductive disruption in wild fish populations but their possible role in wider effects of effluents is under study. Filby et al, revealed a clear link between oestrogen in effluent and diverse, adverse and sex-related health impacts on resident fish species, (Environmental Health Perspectives, Vol. 115, No. 12, Health impacts of oestrogen in the environment, considering complex mixture effects, December 2007, Amy L. Filby, Teresa Neupath, et al).

What happens to the contaminants in the sludge/biosolids?

If governments continue to allow the application of 30,000+ chemicals and PPCPs and many countless biological pathogens on the land, they should prove beyond any reasonable doubt that these contaminants are either removed from the sludge/biosolids before land application or will be destroyed when applied on the land. However, the proof is simply not there. This is a herculean task, it will be impossible to measure the concentration and the rate of removal or the decomposition of 30,000+ chemicals applied on the land. The technology does not exist to measure these thousands and thousands of chemicals and the cost of doing so even if it were possible would be prohibitive. Even though endogenous soil bacteria can probably degrade a small number of chemicals in the sludge, the metabolic pathways to degrade and destroy 30,000+ synthetic chemicals that did not exist in the past, do not exist. A certain amount of these thousands of chemicals will be water soluble and with other small particles including microplastics they will get washed away with the rains and will end up in the streams, rivers and the ocean or will contaminate aquifers. Effluent discharges have been expressed as the mode for contamination that is reputed to play a role in the formation of “dead” zones or oxygen depleted “hypoxic” zones in lakes and the near shore oceans around the world (Scientific American, 2008; National Ocean Service, US Dept. of Commerce, 2010). The oceans are exploding with dead zones (Business Insider, June 26, 2013), and the zones appear to be increasing in size over time.

Clearly, there are toxic chemicals in sewage sludge.

We also do not know anything about what other toxins can form from a 30,000+ chemical soup when sludge is being treated/turned into biosolids. Furthermore, nothing is known about what synergistic effects this chemical cocktail will exhibit when applied on the land. Another unknown is what effect the many antibiotics present in the sludge/biosolids will play on the plant microbiota or on the microbiota of the animals that live on the land where the sludge/biosolids get applied. Both endogenous bacteria as well as mycorrhizal fungi play a crucial role in the growth of plants and trees and altering this microbiome with antibiotics present in the sludge/biosolids can easily negate its nutritional benefits.

Biological Pathogens

Sewage sludge/biosolids also contains largely an unknown number of bacterial and viral pathogenic organisms, protozoan and other parasites and even prions. What is often never discussed in the pro-sludge and biosolids literature is the fact that ALL sewage treatment plants in the world, including all secondary and tertiary treatment plants breed Superbugs or multi-drug resistant bacteria, (Y. Luo et al, Environmental Sci. Technol. Lett. 2014, 1, 26-30; A. McGlashen, Sci.Am. 2017, 01/18.) The reason is simply the fact that antibiotics end up in sewage and during the treatment process with bacteria, the bacteria that acquire antibiotic resistance will get selected in the presence of antibiotics in the sewage. However, the level of treatment (secondary or tertiary) will affect the degree of ocean protection from the contaminants in the sludge. The sludge is simply settled out in secondary treatment and the effluent which is too dirty to be reused typically gets pumped to a receiving environment, such as, a river, lake or into the ocean. However, in tertiary treatment, the sludge gets filtered from the water with 0.04 micron membranes and this step will remove not only the bacteria, but also the source of the bacterial multi-drug resistance or Superbugs, the plasmids. Plasmids are small circles of DNA which contain the genes for the drug resistance and can confer the resistance not only to same species bacteria, but also to unrelated bacteria such as the endogenous soil bacteria. These small circles of DNA called plasmids can survive outside of the bacteria either in water or can even survive for hundreds or possibly even thousands of years in a completely dry state. Plasmid DNA has even survived on the surface of a rocket shot into space and the heat of re-entry into atmosphere, (D.F. Maron, Sci. Am. Nov. 26, 2014). So it is totally unrealistic to hope that Superbug DNA will somehow magically disappear if we let the sludge sit on the land for a few months. The addition of 5-10 or larger micron size disc filters suggested to improve the quality of the effluent instead of the 0.04 micron membrane filters used in real tertiary sewage systems will do nothing for the environmental protection because it will NOT filter out plasmids or anything else smaller than the pore size of such filters.

Fraser Health has repeatedly found cases of the deadly CRE (Carbapenem Resistant Enterococci) in BC Hospitals, however CBC has reported (CBC News, Jan. 30, 2017) that many other hospitals in other provinces are silent on these outbreaks and that there were apparently 160 cases of CRE outbreaks between 2010 and 2012 (Public Health Agency of Canada). These and other Superbugs make their way into the sewage treatment Plants from the hospitals, homes and industrial facilities and so it makes sense that we should not spread them or plasmids containing the genes for this resistance on the land where they can further contaminate and multiply their resistance genes.

Micro-plastic and micro-fibres

Sewage contains micro-plastics from a variety of cosmetic products and micro-fibres that are released into waste water from laundry and industrial processes. These microscopic plastics will remain on the land or be washed from the land into streams, rivers and into lakes and the ocean where they will do their environmental damage. A recent study by the International Maritime Organization, the UN Organization responsible for preventing marine pollution, and carried in

Science and Technology Journal and also reported by CBC, posted to their web site on January 17, 2017 indicates that microplastics are now found in supermarket fish and shellfish. They have infiltrated every level of the food chain in both the marine and fresh water habitats and now we are seeing them come back to us on our dinner plates, (Chelsea Rochman, University of Toronto, 2017). These materials not only enter the gut but also their tissue says Peter Wells, senior research fellow at International Ocean Institute, Dalhousie University. He goes on to say, it’s not only the micro-plastics but the myriad of chemicals that come with them, chemicals such as PCB’s, pesticides, flame retardants and hormone disrupting compounds of many kinds. Although micro-plastics come from many sources and are known to carry chemicals of emerging concern, it behooves us to eliminate sources where possible, including the land application of sewage biosolids.

Micro-plastics are found at an alarming level in Canadian Lakes, Science and Technology Journal, and also reported by CBC, January 2017. They are a concern in lakes worldwide and they are often found at alarming levels says Anthony Ricciardi, professor at McGill School of the Environment. Their source is often municipal coming from the washing of clothes but also from industrial sources and are found at 43,000 plastic particles per square kilometer which jumps to 466,000 near cities around the Great Lakes.

No one wants to eat fish that contains non biodegradable plastics including the many toxins absorbed to these plastics, so it makes sense not to spread them onto land in sludge/biosolids in order to stop further contamination of both the land and the waters.

Micro-plastics are synthetic polymers and cannot be broken down by microorganism no matter how long they will sit on the land or in the ocean. They will survive for many hundreds of years without any noticeable degradation and are eaten by fish, plankton and other marine and fresh water animals, (M.L. Taylor et al, Scientific Reports 6, Article number: 33997 (2016). As noted, the actual toxicity of the micro-plastics themselves is also increased by absorption of toxic chemicals onto their surface. These polymers can't be broken down/metabolized by any creature that ingests them and so if they are loaded by absorbed toxins, they become even more lethal, (M.A.Browne et al. Current Biology, 2013; 23 (23): 2388).

The indefinite Problem

Tens of thousands of these components will contaminate the land for decades and perhaps hundreds if not thousands of years once they are applied on the land and there simply is nothing one can do to decontaminate such land. Furthermore, the tests that would determine the extend to which these toxins will be taken up by the plants or animals we consume simply do not exist, with 30,000 different synthetic, man-made chemicals it is unrealistic and impossible to measure the fate of these chemicals once they are applied on the land. The same goes for the vast majority of biological pathogens like Superbugs that will be spread on the land with the sludge. Once micro plastics from sludge are applied on the land, they will contaminate the land for hundreds of years or waterways if they get washed away by rain. Once it’s applied on the land, it will either stay there or will end up in the rivers, lakes or the ocean - the genie cannot be put back into the bottle once it gets out so the best solution is not to apply this toxic mixture on the land in the first place.

What do we do with it these sludge toxins? How do we safely dispose of this sludge/biosolids?

The wastewater industry currently has a preference to treat sewage sludge and turn it into a material called “biosolids,” a marketing term developed to make it more appealing to farmers to encourage spreading it on the land. It represents a relatively inexpensive way to dispose of the sewage biosolids. Sewage sludge treated in an anaerobic digester converts approximately half of its carbon into biomethane, however, the problem remains what to do with the remaining 50% of the solid residuals. There are risks associated with anaerobic digesters, they are known to explode, thus the reason they are not installed in built-up residential areas.

Thermal conversion is also an option for sewage biosolids disposal, with a remaining issue on how to safely dispose of the ash should it contain potential heavy metal issues. There are two types of thermal conversion, firstly, incineration which has been rejected in many jurisdictions because of the large volumes of air pollutants released during the process; and secondly, gasification which reforms (or manufactures) the sewage biosolids into synthesis gas (syngas) and does not have the massive air pollution issues of an incinerator. In advanced gasifier systems there are no direct air emissions at all. Small gasification systems, suitable for the disposal of sewage biosolids, have only recently been developed having started in Europe in the mid 1990’s. These first generation systems have given way to further development into second and third generation systems which are much more reliable, stable and efficient than the earlier systems. The Advanced gasifiers can handle either dewatered raw sewage sludge or dewatered treated biosolids from a digester, the only difference being higher syngas production from the raw sludge. Due to their size compared to anaerobic digesters and municipal incinerators they are much more cost effective and require far lower operating costs as well.

Lessons learned

K. Noguera-Oviedo and D. S. Aga (J. of Hazardous Materials, 316 (2016) 242-251) reported on the lessons learned from more than two decades of research on emerging contaminants in the environment. Just like the exponential growth of research papers published on the topic of Emerging Contaminants (ECs) in the period of 1995-2015, detection techniques have been vastly improved and the amount of data has also grown exponentially. Noguera-Oviedo and Aga identified five (5) lessons learned from research of the past 20 years and reported that these lesson matter now more than ever before.

Lesson 1: Emerging Contaminants have emerged worldwide in Waste Water Treatment Plants effluents and in surface water, drinking water and groundwater. The precautionary principle should be used in dealing with management options for this material.

Lesson 2: Treatment does not mean complete removal and application of the sludge on the land only exacerbates this problem.

Lesson 3: Metabolites and transformational products matter, meaning that during the treatment or after it, the mixing of thousands of these chemicals often forms new compounds that are more dangerous than those that they originated from. That’s the nature of chemical processes and unless we actually destroy the mix, new toxins will continue to emerge from the old ones, whether it is on the land or in streams, rivers, lakes or the ocean.

Lesson 4: Unconventional testing of the effects of toxicity are needed, because of the complex mixture of chemicals in the effluents and in the sludge. The simple testing done by the pharmaceutical industry while developing new drugs does not apply in this new world of toxic waste chemicals.

Lesson 5: Even the most advanced tools can miss the target. The exponential growth of scientific literature in detecting these compounds will not negate the need to prevent even further contamination of the environment by persistent ECs.

In conclusion, it seems obvious that application of sewage sludge/biosolids on the land is not the answer to dispose of these toxins and pathogens. Disposal of the sludge mixed with municipal solids waste or with wood chips in a gasifier is the only safe way to go because it completely destroys the toxic chemicals and pathogens. Not putting this toxic soup on the land is the only way of protecting our environment and that’s the primary reason for treating our sewage in the first place.

Experts from Cornell Waste Management Institute

Dr. Caroline Snyder’s, emertitus professor, Rochester Insttitute of Technology, written testimony to the PA House Demoncratic Policy Committee, Public Hearings on sewage sludge has been summarized as follows:

“Experts, including soil scientists at the internationally renowned Cornell Waste Management Institute, who have studied biosolids - since the 1970s - with hundreds of peer reviewed papers to their credit, oppose using biosolids and biosolids products on the land where we grow our food and forage. Additional research teams led by Hale, Lewis, Wing, as well as the National Academy of Sciences, and others have reported and documented serious health, environmental, and agricultural harm linked to land application. The damage from this pollutant-rich waste mixture is not just "potential;" it has already happened. It is a gross travesty to call this material "eco-friendly" or to claim that the process "sanitizes" the solids. In fact, standard methods to further process sludge to a so-called Class A product actually encourages the growth and proliferation of endotoxins, and superbugs, as the more vulnerable indicator pathogens are deactivated, which explains why a number of sludge-exposed neighbors suffer from MERSA infections and life threatening respiratory symptoms. With mounting scientific evidence that current regulations and policies do not protect human health, agriculture, or the environment, why are US and Canadian agencies still promoting this harmful practice? For the answer see http://www.sludgefacts.org/testimony_to_pa.pdf “

Land application is not "recycling"; it is simply transferring a complex mixture of toxic chemicals and pathogens from our large industrialized urban centers to arable farms; nor is the practice "strictly regulated." Current biosolids management is highly energy intensive using fossil fuel for processing and transportation, thus - actually adding greenhouse gas emissions (on top of all the pollution produced by hauling these materials all over). Finally, it is ludicrous to claim that using the nation's arable soils as a repository of persistent toxic chemicals, many of which bioaccumulate in the food chain, "enhances soil health".”

Thomas Maler, Ph.D. (chemistry, biochemistry, molecular biology) Victoria, BC