Washington State Senate Bill 5245 is meant to address PFAS (forever chemicals) in sewage sludge (aka biosolids) disposed of around the state on farm and forest soils, sold as fertilizer and commercial compost and even given away free by some cities to unsuspecting, low-income community gardeners. The thousands of PFAS manufactured chemicals are ingredients in various everyday products. They have been associated with impacting growth and development. reproduction, thyroid functions, the immune system, liver and an array of cancers.
While shining a spotlight on PFAS contamination of sewage sludge spread on land is important, SB 5245 is far from addressing the myriad of other problems related to this very toxic waste.
Sewage sludge can contain thousands of contaminants ranging from hazardous wastes, toxicants, pathogens, and thousands of unknown and unknowable toxic commercial products that enter wastewater processing plants and septic systems. For years, the Washington state legislature has promoted sewage sludge as “beneficial” for soils (RCW 70A.226.005). This is not and has never been true. Scientific research has shown that crops can uptake the contaminants and being in the vicinity of the waste can cause health issues.
Sewage sludge is NOT beneficial.
Legislators should expand 5245 to include the truth about sewage waste and its harms, and edit the bill to make it more protective of human health, wildlife, soils, crops, groundwater and natural resources.
SB 5245 is a step in the right direction. We need PFAS regulations. However, it needs to be a very low level because PFASs are cumulative and because the Legislature should not want to expose its constituents to what the State of Maine and elsewhere have experienced, costing private property owners their land, animals, and livelihood. The Environmental Working Group estimated that 20 million acres of farmland have been contaminated by PFAS through the land application of sewage sludge.
PFASs are hardly the only contaminants of concern.
• The bill should reflect the fact that there can be thousands of contaminants in the sewage sludge—toxicants, hazardous wastes and pathogens. Therefore, due to the amount, types and unknowns of this sewage mixture, the sewage waste cannot be beneficially used.
• The bill must recognize that the EPA’s 2009 targeted national sewage sludge sampling found 145 industrial chemical pollutants in every sample and that in 2018 EPA’s Office of Inspector General (OIG) identified 61 chemicals acutely hazardous, hazardous, or listed as hazardous in other EPA programs among the 352 chemical pollutants EPA identified in sewage sludge over the last 26 years and that the EPA does not have the resources to assess the health risk of the many contaminants.
• The Federal Clean Water Act defines sewage sludge as a pollutant. That’s because an unknown and unknowable number of chemicals are mixed and combined, resulting in a highly complex, unpredictable, biologically active combination of organic material containing human pathogens, microplastics, heavy metals, dioxins, industrial chemicals — including hundreds of carcinogens, mutagens, and hormone disrupting chemicals — pesticides, herbicides, pharmaceuticals, flame retardants, PCBs, and other persistent bio-accumulative toxins. SB 5245 must acknowledge this.
• Washingtonians deserve the state’s recognition in this bill that sewage sludge contains toxins known to be hazardous to the public health and therefore should never be applied to soils where crops are grown. Furthermore, natural ecosystems and wildlife must also be protected from these contaminants, so sludge shouldn’t be spread on forest soils either.
• Wastewater treatment plant owners must be encouraged and provided financial support to upgrade their processes to methods that do not generate “biosolids” as a byproduct that is spread on land.
• Ground water testing at sites where sewage sludge has been applied and nearby water bodies must occur regularly at the expense of the hauler and the lab results made public.
• Washingtonians also deserve a publicly accessible online map listing the locations of parcels where bulk biosolids have ever been approved for land application as well as the amounts and other data associated with those applications,
Below is a comment on SB 5245 sent to legislators by Morton Alexander, a founding member of Protect Mill Canyon Watershed.
More ‘forever chemicals’ found in WA drinking water as cleanup costs mount
(Seattle Times, Dec. 11, 2022)
“In Washington, public water systems with PFAS exceeding the state action levels range from Western Washington communities of Highline and Issaquah to the city of Airway Heights at the eastern edge of the state. The public water systems now grappling with this pollution collectively serve nearly 570,000 people, 7.4% of the state’s population, according to a Seattle Times analysis of test results.
“Now, a massive legal battle is playing out across the country as more than 200 providers of public drinking water … sue manufacturers, distributors and in some cases the Defense Department in federal court to determine who will pay the cleanup bills that will tally in the billions of dollars.”
Here is a comment on the article by protectmillcanyon.org:
We appreciate the Seattle Times looking into this water quality/public health crisis. Yet another instance of corporate malfeasance which unfortunately is ubiquitous across many sectors of the economy. Only in-depth investigative reporting can expose this kind of horrendous corporate wrong-doing, often accomplished with the collusion of the government regulatory agencies that should be looking out for the public’s interest. Hopefully such reporting starts the process of rectifying those many wrongs.
We must point out, however, a glaring omission in the reporting of this article: It fails to mention the role that “biosolids” plays in the widespread contamination of groundwater (and food, for that matter) with PFAS chemicals. Biosolids is an industry-/government-concocted euphemism for municipal sewage sludge which is routinely applied to farmland and forest land in WA (and most states in the Union). Biosolids are tested for an unbelievably small number of pollutants (nine heavy metals and nitrogen) even though the EPA, which sets the ground rules for the land application of biosolids, has itself “… identified 352 pollutants in biosolids. The EPA does not have complete risk assessment information on these pollutants; therefore the agency cannot say whether the pollutants are safe or unsafe when found in biosolids … [including] sixty-one designated as acutely hazardous, hazardous or priority pollutants in other [Federal] programs.” – Source: EPA Office of Inspector General 2018 Report.
Many scientists and ecologists attest that the number of unregulated pollutants present in biosolids is far higher.
Even though scientists and ecologists have organized for many years to end the practice of land application of biosolids, we are always met with the official response, in our case from the Department of Ecology that oversees biosolids application in our state, that all is well because the regulations say so.
Recently, a spate of reports from around the country (see below) have shined a spotlight on PFAS contamination of foods, farm soil, farm groundwater and the farmers themselves resulting from PFAS present in the sewage sludge that was used as fertilizer on the farms, sometimes over the span of decades. This has provided much needed public recognition of the biosolids problem, although organizers like me are frustrated that the reporting almost universally ignores the many other pollutants in sewage sludge that honestly no one in their right mind would allow to be dumped anywhere near our food supply or anywhere, for that matter, where they might contaminate air, water, wildlife and vegetation.
The Dept. of Ecology has recently released a “PFAS Action Plan” (also not mentioned in your article) which mentions sewage sludge/biosolids, but due to the fact that the state legislature has mandated that Ecology promote the use of biosolids as fertilizer, no meaningful action is recommended vis a vis biosolids in that plan and the spreading of pollution on our farms and forests continues unabated.
We urge reporters to look deeply into this aspect of the story needs investigating. One place to start is by looking at this website where we have collected quite a bit of information on the subject.
We also suggest that you contact Ed Kenny (firstname.lastname@example.org), a member of our group. On July 15, 2022, the Nisqually Delta Association, a non-profit organization composed of local citizens dedicated to the preservation and enhancement of the Nisqually Delta and the surrounding community, and Ed Kenney, a long-time activist and opponent of the use of municipal sewage sludge as “fertilizer”, filed an appeal of the Washington Department of Ecology’s approval and issuance of the Statewide General Permit for Biosolids Management and its associated State Environmental Policy Act (SEPA) determination of nonsignificance (which falsely declares that there are no significant threats to environmental quality from spreading sewage sludge on farmland and therefore absolves Ecology from conducting a formal environmental assessment of the practice).
We hope this message opens a new arena for members of the press to look into and might prompt expanded investigation into the issue.
Group Files Appeal Challenging Rules that Allow Toxic Sewage Sludge to be Dumped on Farmland in Washington
On July 15, 2022, the Nisqually Delta Association, a non-profit organization composed of local citizens dedicated to the preservation and enhancement of the Nisqually Delta and the surrounding community, and Ed Kenney, a long-time activist and opponent of the use of municipal sewage sludge as “fertilizer”, filed an appeal of the Washington Department of Ecology’s approval and issuance of the Statewide General Permit for Biosolids Management and its associated State Environmental Policy Act (SEPA) determination of non-significance (which falsely declares that there are no significant threats to environmental quality from spreading sewage sludge on farmland and therefore absolves Ecology from conducting a formal environmental assessment of the practice).
“Appellant Nisqually Delta Association (“NDA”), a non-profit organization composed of local citizens dedicated to the preservation and enhancement of the Nisqually Delta and the surrounding community, and Ed Kenney, (collectively “Appellant”), hereby provides notice of appeal of the Washington Department of Ecology’s (“Ecology”) approval and issuance of the Statewide General Permit for Biosolids Management (“Permit”) and its associated SEPA determination of non-significance, according to the direction set forth in WAC 371-08-340. A main concern of Appellant is that the General Permit fails to address the certain environmental and human health impacts of PFAS, PBDEs, and microplastics associated with land application of biosolids.”
This is a major development in the continuing effort to end the land-application of sewage sludge in WA. Please check back here for updates on this important case.
Read the Notice of Appeal.
To donate funds in support of this legal action, please send checks, made out to Nisqually Delta Association, to Wanda Hedrick, 400 17th Avenue SE, Olympia, Wa. 98501.
Tell the USDA: Municipal sewage sludge has NO PLACE in urban agriculture!
In January, Sally Brown of Washington state, a paid shill promoting the use of sewage sludge as “fertilizer,” was appointed to the USDA Urban Agriculture Advisory Committee. The only reason she would have been appointed to this post is with the intention on the part of the USDA to normalize the spreading of toxic municipal sewage sludge on urban agriculture operations. This is chillingly reminiscent of a recent plan hatched by King County in Washington state to “donate” sewage sludge to low-income community gardeners. This insanity must stop! Not only has sewage sludge recently been found to be contaminated with toxic “forever chemicals” in the PFAS family (fire-retardants, non-stick treatments, etc.), but it has been known for decades that sewage sludge is also laced with hundreds of industrial chemicals, pharmaceuticals, pathogens that survive sludge “treatment,” micro-plastics and more.
Tell the USDA: Municipal sewage sludge has NO PLACE in urban agriculture (or any agriculture for that matter). The USDA must PROHIBIT the use of sewage sludge in urban agriculture, not promote it.
The USDA Urban Agriculture Advisory Committee is now taking public comment. Members of the public who wish to submit comments or questions related to urban agriculture may submit them here:
Comments must be submitted by March 18, 2022.
The Washington State Department of Ecology hosted a public hearing on the proposed Statewide General Permit for Biosolids Management on June 22nd, 2021. Read an article from the Inland FoodWise Online Journal about that hearing:
65% Say ‘No More Sewage Sludge on Farmland’ in Comments to Department of Ecology
As of Feb. 1, 2022, Ecology has not issued their final report on the hearing in which they will be expected to respond to the comments that were submitted as well as issue the final wording of the permit.
It’s time to stop spreading sewage sludge on our farms.
Tell the USDA:
The Urban Agriculture Advisory Committee should NOT include a strident proponent of using sewage sludge in urban agriculture.
The 1987 Federal Clean Water Act reacted to pollution of waterways by promoting development of municipal sewage treatment plants.
In 1992, the Washington State legislature deemed “biosolids” (the non-liquid filth byproduct of those treatment plants before their effluent discharges into rivers) to be a beneficial resource and mandated that the Department of Ecology promote its use on soil. (Garbage out of the effluent, and garbage back in to our crops). This foolish mandate from the state, based on very outmoded science, if any at all, has made the Department of Ecology into an active promoter of pollution, rather than an independent regulator in the public interest.
A 2009 U.S. Environmental Protection Agency study concluded that all sewage sludge contains toxic and hazardous elements.
In 2018, the EPA’s Office of Inspector General concluded that they haven’t the means to prove “biosolids” safe.
Our main concern with a five-year re-authorization of how the Department of Ecology manages the program of land application of sewage sludge is that the material is host to an unknown amount of contaminants which constantly go down the drain in municipalities. They only test for nine heavy metals, nitrogen and selected pathogens. Unexamined are the many chemicals, micro-plastics, pharmaceuticals, and the infamous alphabet soup of ubiquitous super toxins now headed by PFAS (Per- and PolyFluoroAlkyl Substances).
Of course none of this matters to the Department of Ecology, which is in the grip of the waste and other polluting industries. Ecology staff is very aggressive in pursuit of their “partnership” (Ecology caseworker’s term) with one of the state’s main wholesalers of sludge, Fire Mountain Farms. FMF has been repeatedly slapped on the wrist by its partner, Ecology, for code violations like storing chemical wastes in the same piles of “biosolids” that it land spreads around the state. FMF intentionally created a “mixed” product to spread on agricultural fields that sometimes was comprised of as much as 15% of listed hazardous waste. A search of Ecology documents by Yelm-based Preserve the Commons found that much of it was flammable with large quantities of paint thinner.
Organic farmer Tim Pellow speaks to a 2017 combo demonstration and press conference organized by Protect Mill Canyon Watershed outside Spokane office of Department of Ecology.
In the case of the permit issued for the farmland neighboring Mill Canyon in Lincoln County, home to commercial organic food producers and a natural spring supplying many neighbors drinking water (directly downhill from one of the targeted wheat fields), the concern was about migration of toxins through flooding, wind storms and the fact (established by USDA soil maps) that most of the farmer’s land is classified as HEL, Highly Erodible Land. Fortunately, local citizens organized through Protect Mill Canyon Watershed to block that land application.
In many other such battles around Washington, “Biosolids” (the marketing name for the sewage sludge) is heavily pushed by Ecology as free fertilizer for farmers, and compost for gardeners. Read the labels of what you buy in the gardening stores. Ecology says “the draft permit streamlines some requirements, reducing the regulatory burden for the [biosolids industry] in the state.” This matches the complaint expressed (at a public meeting) by one of the officers of FMF that “there is too much paper work” while submitting blatantly inadequate and incorrect boiler plate for the required environmental analysis of the proposed Lincoln County site that was to be sludged.
Almost weekly, new studies come out around the world criticizing the practice of conditioning soil with sewage sludge as dangerous folly. Of course, it might seem futile to generate comments to the Department itself, rather than to a higher independent regulatory authority. Unfortunately, this is the system we are stuck in.
The Sierra Club has been helping organic farmers and small communities across Washington to resist contamination from nearby land applications or storage piles of sludge. We’d like to see Ecology replace “best management practice” with “independent current science” as a guideline. We call on the state to seriously research alternative methods of disposal such as pyrolysis, gasification or extraction of useful materials.
To view the critics’ side, please view a recent Sewage Waste Webinar on the Northwest Toxics Communities Coalition website: https://nwtoxiccommunities.
Stories of 3 local Washington State battles against contamination of farmland begin around the “25 minute” mark in the linked webinar above.
Please comment on the renewal of Ecology’s dirty business before the July 12 extended deadline.
Go here to Just Say No!
For more information or to comment by email or postal mail, please contact Emily Kijowski, Biosolids Technical Specialist, Department of Ecology, P.O. Box 47600, Olympia, WA 98504-7600, email email@example.com, phone 360-789-6592. Remember to identify the title of the document you are providing comments on: Statewide General Permit for Biosolids Management.
In 2017 we organized and successfully prevented sewage sludge from being spread on farmland adjacent to where we live. We want the state of Washington to stop allowing sewage sludge to be dumped on farmland.
Learn How You Can Organize a
Successful Anti-Sludge Campaign
In Your Community
Morton Alexander, Lead Organizer of the Protect Mill Canyon Watershed campaign, has put together a comprehensive “How To” manual for effective local grassroots organizing around ending the spreading of sewage sludge on farmland.
Protect Mill Canyon Organizer Morton Alexander
Four Delicious Limericks
About Sewage Sludge
by Chrys Ostrander
Truth is I carry a grudge
for a bureaucracy that refuses to budge.
They must stop the spread
where we grow all our bread
of that toxic concoction called sludge.
News flash! Here’s a real scoop.
They’re growing your food in our poop.
Mixed with pollution, it ain’t no solution.
Don’t want no sludge in my soup!
Mix municipal sewage with soil
Our farmland you’ll certainly spoil.
The crops will uptake the waste we all make,
It’s enough to make your blood boil.
We live in a toxic society,
But there’s one big impropriety.
What we put down the drain fertilizes our grain.
You’re not crazy if that gives you anxiety.
Updates and News
Producers Warned by EPA that PFAS Is Contaminating Pesticides and Food
March 29, 2022 – “Plastic storage barrels contaminated with polyfluoroalkyl substances (PFAS) may be in violation of the Toxic Substances Control Act (TSCA), according to an open letter released by the U.S. Environmental Protection Agency (EPA) last month. Manufacturers, producers, processors, distributors, users [ed. note: Users– that’s you!], and those that dispose of fluorinated High-Density Polyethylene (HDPE) containers or other similar plastics that form PFAS as a byproduct were notified …
…Advocates are encouraged to contact their elected representatives and urge them to take meaningful action to eliminate sources of PFAS in food, farming, and our environment …”
Sewage sludge spreading leads to farm groundwater PFAS contamination
April 12, 2020 – “…After seven out of 34 land application sites in Vermont were found to have PFAS levels above state groundwater standards, the state Department of Environmental Conservation is considering measures to prevent future contamination …
..Sludge and septage to be spread on fields must be treated to EPA standards to reduce pathogens and limit heavy metals, and are called “biosolids.” Critics have argued those standards do not address the thousands of chemicals that now show up in human waste, like pharmaceuticals and PFAS …”
Advisory warns of PFAS in beef from Michigan cattle farm
HARTLAND, MI — Officials warn that beef from a southeast Michigan cattle farm contains unsafe levels of toxic PFAS chemicals traced to the application of wastewater biosolids as fertilizer on fields used to grow feed crops.
On Friday, Jan. 28 2022, the Michigan health and agriculture departments issued a joint consumption advisory for beef from the Grostic Cattle Co., a century-old family farm near Hartland that sells directly to consumers and at farmers markets.
The Michigan Department of Health and Human Services (DHHS) believes that test samples indicated prolonged consumption of meat from the Grostic farm could pose a health risk…
“This contamination, however, makes clear that human exposure to PFAS from biosolids could be a significant pathway and we should therefore ban applying biosolids that contain PFAS to crops while we await further sampling and test results,” said Charlotte Jameson, chief policy officer for the Michigan Environmental Council.
The Michigan Department of Health and Human Services “determined that prolonged consumption of the beef from this farm could increase PFOS levels in the human body.”
Michigan last year banned land applications of industrial biosolids containing more than 150 parts per billion of PFOS and requires testing of biosolids before they are placed on land.
Testing found PFAS in cattle feed crops grown there, as well as in manure and soil. The farm provided frozen beef cuts for analysis this month at a U.S. Department of Agriculture lab, which measured an average PFOS level of 1.9 ppb.
Wisconsin State Farmer
Toxic ‘forever chemicals’ found in Michigan farm’s beef
Toxic ‘forever chemicals’ found in Livingston County farm’s beef
News Center Maine
More farms contaminated by PFAS chemicals
UNITY, Maine, Feb. 1, 2022 — State lawmakers in Augusta are considering an outright ban on the spreading of sludge in Maine, because of contamination from toxic chemicals known as PFAS.
The chemicals were in leftover sludge from wastewater treatment plants. For decades that sludge was hauled to farms across the state and used as fertilizer.
Johanna Davis and Adam Nordell own the Songbird Organic Farm in Unity. But the couple has stopped sales and pulled products from customer shelves following the discovery of high levels of PFAS in their water, soil, produce, and in their blood.
“The water that we drink and irrigate our crops with is over 400 times Maine’s safety threshold,” Davis said.
The farm posted a statement about halting sales on its website last week. The source of the contamination is believed to be wastewater sludge spread on the farm’s fields in the early 1990s.
If approved, the amendment would also prohibit the sale or distribution of compost that contains sludge. According to the DEP, there are four wastewater treatment plants and 11 composting facilities licensed to handle the material. The committee is expected to take up the amendment next week.
Maine’s ‘forever chemicals’ problem has now spread to chicken eggs
Bangor Daily News, Dec. 14, 2021
Last month the state issued a “do not eat” advisory for deer meat harvested in and around Fairfield due to unsafe levels of so-called forever chemicals found in the animals. Now testing data has shown levels of those chemicals in some chicken eggs from the same area.
Used in everything from non-stick pans to waterproof clothing, PFAS have been linked to a number of chronic illnesses in people, including cancer. Here in Maine, the chemicals are increasingly showing up in the food people grow, raise and hunt after sludge was spread on farm fields.
FAIRFIELD, MAINE – Nov. 23, 2021 —
Do not eat deer advisory issued for greater Fairfield, Maine area
Maine Department of Inland Fisheries and Wildlife, in conjunction with the Maine Center for Disease Control and Prevention (Maine CDC), has detected high levels of PFAS in some deer harvested in the greater Fairfield area and issued a do not eat advisory for deer harvested in the area.
This area (view map at the link below) encompasses multiple farm fields that have been contaminated by high levels of PFAS through the spreading of municipal and/or industrial sludge for fertilizer that contained PFAS. Deer feeding in these contaminated areas have ingested these chemicals, and now have PFAS in their organs and meat.
Poly-fluoroalkyl substances (PFAS) have been used for decades in a variety of household and consumer products, including non-stick cookware, carpet, waterproof clothing, and food packaging products such as pizza boxes and microwave popcorn bags. PFAS were also used in firefighting foams. Known as “forever chemicals” since they do not break down, PFAS persist in the environment and are transferred into soil, water, plants, and animals.
Hunters who have already harvested a deer in the area are advised not to eat the deer, and to dispose of the deer in their trash or landfill.
Maine Department of Inland Fisheries and Wildlife Website
Maine Department of Inland Fisheries and Wildlife Press Release
WASHINGTON, D.C. – May 25, 2021 — A new report released today found concerning levels of toxic PFAS (per- and polyfluoroalkyl substances) found in home garden fertilizer products widely sold throughout the United States. The report, based on testing conducted by the Sierra Club and the Ecology Center, found PFAS chemicals in nine fertilizers made from sewage sludge — commonly called “biosolids” in ingredient lists — and maps more than 30 companies selling sludge-based fertilizers and composts for home use across the US. Eight of the nine products exceed the screening guideline for PFOS or PFOA set in Maine, the state with the strictest safeguards for PFAS levels in sludge spread on agricultural lands.
The following two images show that the area around Spokane has a dense cluster, when compared to the rest of the country, of locations where consumer fertilizer products that contain sewage sludge are sold. Virtually every location in the vicinity of Spokane sells sewage sludge-laced composts manufactured by Barr tech, a Spokane-based private large-scale composting company. Home gardeners and farmers alike in our region run a higher risk of contaminating their soils, and their food, with the toxic contaminants in sewage sludge based on our region’s large number of available retail outlets. It’s also not clear if purchasers of compost containing sewage sludge are adequately informed that sewage sludge is an ingredient and/or what the risks are.
On March 24, 2021, the Northwest Toxic Communities Coalition presented a free Virtual Webinar, SEWAGE SLUDGE FERTILIZER CAPACITY: TIPPING POINT? Can humans withstand exposures to increasingly complex combinations of chemicals and biological agents?
>> Listen to an audio recording of the webinar <<
Four Expert Presentations:
The Irreversible Impact Widespread Sewage Sludge Has on our Planet’s Ability to Support Life by Dr. David Lewis, retired from the U.S. EPA in 2003 as a senior-level Research Microbiologist with 32 years of service. He also served on the Graduate Faculty of the University of Georgia. His research on public health has been published in Nature, Lancet and other leading scientific and medical journals. Dr. Lewis’s book, Science for Sale, covers the history of effects of sewage sludge. Dr. Lewis received the 2000 Science Achievement Award from the EPA, and the 2018 Distinguished Service Award from the Sierra Club.
Three Adventures Organizing Citizens to Stop Sewage Sludge Land Spreading by Ed Kenney, Nisqually Delta Assoc., Olympia, WA. Ed is a consummate environmental activist who has organized teams of volunteers to clean up the debris and planted trees for large restoration projects. He was awarded Conservationist of the Year by the Black Hills Audubon Society in 1992. More recently, Ed brokered a multi-million-dollar agreement between Joint Base Lewis-McChord military base, the City of DuPont, Cal Portland and six conservation groups to restore over three miles of Sequalitchew Creek. He has fought against land application of sewage waste in Washington state.
Industrial Waste Spreading by Patricia Martin, former Mayor of Quincy, WA. Patty Martin is the founder of Save Our Soil (formerly Safe Food & Fertilizer), and Chair of the Northwest Toxic Communities Coalition. The book, Fateful Harvest (2001), chronicled her fight to expose the use of hazardous waste-derived fertilizers in agriculture and the chemical industry’s efforts to shut her up. In 2013, Patty received the Environmental Justice Award from the Sierra Club and the Center for Environmental law and Policy for her work on air quality.
Protecting a Watershed: A Successful Anti-Sludge Campaign in Eastern Washington by Morton Alexander, Co-founder of Protect Mill Canyon Watershed. Morton Alexander is a community organizer and retired state employee. He tends to his home orchard and is a neighbor to other organic food producers in Mill Canyon, Lincoln County, WA.
PCC Community Markets (aka Puget Consumer Co-op) is the nation’s largest co-op grocery retailer with 13 stores and more than $288 million in revenue. The Co-op has been opposed to the use of sewage sludge on farms for decades and continues to voice opposition to the practice. Here’s part of what PCC wrote to the WA Dept. of Ecology in January 2020: “Application of biosolids to agricultural lands, unfortunately, presents significant risks to both aquatic and land-based ecosystems through introduction of potential toxins and potential pathogens. Overall, we do not believe that biosolids application to agricultural lands should continue or be permitted— especially with the increasingly fragile state of our local environment and species, such as Chinook salmon.”
Thank you, again, Upper Columbia River Group of the Sierra Club of Washington State for your support of ending the land application of sewage wastes!
A Victory in Yelm!
Through community organizing, residents of Yelm, WA stopped sewage sludge from being spread in their watershed. Read more on their website,
Preserve the Commons.
Sewage Sludge Action Network Facebook Feed
Up to the minute news and information from this fine national sewage sludge clearing house.
This could change everything!
In March it was announced by a Maine-based grassroots environmental organization, the Environmental Health Strategy Center, that a farmer in Arundel Maine discovered milk from his cows was contaminated with unsafe levels of toxic PFAS chemicals. The contamination came from treated municipal sewage sludge that he had spread on his fields for years. The farmer has had to stop selling his milk and his business was ruined.
Read the original article as broken by Reuters News Service on March 19.
Patrick MacRoy, deputy director at the Environmental Health Strategy Center, said the contamination at the Stoneridge Farm raises questions about the safety of biosolids [sewage sludge] used at farms nationwide. “The Stone case is incredibly troubling because the source of exposure – waste sludge – is something that is also spread across hundreds of farms in Maine and thousands nationally,” he said.
Two days after this announcement, the Maine Department of Environmental Protection announced that it will require new testing of all sludge material licensed for land application in the state. The tests will look for several synthetic contaminants known as PFAS, which are found in a range of consumer products. PFAS have been linked to cancer and other health problems.
So, yes! Congratulations to Maine for taking swift action in light of the discovery of this contamination. The additional testing being required in Maine should put all other state regulators who oversee sewage sludge disposal on notice: When can we expect YOUR agency to order additional testing of sewage sludge and the farms where it has been applied?
While there is new attention, across the country, being paid to the PFAS contamination problem and it’s good that it is getting people to scrutinize their sewage sludge programs, we can’t get too distracted from the old problem we have always had with sewage sludge since the first days of land disposal, namely, the hundreds of other toxic contaminants found in sewage sludge that are not regulated and are not being tested for.
One quote from an official in Maine should drive home what we are up against:
“In taking Friday’s action, Department of Environmental Protection Commissioner Jerry Reid stated, ‘The Department is moving forward with the additional [PFAS] testing requirement to ensure that any future land applications of sludge are safe.’ “
One thing must be made clear to the regulators and better understood by the public: The land application of sewage sludge is not “safe.” It has never been “safe.” It can’t be made “safe.”
The EPA’s own inspector general has concluded that the EPA, agency that sets the ground rules for sludge regulation among the states, does not have the data to perform risk assessments on the hundreds of toxic pollutant contaminants they know are present in sludge and therefore EPA isn’t in a position to say one way or the other how safe the land application of sewage sludge is even if there was no PFAS. If sewage sludge in Maine is sampled for PFAS and found to be below the state’s standard for those chemicals, that sludge is still not safe!
The attention being paid to PFAS is an open door for active citizens to educate folks about the other sludge contaminants. We need to get the officials to acknowledge the need to test for other substances as well. Not just testing the sludge, but also the soils, the groundwaters, the crops. We need to make sure the regulatory/industrial complex that promotes the land application of sewage sludge doesn’t use the campaign against PFAS chemicals to give themselves a clean bill of health and go back to business as usual if they happen to find PFAS at ‘acceptable’ levels in some sludge.
As we organizers do our agitating and educating, let’s remember to have compassion for any farmers whose livelihoods end up being affected as a result of greater scrutiny our efforts will bring about. The blame, as always, is on the manufacturers of these toxic compounds which begin as profit for them and end as pollution for us. It’s on the chemical regulators and the government agencies that have, for so long, recklessly promoted an obviously wrong-headed and dangerous approach to sludge disposal.
We need to end the land-application of sewage sludge here in the State of Washington and we need to join with others in a national call for a different way. No Sludge in Ag!
 The curious case of tainted milk from a Maine dairy farm by Richard Valdmanis and Joshua Schneyer, Reuters, March 19, 2019
 Maine DEP Establishes Aggressive Requirement for PFAS Testing in Biosolids, National Law Review, Monday, March 25, 2019
Protect Mill Canyon Watershed Earns “Water Protector” Award
We are Grateful to the Sierra Club for Recognizing Our Work and for Their Continued Activism Around the Sewage Sludge Issue (see the S.C. Sewage Wastewater Residuals Fact Sheet)
The Sierra Club opposes the use of contaminated toxics and/or pathogen containing waste as a compost ingredient and the application of municipal sewage sludge as a fertilizer. (Compost Policy, Sewage Sludge Policy and Agriculture and Food Policy.) Visit the documents posted on the Sierra Club’s Grassroots Network Wastewater Residuals Team web page.
The Struggle Continues
2021 is the year we take sewage sludge off your kitchen table and put it on the legislative table. We won’t accept the dumping of sewage sludge on agricultural land and we’re going to bring it into the public policy conversation in a big way.
This excellent video “A Toxic Betrayal” is 10 years old, but since nothing has changed, it’s sadly all still current.
It’s well-suited for public showings and discussion since it’s less than 20 min. long.
United Sludge Free Alliance is credited at the end of the video. Check out their website.
Crapshoot: The Gamble with Our Wastes, Jeff McKay, provided by the National Film Board of Canada
Send a message to Washington Governor Jay Inslee and Washington State Department of Ecology Director Maia Bellon:
You must immediately impose a state-wide emergency moratorium on approving all pending permits for land application of sewage sludge!
Contact your Washington State legislators and ask them to introduce legislation:
1) To ban the land-application of sewage sludge;
2) To get safety warning labels on all products that contain biosolids;
3) To label foods that were grown using sewage sludge.
Fire Mountain Farms, the same company that wanted to spread sewage sludge in the Mill Canyon watershed in eastern Washington has now applied for a permit to to spread biosolids (Municipal Sewage Sludge) on 180 acres of land only 1000 feet away from the Nisqually River in Yelm, WA!
A local organization in Yelm, Preserve the Commons, is leading the struggle against yet another ecological onslaught by the sewage sludge slingers. Learn how to prevent municipal sewage sludge from coming to yelm. Understand the legal effort underway to prevent biosolids in Yelm.
The Dept. of Ecology is allowing public comment until February 13th. You can send an email, letter or call. Details on the Preserve the Commons website.
TAKE ACTION: Congress Must Act! (Open)
TAKE ACTION: Demand Your Right to Know About Toxic Sewage Sludge in Your Food! CONGRESS MUST ACT.
Ask your Member of Congress to cosponsor the Sewage Sludge in Food Production Consumer Notification Act
Sewage sludge: The U.S. Environmental Protection Agency (EPA) euphemistically calls it “biosolids.” But what is it really? And why should you care?
“. . . whatever goes into the sewer system and emerges as solids from municipal wastewater treatment plants. Sludge can be (its exact composition varies and is not knowable) any of the 80,000 synthetic chemicals used by industry; new chemicals created from combining two or more of those 80,000; bacteria and viruses; hospital waste; runoff from roads; pharmaceuticals and over-the-counter drugs; detergents and chemicals that are put down drains in residences; and, of course, urine and feces flushed down toilets.”
This toxic stew is sold to farmers who use it to fertilize food crops— a fact most consumers don’t know— because food producers and retailers aren’t required to tell you. Even consumer gardening products like compost and fertilizer sometimes contain sludge, but with no warning labels. Of special concern are children exposed to sludge either in their food or in the garden when they’re out helping in the garden.
In November, the Environmental Protection Agency’s Office of Inspector General published a new report: “EPA Unable to Assess the Impact of Hundreds of Unregulated Pollutants in Land-Applied Biosolids on Human Health and the Environment.” In it, the OIG complained that the EPA isn’t making the public aware that “potentially harmful and unregulated pollutants,” such as pharmaceuticals, steroids and flame retardants, are present in biosolid.
Congressman Jose Serrano (D-N.Y.) introduced the bill (H.R. 2064) which would require the food industry to label products that have been grown in farmlands that use sewage sludge as fertilizer. On his Facebook page, Serrano said:
“Americans need to know where and how their food was grown so that they can make informed decisions when buying food products, especially if the fertilizer used to grow that food contains varying degrees of pathogens, heavy metals, organic chemicals, industrial solvents, asbestos, and radioactive waste. It is time to make sure that federal law adequately protects consumers from sewage sludge that is being used as fertilizer.”
Consumers of organic food might think we don’t need to worry since biosolids are prohibited in organic agriculture, but we are also at risk as current organic rules would not prohibit a farm that had used biosolids from certifying as organic if no biosolids had been applied in the three years prior to certification. There’s also drift and run-off issues that can contaminate organic farm soil. Based on the lack of EPA data, there is no way of knowing if the tree-year period is sufficient when it comes to biosolids.
Ask your Member of Congress to cosponsor the Sewage Sludge in Food Production Consumer Notification Act.
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New! Wisconsin case shows how sewage plants spread unregulated toxins across landscape
Wisconsin State Journal, Jan 27, 2019
Excerpt: “Industry has created more than 3,000 PFAS compounds (fire-retardants, non-stick cookware, etc.), and new ones have regularly been introduced. Some have been in use since the middle of the last century. Relatively few have been extensively studied. Research shows they accumulate in animal tissue, and are associated with diseases of the liver, kidneys, glands and immune system. They escape treatment plants through the processed wastewater that is deposited into public waters and the treated sludge spread onto farm fields…”
Motivated Activists Wanted. (Open)
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Other Recent Updates:
Environmental Protection Agency not protecting human health and the environment from biosolids, audit finds. (Open)
November 15, 2018: The EPA’s Office of Inspector General (OIG) issued a report of an audit of the EPA’s Biosolids Program. “The EPA’s controls over the land application of sewage sludge (biosolids) were incomplete or had weaknesses and may not fully protect human health and the environment. The EPA consistently monitored biosolids for nine regulated pollutants. However, it lacked the data or risk assessment tools needed to make a determination on the safety of 352 pollutants found in biosolids,” the report states.The OIG made thirteen recommendations, including requiring labeling of biosolids products to include information regarding the presence of up to 352 unregulated pollutants in sludge and statements of risks about biosolids.
“Three-Hundred-Fifty-Two Pollutants— Some Hazardous— Found in Biosolids”
“…the EPA identified 352 pollutants in biosolids. The EPA does not have complete risk assessment information on these pollutants; therefore the agency cannot say, whether the pollutants are safe or unsafe when found in biosolids … [including] sixty-one designated as acutely hazardous, hazardous or priority pollutants in other [Federal] programs.”
“…Existing biosolids data and studies do not fully examine the pollutants found in biosolids, especially unregulated pollutants. Until such research and data exist, the EPA cannot determine if any regulations should be issued. In over 20 years, no new pollutants have been regulated.”
The OIG website has a page devoted to this report, including this audio podcast which is an excellent summary of the findings and recommendations.
Visit our ‘Documents‘ page for a library of background information.
Spokane considers burning sewer sludge after outcry over fertilizer use. (Open)
Spokesman Review Newspaper, Wed., March 28, 2018.
Excerpt: Late last month, the city [of Spokane] signed a contract to explore the possibility of burning that sludge at its Waste-to-Energy plant amid concerns the so-called “biosolids” retained chemicals that could be harmful if absorbed in the ground water.
The link in the above sentence points to a story about our Protect Mill Canyon Watershed campaign. We are still making waves!
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We are often asked, ‘what else can be done with sewage sludge besides spreading it on farmland?’ (Open)
Incineration is often cited as an option, but, as noted in the March 2018 article Spokane considers burning sewer sludge after outcry over fertilizer use “air emissions are a concern when incinerating the material, an issue that has plagued Spokane’s Waste-to-Energy facility in the past.” We are very concerned about emissions from sludge incineration. Hopefully, this ‘exploration’ of incineration as an option will be an open and transparent process. If so, it will be a good opportunity to scrutinize this option for dealing with sludge.
That said, there are established and emerging technologies that employ closed-loop pyrolysis which heats materials to 900°C . Organic materials are broken down under high temperature and with the exclusion of oxygen. The gasses produced are marketable products such as hydrogen and can be used to fuel the process. Plants of this type are increasingly being constructed in areas where alternatives to land-application are prioritized.
Charbon Zero™ Corp (CZC™)
Charbon Zero Corp™ (CZC™) was formed to generate renewable clean energy from non-recyclable waste plastic, plant-derived wastes and specialty wastes using enhanced fluidized bed combustion (FBC) technology with full carbon capture and utilization (CCU). Charbon Zero Corp has designed a facility that will generate ‘renewable clean energy’ from combustible wastes, without release of any form of exhaust, wastewater or solid waste. Plans are in the works to build the first one in Washington State. With a ban on land-application of sewage sludge looking more likely now than ever before, investing in facilities to process sewage sludge in other ways that are not harmful to the environment or human health is the only responsible thing to do.
• Generates Valuable Residual Products
• Reduces or Eliminates Non-Recyclable Wastes
• A Clean Technology Intended to Mitigate Climate Crisis
• A Critical Unmet Human and Environmental Health Need
• A Sustainable Approach to Repurposing Growing Waste Streams
Kamloops Biosolids Awareness posted some information on alternatives to land application on their Facebook page:
Wondering what great ideas Kamloops has now for its piles of TSS – Toxic Sewage Waste? … hearing that the FN Band has voted resoundingly to REJECT the tons of pollutants from being dumped on their lands. Maybe, just maybe, Kamloops will take responsibility for its toxic burden, and embrace a 21st century solution. Pushing its pollutants onto other communities is NOT being very neighbourly. Just saying.
Think for a moment about just how absurd this “biosolids” business model really is. The wastewater treatment facilities have spent a great deal of time and effort collecting, concentrating, and segregating the pollutants out of the water … so why on earth would we turn around and put those piles of toxins back into the environment we just eliminated them from? That is truly a short-sighted practice that merely supports a business model based on “pushing” pollution. Situating a gasification / pyrolysis (or clean incineration) plant directly beside the water facility would dramatically cut trucking costs, and cut the huge carbon emissions this constant transport inevitably involves.
Hydrogen from organic waste: Start-up has developed a new process
Published by: Market Research Telecast, July 11, 2021
The biomass [sewage sludge, green waste, food leftovers, organic waste, compost or digestate from biogas plants] is first dried with the waste heat from the reactor [incineration chamber]. It then enters the reactor in the form of pellets, where it is exposed to temperatures of around 900 degrees. This creates a gas mixture that mainly consists of hydrogen and carbon monoxide – so-called “synthesis gas”. The operator of a plant can use established industrial processes to produce hydrocarbons, for example, or to separate the hydrogen and convert it into electricity in a fuel cell.
“We carried out 1500 hours of trials in a test facility and came up with a hydrogen yield of up to 50 percent,” says [Bernd] Bodeit [of BHYO GmbH, a german limited liability partnership]. An assessment by Fraunhofer ISI and TH Bingen has shown that one ton of biomass can be used to produce up to 100 kilograms of hydrogen.
An example of gasification – producing energy and biochar – Tennessee Gasification plant – https://www.youtube.com/watch?time_continue=5&v=E_-dXjyjTgs
An example from the UK – gasification of sludge – Yorkshire Water’s Gasification Plant – https://wwtonline.co.uk/features/gasification-of-sludge-innovation-in-action
Pyrolysis of sewage sludge – syngas and biochar – Pyrochar – Cordis Europe – https://cordis.europa.eu/news/rcn/123842/en
There are new solutions appearing almost daily – We can make BRICKS (https://www.sciencedaily.com/releases/2019/01/190122084410.htm) out of biosolids, or we can
PAVE ROADS (https://www.researchgate.net/publication/265697446_Potential_Uses_of_Sewage_Sludge_in_Highway_Construction) with it.
Making Bio-Crude is also an option – https://www.treehugger.com/renewable-energy/simple-new-process-turns-sewage-sludge-biocrude-oil.html
These are just a few possibilities.
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We Won! Read about the Mill Canyon Campaign. (Open)
We are residents who live in an area near Davenport, Washington called Mill Canyon. Beginning in 2013 we felt threatened by proposals to spread municipal sewage sludge on nearly 900 acres of nearby agricultural land uphill from where we live, garden and farm. The area in question includes our natural watershed. As citizens, we were alarmed and successfully organized to prevent the dumping of sludge in our watershed. We didn’t want sewage sludge to be applied to agricultural lands in our watershed. We fought hard against it. Now, due to our efforts and those of our supporters, sludge will not be applied to lands immediately adjacent to the canyon where we live, according to a newly approved permit, issued December 13th by the Department of Ecology. The scale of the win for our committee is significant. The total acreage that will have sludge applied has been reduced from the original 887.45 acres to 157.77 acres in the final permit, five and a half miles away from us (but close to other folks, sad to say).
We still strongly advocate for a state-wide moratorium on any further sludge permits until a thorough review of current science is completed, which we hope will determine that there is too much risk to continue the practice of spreading municipal sewage sludge on farmland.
Lots of news coverage of the final outcome. Our press release is below. Here are links to other media coverage.
FOR IMMEDIATE RELEASE: DECEMBER 19, 2017
Citizens’ Group Reports Victory in Battle Against Sewage Sludge
An informal committee of neighbors in the Mill Canyon area northeast of Davenport, WA is calling it a victory: They didn’t want sewage sludge to be applied to agricultural lands in their watershed. They fought hard against it. Now, due to their efforts, sludge will not be applied to lands immediately adjacent to the canyon where they live, according to a newly approved permit, issued December 13th by the Department of Ecology.
The scale of the win for the committee is significant. The total acreage that will have sludge applied is reduced from the original 887.45 acres to 157.77 acres in the final permit. The original application indicated sewage sludge would have been applied less than one mile from Mill Canyon residents’ farms, gardens and wells and less than half a mile from the source of a private spring used for drinking water that figured prominently in comments sent to the Department of Ecology citing concerns over potential contamination from the sludge. With the approved permit, the closest to the canyon any sludge will be applied is over 5 miles away.
For close to two years, the citizens fought the permits sought by Fire Mountain Farms of Onalaska, WA. Fire Mountain Farms is a company with a checkered reputation that offers to apply sewage sludge on farms at no cost to the farmer (the company is paid by sewage treatment plants to take the sludge away). Concerned Mill Canyon residents met with their neighbors and testified at public hearings. They wrote letters and generated publicity that raised public awareness about the risks of applying sewage sludge to farmland.
In the spring of 2017, when it looked like the permits to dump the sludge were all but destined to be approved, the neighbors stepped up their opposition efforts. They named their informal committee “Protect Mill Canyon Watershed.” They announced their intention to appeal in the case of an adverse decision and launched a detailed website laying out their position. They initiated a statewide letter-writing campaign that helped garner support for their position and put pressure on the Department of Ecology. The committee also received valuable guidance, advice and support from the Columbia Institute for Water Policy, the Northwest Fund for the Environment, Safe Food and Fertilizer (a project of Earth Island Institute) and the Sierra Club.
Ultimately, it was one-on-one negotiations between neighbors that achieved the compromise reducing the acreage and proximity of sludge application. As the deadline for a decision on the permit from Ecology approached, representatives from Protect Mill Canyon Watershed met and corresponded with the grain farmer who was seeking to have the sludge applied to his lands. Despite urgings from the Department of Ecology and the sludge applicator that the original provisions should be defended in administrative court, the farmer ultimately decided that being a good neighbor was most important and agreed to withdraw from applying sludge close to Mill Canyon.
Morton Alexander, a landowner whose spring was at risk commented, “We refused to just lie down and accept this threat to our beautiful canyon, its air and water. We are grateful for support from the larger community, regional and statewide, that brought credibility to our fight. Hopefully, our success inspires resistance by others in similar struggles.”
Protect Mill Canyon Watershed is an informal committee of Mill Canyon residents.
Committee members: Morton Alexander, Corrina Barrett, Ernest Barrett, Laura Harris, Paige Kenney, Chrys Ostrander and Timothy Pellow. Jill Herrera, Grant Writer; Rachael Paschal Osborn, Columbia Institute for Water Policy, Legal Adviser; Donald Hanson, Science Adviser; Patricia Martin, Safe Food and Fertilizer, Technical Adviser.
– Protect Mill Canyon Watershed website: http://www.protectmillcanyon.org/
– Final Permit from Ecology, Site-specific Land Application Plan for Fire Mountain Farms – Rosman Farms Unit
– Protect Mill Canyon Watershed maintains the position that sewage sludge should never be released into the environment and that the practice of applying sewage sludge to agricultural and forest lands in Washington should be ended. Protect Mill Canyon Watershed advocates for a statewide moratorium on future permits for the land application of sewage sludge.
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