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 ( https://bit.ly/2usTXx6 ) 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"  (  https://bit.ly/39pgeLn ). 

Another Important new scientific study just came out on a related topic - "Pharmaceutical and Personal Care Products: From Wastewater Treatment into Agro-Food Systems"
( https://bit.ly/39jRJ1Q ) 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" ( https://bit.ly/31zzuD6 ). 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 - https://pubs.acs.org/doi/abs/10.1021/acs.est.8b07222?journalCode=esthag
2. Germination and growth issues after biosolids application - https://www.sciencedirect.com/science/article/pii/S0045653519306095

3. Grazing animals affected by biosolids pollutants - https://www.sciencedirect.com/science/article/pii/S0160412018317318

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" https://bit.ly/2Fc6ObP

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" https://bit.ly/2PRKdFk

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" https://bit.ly/2SXfLIQ

(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 - ( 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" )

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." (http://bit.ly/1sb2qOP)

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 - https://bit.ly/38d5H5t To see other new scientific studies on "biosolids" - go here - https://bit.ly/2Hb55kU To see more information around the faulty "risk assessment" practices (used by this government and the sludge industry) for "biosolids" - go here -  https://bit.ly/2H9zsbM To see what alternatives there are to land disposal of "biosolids" - go here - https://bit.ly/2H8MtSQ

What the Experts have to Say - Quotable Quotes on this Reckless Practice

"Biosolids" … the reality … without the PR spin … 

Prof. Murray McBride, Cornell University -  "Is it reasonable to conclude that there is little or no risk of land-applying a material (biosolids) containing unknown concentrations of thousands of chemicals with undetermined toxicities?" ... "Once contaminated, stopping the application of pollutants such as metals and many organic chemicals that are in sewage biosolids will not correct the problem. The contamination will remain for decades or centuries"


Prof. Jordan Peccia- Yale University - " biosolids contain heavy metals, hazardous organic chemicals, microbial pathogens, and antibiotic resistant bacteria ... polybrominated flame retardants, pharmaceuticals like Prozac and Tagamet, human hormones such as estrogen, antibiotics, narcotics"

Lidia Epp  (manager of  the Molecular Core Lab in the Biology Department of College of William and Mary in Williamsburg) "It is evident that the long term exposure to a host of the environmental pollutants is the foundation of many chronic conditions that are now at the epidemic levels. Rather than focusing narrowly on determination of specific sets of toxins present in biosolids from different sources – the research needs to shift to the epidemiological studies assessing the overall impact of complex mix of pollutants present in sludge."

Dr Andrew Singer (Microbiologist, Oxford) - "That sludge has e-coli in it,  plus antibiotics, plus biocides, plus metals - all of that breeds something called an antibiotic resistant bacteria. So as you are maybe rambling through a field that's been amended with this sludge, either last week or a year later, there is an elevated risk that you will - or your pet will - acquire this antibiotic resistant bacteria, carry it home with you, the dog licks you in the face, you have it. This is how it is transmitted. It is a rare event, but unfortunately rare events matter on a global scale, so you only need these rare events to happen once for it then to become important for the world.  So you’re effectively disseminating [in the environment] the very thing we should be trying to eliminate.”
Controlling the spread of antibiotic resistance was “one of the highest global priorities in the world,” he added. “There is virtually no higher priority than this, other than maybe climate change, and it is a seemingly routine occurrence that we are spreading this onto our land.”

Prof. Claudia Gunsch,  Duke University "As industry invents new materials and chemicals for modern products, many find their way to our skin and bloodstream and, subsequently, into our sinks and toilet bowls. More than 500 different organic chemicals have been identified in the biosolids used as fertilizer across the United States."

Dr. Sierra Rayne (microbiologist) - "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. As scientists, we have been watching the issue with increasing concern. 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. We cannot even say with any degree of confidence what the true range of contaminant risk is from the sludge ... 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."

Professor Alistair Boxall (University of York) , said sewage sludge contains "a real mixture of things ... It will contain microplastics, it will contain persistent organic pollutants, it will contain metals, it'll contain pharmaceuticals. We have no idea of how those work in combination to affect our health and also affect ecosystem health."

Brian Bienkowski (Scientific American - May 12, 2014) - "Sewage sludge used as fertilizer on farms can leave traces of prescription drugs and household chemicals deep in the soil, according to a new study by federal scientists. The findings suggest that the widespread use of biosolids could contaminate groundwater near farms with a variety of chemicals, including anti-depressants such as Prozac and hormone-disrupting compounds in antibacterial soaps ...The researchers looked for 57 “emerging” contaminants that are increasingly showing up in the environment. Ten were detected in the soil at depths between 7 and 50 inches 18 months after the treated sludge was applied. None was in the field’s soil beforehand... Other studies have found hormones, detergents, fragrances, drugs, disinfectants, and plasticizers in treated sludge used as fertilizer. But this is the first study to show how they can persist and move in soil."

Dr. Richard Honour (microbiologist) - ""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."

Laura Orlando (Boston University civil engineer)  believes a ban on land application is in order. “Everything we have that’s being manufactured in our society ends up in our sewer and it’s going to be in the sludge, so I think we should take land application out of the equation while we figure out what to do with it,” she said.

 Dr. Thomas Maler (biochemistry) -"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" 

Dr. Caroline Snyder  (emeritus professor, Rochester Institute of Technology) -  "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".”

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

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" https://bit.ly/2Fc6ObP

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" https://bit.ly/2PRKdFk

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" https://bit.ly/2SXfLIQ

Sewage Sludge and Soil Worm Populations ... NOT a Good Combination !!

Sewage Sludge (biosolids) and Soil WORM Populations - not a good combination! 

Time to stop using our agricultural soils as a sink for our cities' toxic sewage waste! 

1. https://bigthink.com/surprising-science/microplastics-soil
Highlights -

• New research from Anglia Ruskin University states that microplastics in soil are causing earthworms to lose weight.
• Soil affected by microplastics produces less crop yield due to less productive earthworms and lower pH levels.
• If this trend continues, our entire agricultural system could be compromised.

2. https://www.newsweek.com/microplastics-growth-worms-weight-study-1458887


3. https://pubs.acs.org/doi/full/10.1021/acs.est.9b01339  " The findings reported here imply that the pervasive microplastic contamination in soil may have consequences for plant performance and thus for agroecosystems and terrestrial biodiversity."

4. https://www.independent.co.uk/environment/microplastics-worm-growth-ecosystems-pollution-study-a9100866.html


5.  "Sewage sludge microplastics could pollute soil for thousands of years" https://bit.ly/2Sngwd2 "43% of microplastics that go down the drain eventually end up applied to agricultural land as biosolids."


6.   http://agris.fao.org/agris-search/search.do?recordID=US201900108222
 Highlights - 
"We investigated dissipation, earthworm and plant accumulation of organic contaminants in soil amended with three types of sewage sludge"
"This indicates that a chemical's short half-life in soil is no guarantee that it poses a minimal environmental risk, as even short term exposure may cause bioaccumulation and risks for chronic or even transgenerational effects."
"sewage sludge can present a potential risk for soil ecosystems and food webs, as a wide range of pollutants, organic and inorganic, enter water treatment facilities and end up in sewage sludge"
" there are no criteria taking into account the content of organic pollutants in sewage sludge"
"Organic pollutants may originate from detergents or other domestic chemicals, personal hygiene products, pharmaceuticals and a wide range of other products or wastes finding their way into the sewage system. Many of these organic pollutants are not degraded during waste water treatment processes, and reach soils where they may potentially cause harm to soil organisms … many of these chemicals are known or suspected endocrine disruptors
and may cause more chronic effects"
"The risk of adverse effects stems not only from their toxicity, but also from persistence and long-term exposure. High internal concentrations, as observed when organic pollutants bioaccumulate in organisms, can contribute to the environmental risk they may pose"
"The transfer of galaxolide and triclosan to earthworms was significant … . Although nonylphenol monoethoxylate rapidly dissipated in soil, it was still detected in earthworms three months after sludge application, suggesting that a chemical's short half-life in soil could still pose environmental risks." 

7. https://www.ceh.ac.uk/news-and-media/news/high-microplastic-levels-soil-can-halve-worm-fertility

December 2020 update - 

Impacts of polyethylene microplastics on bioavailability and toxicity of metals in soil

"MPs increased the bioavailability of metals in the soil and the toxic effects to earthworms. These findings provide insights regarding the impacts of MPs on the bioavailability of metals and the combined toxic effects of these two kinds of pollutants on terrestrial animals"

Impacts of polyethylene microplastics on bioavailability and toxicity of metals in soil - ScienceDirect

Sewage Sludge Management in Germany - A look at the recently published (2015) Overview

A few years ago (2015), Germany published a fascinating and frightening look at the sewage sludge situation. It is a wonderful guide to the present-day production, treatment and possible uses of this sludge.  Below I will present some of the more interesting and sobering findings in this German study. 

The entire document can be accessed here in English Translation -
Sewage Sludge Management in Germany



"Sewage sludge can be regarded as a multisubstance mixture. Because of the inhomogeneity and tremendous differences in the concentrations of its components, it is difficult to determine or define a standard composition for sewage sludge, which is mainly composed of organic substances. Sewage sludge (i. e. stabilized primary, secondary or tertiary sludge that occurs in a mixture at the end of the treatment process) contains plant nutrients such as nitrogen and phosphorous, as well as harmful substances such as pathogens, endocrine disrupters and heavy metals"

"Sewage sludge fertilizer is a pollution sink for harmful sewage components from households, businesses and diffuse sources, concerning whose environmental impact too little is known. The extent of the possible soil, plant, groundwater, and surface-water pollution resulting from these sources is difficult to determine, even in cases where relatively small amounts of sewage sludge are used ...  new breakdown products of pharmaceutical drugs are discovered in sewage sludge all the time. These breakdown products are incorporated into sewage sludge via human excretion and in other ways. It is simply not humanly possible for scientists to develop specific detection processes for and assess the environmental impact of all of these substances, whose combined impact is particularly difficult to characterize and assess. Scientists can merely estimate the theoretical hazards posed by these substances; and unfortunately, by the time the relevant hard facts become available, the pollutants in question will already have found their way into the biosphere."

"Owing to its extreme inhomogeneity, the quality of sewage sludge is difficult to characterize. Sewage sludge fertilizer contains the following elements, all of which are potential ecosystem pollutants: various organic substances that exert hormonal effects; various infectious agents; heavy metals; residues of pharmaceutical drugs."

"Sewage sludge fertilizer is also a pollution sink for harmful sewage components from households, businesses and diffuse sources, concerning whose environmental relevance too little is known. Notwithstanding tighter controls and stricter limit values for certain sewage sludge pollutants, uncontrolled pollutants such as hydrocarbons inevitably find their way into the soil. Incorporation of certain pollutants into the food chain cannot always be avoided, despite the fact that, for example, plants normally do not absorb organic pollutants. Nonetheless, new breakdown products of pharmaceutical drugs are discovered in sewage sludge all the time, and they are incorporated into sewage sludge via human excretion carried by the wastewater that is treated by sewage treatment plants." 

"In keeping with the precautionary principle and in light of the pollutants and pathogens found in sewage sludge, the UBA deems the agricultural use of sewage sludge to be a serious public health and environmental hazard and advocates that this practice be phased out."

New research looks pretty bad for biosolids -

New research looks pretty bad for biosolids -  Publications from just this past year 

1. Root uptake of toxins - https://pubs.acs.org/doi/abs/10.1021/acs.est.8b07222?journalCode=esthag

"Determination of nanoparticle uptake, distribution and characterization in plant root tissue after realistic long term exposure to sewage sludge"

"In the past 15 years, the use of nanoparticles (NP) in daily life and medical products has constantly increased.
As a consequence, NPs cause major concern as a potential contaminant of the environment, e.g. through waste water, deposition or precipitation. Furthermore, the uptake of NPs by agricultural plants is also relevant for
human exposure … our study proved that particle uptake in plant roots is an important issue also under realistic exposure conditions ... the presented data are relevant for human exposure by consumption of root crops."

2. Germination and growth issues after biosolids - https://www.sciencedirect.com/science/article/pii/S0045653519306095

"The application of agricultural sewage sludge alone results in a major input of plastic particles into agricultural soils, estimated to be between 63,000 and 430,000 and 44,000–300,000 tons per year of microplastics (<5 mm) in the EU and North-America farmlands, respectively"

"Seed germination rate was significantly reduced for all three sized plastics … This suggests that clogging of the pores with plastic particles might inhibit water uptake and thus delay germination. Given we observed increasingly pronounced effects with the increased size of the plastic, the delay in germination might be caused by physical blocking. We also observed a change in root growth after 24 h of exposure, with a decrease in root growth when exposed to 50 nm particles, and an increase when exposed to 500 nm plastic particles."

"To conclude, we present the first study on adsorption, uptake and the phytotoxicity of nano- and microplastics to a vascular terrestrial plant. The results from the present study demonstrate that plastics particles adsorb particularly on the root hairs. Exposure to plastic particles results in short-term and transient effects on germination rate and root growth. Given our limited understanding of the impact of nano- and microplastics in terrestrial systems, it is key to conduct studies on nano- and microplastics loads, uptake, and effects on terrestrial systems."

3. Grazing animals affected by biosolids pollutants - https://www.sciencedirect.com/science/article/pii/S0160412018317318 

"this study shows that chronic EC exposure, via sewage sludge, at concentrations and complexity relevant to humans, induces persistent xenotoxicant responses in the liver, disrupts a large portion of the observable liver proteome and affects lipid levels and the expression of liver cancer markers, all of which are likely to affect many body systems. Our observations support the existing data showing that low-level EC exposure is a significant contributor to abnormal liver physiology"

"Our results demonstrate that chronic exposure to ECs causes major physiological changes in the liver, likely to affect multiple systems in the body and which may predispose individuals to increased disease risks"
"The increased incidence of diseases, including metabolic syndrome and infertility, may be related to exposure to the mixture of chemicals, which are ubiquitous in the modern environment (environmental chemicals, ECs). Xeno-detoxification occurs within the liver which is also the source of many plasma proteins and growth factors and plays an important role in the regulation of homeostasis."

4. Problems with Chemical Mixtures in Low Dose (almost a perfect definition for "biosolids") - https://horizon-magazine.eu/article/chemical-mixtures-pose-underestimated-risk-human-health-say-scientists.html?fbclid=IwAR1IfkBrYyLrDwt-HboBcTVYzPieScWVboZoxrz_BCkhy9k8i_W9CVFZrTY

Two things of importance here in relation to sewage sludge / biosolids -
1. Biosolids / sewage sludge is one of the most "pollutant-rich" materials on earth - with tens of thousands of toxins contained within it … mostly in "small dose"
2. All regulations (EPA, or OMRR etc) base their "risk" assessments, and statements of "safety" on ONLY single pollutant toxicity measures - in other words on incomplete and out-of-date science.

5. Microplastics in Biosolids problematic - https://www.sciencedirect.com/science/article/pii/S004896971931366X?fbclid=IwAR10GiY8MppoSXErlmGecaEKxzgoOb0Zbu_8BaEmf8bqXSujgh_tgeIVl48

"Microplastics are emerging as a steadily increasing environmental threat … Treatment plants are essentially taking the microplastics out of the waste water and concentrating them in the sludge … Our results indicate that microplastic counts increase over time where successive sludge applications are performed. Microplastics observed in soil samples stress the relevance of sludge as a driver of soil microplastic contamination."

6. Microplastics Can Change Soil Properties and Affect Plant Performance -
https://pubs.acs.org/doi/abs/10.1021/acs.est.9b01339? fbclid=IwAR3PJRQeLEPA3vj8h5JDGkb_KlhMLPNBX_7DbEjVZRHu0zXHcKYwBMJKrcA&journalCode=esthag

"PES is the most commonly reported type of environmental microplastic, including its presence in sewage sludge used as an agricultural amendment … pervasive microplastic contamination may have consequences for agroecosystems and general terrestrial biodiversity." 

7. Spreading Sewage Sludge / "biosolids" MEANS spreading Antimicrobial Resistance - https://www.mdpi.com/books/pdfview/book/1273

"It was reported that almost half of all antibiotics were released in rivers through wastewater effluents and the practice of manure and sludge land spreading"

"There are various sources of antibiotics in the aquatic environment. Wastewater from residential facilitates, hospitals, animal husbandry and the pharmaceutical industry is considered as the main source of antibiotics. The antibiotics taken by humans or animals cannot be fully metabolized, and consequently enter sewage or manure via excreted urine or feces. Since antibiotics can only be partially removed in wastewater treatment plants, the antibiotic residues will be discharged into the aquatic environment. Other important sources of antibiotics in the environment include the manure and sludge used in agricultural sites, as well as discarded pharmaceuticals, sludge and solid waste of the pharmaceutical industry in landfills "

"It is notable that the antibiotics were found in surface water and groundwater which serve as drinking sources. This gives rise to the concern that antibiotics may occur in drinking water and threaten human health. After all, the conventional drinking water treatment processes were proved not to be effective in removing all antibiotics"

8. "Endocrine disruptors and carcinogens in the plastics can leak out and adversely affect soil." 
https://www.food.news/2019-03-12-microplastics-are-invading-our-farm-lands.html? fbclid=IwAR3mGHmGJDsZA9q_7ICQEXj3xOUBYT-E5IvLferb6MBkr5OM6bDGW_EKBAY

"Swedish University of Agricultural Sciences Associate Professor Martyn Futter told Australia’s ABC that people are failing to consider what happens to these biosolids after they’re used on land. He said that the endocrine disruptors and carcinogens in the plastics can leak out and adversely affect soil."

9. More microplastic issues - https://www.sciencedirect.com/science/article/pii/S0160412018327752?fbclid=IwAR1-OHw64DFfQC9U4fmhYvI9yRW5ya_igXJUVAQmKF9AyAQ6vKtOlVq-6IE

" The findings of this study indicate that the behavior of plastic particles in the soil not only disrupts the movement of springtails but also has wider implications for effective management of soils."

"In this study, we investigated the responses of soil-dwelling organisms (springtails) to soils contaminated with various particulate plastics. The springtails showed lower mobility in plastic-contaminated soils. Springtail behaviors were associated with the fate of plastic particles in the soil pores, and we observed that, in turn, plastic particles showed certain patterns of mobility in response to springtail behavior."

10.  Pharmaceuticals discharge in the environment via the excretion of pharmaceuticals by humans  http://europa.eu/rapid/press-release_MEMO-19-1598_en.htm

" the largest source of pharmaceuticals discharge in the environment is the excretion of pharmaceuticals by humans and animals, estimated to be about 90% of total emissions. These emissions enter the environment mainly via urban wastewater, sewage sludge, and manure."

11. Microplastics on land -
https://greennews.ie/growing-evidence-microplastics-food-chain/? fbclid=IwAR1niUW9svrjpPkeZ8qXh27vmbknQnULWuO2joIjCEQ11WFkvu0kzrTlOjw

"The European Chemicals Agency (ECHA) recently found that concentrated levels of microplastics are more likely to be found in sewage sludge applied as fertiliser than in our oceans."

12. Microplastic Problems -  https://www.endsreport.com/article/1528656/sewage-sludge-microplastics-pollute-soil-for-thousands-years?fbclid=IwAR26UntqNz780ckVtxxBeM194Kcq1Irbhg_1QmhQJxbQUOJ-vNzQ-JsrqOo

“We have identified diverse sources of microplastics to the environment from ‘intentional uses’ in cosmetics, detergents, other household products, paints, and agricultural uses, amongst others. Many of these microplastics are washed down the drain at the point of use and because of how wastewater in the EU is treated, these microplastics will not typically be released directly to aquatic environments, but are likely to concentrate in sewage sludge that is then frequently applied to agricultural soils as a fertiliser,” he said.
The agency estimates that 43% of microplastics that go down the drain eventually end up applied to agricultural land as biosolids.
Microplastics are also an ingredient in some fertilisers and plant protection products, Simpson added, exacerbating the problem. Their extreme persistence, with half-lives put in the thousands of years, means that “we currently cannot assess the risks to the environment resulting from such long-term accumulation and exposure.”
In January, the European Commission asked ECHA to consider whether an EU-wide restriction on intentionally-added microplastics would be justified. This would go far beyond a ban on them in wash-off personal care products, which is now in force across the UK. The US, France, Italy and Sweden have similar bans in place, while the EU cosmetics industry has undertaken voluntary measures."

13. EPA can no longer assure public that "biosolids" are safe - https://www.epa.gov/sites/production/files/2018-11/documents/_epaoig_20181115-19-p-0002_glance.pdf

"The EPA’s website, public documents and biosolids labels do not explain the full spectrum of pollutants in biosolids and the uncertainty regarding their safety. Consequently, the biosolids program is at risk of not achieving its goal to protect public health and the environment."

"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. The EPA identified these pollutants in a variety of studies from 1989 through 2015. Our analysis determined that the 352 pollutants include 61 designated as acutely hazardous, hazardous or priority pollutants in other programs"

14. New publication from Germany highlights problems with Antibiotic Resistance and how it relates to Sewage Sludge applied to soils - 
https://www.umweltbundesamt.de/en/publikationen/antibiotics-antibiotic-resistances-in-the?fbclid=IwAR2EygB1NiIlpBFPUZSpNdGQrZa6QFpp4KToinwFFORFIq59MZFIlEq3BqA

"If sewage sludge from waste water treatment plants is applied to soil, active substances can find their way onto fields and meadows. Antibiotics can also enter the groundwater from rivers, lakes and streams or via the soil"

"It is evident that waste water from hospitals and waste water treatment plants can contain high concentrations of antibiotics. In addition, many antibiotic substances accumulate in the sewage sludge, which is a pollutant sink in the waste water treatment plant"

"Sewage sludge is a reservoir for ARB and ARG. High bacterial densities and sufficient nutrient contents provide the ideal conditions for the adaptation of bacteria through horizontal gene transfer processes. In particular, substances with a selective impact such as antibiotics, but also heavy metals for example, bring growth benefits for resistant bacteria and therefore support the dissemination of ARG. The storage conditions of sewage sludge as well as the high nutrient content and high bacterial density also support the propagation of these resistant bacteria. When used as fertilizers, both the antibiotic residues and ARB reach the soil, thus ARB can be directly spread further in the environment"

"A study by UBA examined the occurrence of resistance genes in the case of the presence of different antibiotics as a consequence of the use of sewage sludge in agriculture and the horizontal dissemination of these ARG. The results show that the spreading of sewage sludge leads to a significant increase of ARG in the soil, and that these ARG can be proven to exist in the soil over an extended period of time. It is also possible for multi-resistant soil bacteria to be transferred to potential pathogens."

15. More on  Antibiotic Resistance & Sewage Sludge https://nyaspubs.onlinelibrary.wiley.com/doi/full/10.1111/nyas.14036?fbclid=IwAR2Gv9FmV5MOgxYg-qecbNT6zEW8lVun6f-hzvnVYScXhcGCnw67Hyk-zYw

"Complexities in understanding antimicrobial resistance across domesticated animal, human, and environmental systems"

"growing data suggest that ARB and ARGs may be dispersed by wild birds after exposure to sewage near rivers, spreading of sewage sludge onto farmland" 

16. More on Microplastics and Sewage Sludge -  https://www.ciel.org/wp-content/uploads/2019/02/Plastic-and-Health-The-Hidden-Costs-of-a-Plastic-Planet-February-2019.pdf?fbclid=IwAR3zD2EWwezWxzyQdD5RJvgssDf0SUMW3-i2rcSKper7W2Qoqr7tUDaPmkI

"The origin of microplastic particles is difficult to determine; they may come from environmental sources, including water, waste treatment sludge used as fertilizers, and processing and packaging ...Microplastics are resistant to degradation. Laboratory experiments have shown that micro- and nanoplastics can be transported from prey to predator and suggest that plastic-associated chemical additives and contaminants could also be passed through the food chain"
"Sewage entering municipal treatment systems is high in microfibers from textiles, microplastics from personal care products, and degradants of consumer products. Between 80 and 90 percent of microplastics entering treatment systems remain in residual sewage sludge.This sludge is often used as fertilizer in agriculture, resulting in plastic being deposited on agricultural fields where it can remain for long periods of time. To understand the significance of sewage sludge as a source of microplastic pollution, one study estimated that sewage sludge accounts for 63,000–43,000 and 44,000–300,000 tons of microplastics to be added annually to European and US farmland, respectively. Based on a recent study, microplastics can persist in soils for more than 100 years, due to low light and oxygen conditions"
"One health concern regarding plastic in soils is the potential transfer of toxic chemicals to crops and animals. The plastic industry is a major source of chemical additives reaching the environment. Some of these additives, including endocrine-disrupting chemicals such as phthalates, polybrominated diphenyl ether (PBDEs), and bisphenol A have been found in fresh vegetables and fruit"
" Earthworms that encounter polyurethane particles in soils can accumulate PBDEs. Earthworms are important to maintain healthy ecosystems and soils, particularly in agricultural regions. Worms aerate the soil through burrowing, process detritus, move the soil, and are a key food source for other animals. It is possible that PBDEs could be transferred in worms to other areas of soil and through the food web."