We Won! The Struggle Continues.

The Washington State Department of Ecology hosted a public hearing on the proposed Statewide General Permit for Biosolids Management on June 22nd, 2021. 

Below is reprinted an article from the Inland FoodWise Online Journal about that hearing:
Author: Chrys Ostrander

July 12, 2021

65% Say ‘No More Sewage Sludge on Farmland’ in Comments to Department of Ecology

Tumtum, WA: Out of exactly 100 public comments received by the Washington State Department of Ecology on the morning of the comment deadline, 86% of people who submitted written comments don’t want municipal sewage sludge to be used as fertilizer, or that its use be significantly more strictly regulated. 65% want an immediate ban.

Widely recognized safety concerns about chemical contamination in sewage sludge which is then used as fertilizer were commonly mentioned by commenters. [July 13 Update: At the closing of the comment period there were 113 comments. 63% favor an immediate ban on land-application, 21% seek more stringent regulation. The remaining 16 comments (14%) were either pro or neutral.]

The Washington State Department of Ecology proposes to re-issue a five-year Statewide General Permit for Biosolids Management which expired in September, 2020. Biosolids is another word for treated sewage sludge. The Statewide General Permit sets the regulations for Washington facilities which are involved in the spreading of sewage sludge on farm and forest land.

Ecology is accepting public comments on a draft permit until 11:59 PM July 12, 2021.

Most of the commenters who supported stricter regulations supported tighter rules, such as testing for a wider variety of contaminants or taxing and regulating the sludge, which is often given away free to farmers, the same way other fertilizers are. While not seeking an immediate ban on land application, some of the stricter requirements suggested by commenters could themselves ultimately preclude land-application of sewage sludge. For example, if additional testing for chemicals (that does not occur now) indicated unacceptable levels of one or more pollutants in most batches of sludge, then the land-application program might be forced to close down.

Ecologically sound alternatives to land-application of sewage sludge exist and are in use in the U.S.A. and in other countries. Several commenters strongly suggested that the Department of Ecology embark on a quest to develop alternatives to land-application that can be implemented in towns and cities across the state.

Most commenters want the land-application to end now. That would mean Ecology would have to find another way to manage the disposal of the 86,000 dry tons of biosolids that the agency says are currently land-applied each year in Washington. In the mean time between an outright ban and deployment of replacement infrastructure, hazardous waste landfills exist accessible by truck and train from points in Washington and some existing incinerators in the state can be adapted to incinerate sewage sludge while the transition to a different disposal methodology takes place.


All the comments can be accessed HERE:

Sierra Club of Washington: Controlling Sewage Waste: Washington State Ecology’s Approach versus Science

Protect Mill Canyon Watershed is a grassroots committee based in Spokane and Davenport that organizes for a ban on land-application of sewage sludge.

Inland Foodwise Online: It’s Time to Stop Spreading Sewage Sludge on Washington Farms Say Environmental and Food Safety Advocates
IFO is a blog about the inland northwest food system.

 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.

Email the committee today!


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.

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 emily.kijowski@ecy.wa.gov, 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.

Read it Now!

Morton Alexander
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

Beyond Pesticides
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 …”

Read more…

VT Digger
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 …”

Read more…

Michigan Live
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.

Read more…

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.

Press Release

Full Study and Map

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.


facsimile of NEJA Newsletter
Read the article by long-time activist Darlene Schanfeld in the summer 2019 issue of the National Equal Justice Association newsletter.

Facsimile of newsletter page
“Biosolids” are what the waste industry euphemistically calls the sludge left over after sewage is processed through wastewater treatment plants. It is increasingly promoted as free fertilizer for farmers as well as compost for gardeners.

As thousands of toxic materials are invented, used, and go down drains into sewers, our State Department of Ecology and the EPA have for decades only required testing for 9 contaminant metals, despite the fact that in 2009, an EPA study concluded that all sewage sludge contains hundreds of toxic pollutants.

In 2018, the EPA’s Office of Inspector General concluded that they haven’t the data or the means to prove “biosolids” safe. Yet serious health issues are related to PFAS chemicals (per- and polyfluoroalkyl substances) which have been found in food products from land treated with these biosolids in Maine, Pennsylvania, New Mexico, and Washington, as well as in milk from cows fed grains from biosolid-treated fields.

In the past 2 years, the Sierra Club has helped small rural communities across Washington State to protect their air, land and water from farmland sludge applications.

If you want to see updates and join in the discussion about battles against land application of “biosolids, visit tinyurl.com/join-no-sludge-on-aglands

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.[1]

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.’ “[2]

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!

[1] The curious case of tainted milk from a Maine dairy farm by Richard Valdmanis and Joshua Schneyer, Reuters, March 19, 2019

[2] 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.

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)

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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

Steven Verburg
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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If you're serious, join the "No Sludge on Ag Land" Google Group to network with others and get shit done.

We're working on ending the practice of spreading sewage sludge on farmland and forests in Washington State.

You don't need to have a Google Account to be on the listserve. Fill out this form and you will be added to the listserve if approved. It will be set up so your messages to the group will go to each member of the group and all replies will go to all members of the group (good transparency and keeping folks in the loop). To reduce clutter, individual replies may also be used. It is a private group.

Please tell us a little about yourself and why you want to help organize around this issue.

Also, you may send us the email addresses and first and last names of people you think it would be good to have on the list. We will send them invitations. If they are interested, they can opt in.

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Other Recent Updates:


Spokane considers burning sewer sludge after outcry over fertilizer use

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!

We are often asked, ‘what else can be done with sewage sludge besides spreading it on farmland?’

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:

January 31, 2019

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.

Read the full article

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.


We Won! Read about the Mill Canyon Campaign

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.



 Citizens’ Group Reports Victory in Battle Against Sewage Sludge


Morton Alexander,
Mill Canyon resident  mortonalexander@sisna.com
(801) 637-6903


Chrys Ostrander,
former Mill Canyon resident
(914) 246-0309

Davenport, WA

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.

Map showing how much land was saved from the threat of sewage sludge application.
The green shaded areas had been included in Fire Mountain Farms’ permit application but are NOT included in the final permit! Only the red shaded area will receive any sludge, over 5 1/2 miles away.

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.




Sludge Moratorium

Urgent Action Alert!



Here's how YOU can make a difference! (Open)

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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

Please use the following text as a reference when writing your message. More details about our specific objections to spreading sewage sludge on agricultural lands can be found HERE.

Impose an immediate moratorium on approval of permits for biosolids disposal on agricultural lands

Dear Ms. Bellon and Gov. Inslee,

%your signature%

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Share this with your friends:


Remember, it’s always good to add a personal message. Also, please cc us when you send your message:

Here is the pertinent contact information and message text:

Governor Jay Inslee

Office of the Governor
PO Box 40002
Olympia, WA 98504-0002
Phone: 360-902-4111
Fax: 360-753-4110
Email: Governor.Inslee@Governor.wa.gov
Email (from his website’s contact form): http://www.governor.wa.gov/contact/contact/send-gov-inslee-e-message
Facebook: https://www.facebook.com/WaStateGov
Twitter: https://twitter.com/GovInslee

Maia Bellon, Director, Washington State Department of Ecology

Ecology Headquarters
PO Box 47600, Olympia, WA 98504-7600
Phone: (360) 407-7001
Fax: (360) 407-6989
Email: maib461@ecy.wa.gov

Dear Ms. Bellon and Gov. Inslee,

You must immediately impose a state-wide emergency moratorium on approving all pending permits for land application of sewage sludge.

Residents who live in an area near Davenport, Washington called Mill Canyon successfully challenged a proposal to spread municipal sewage sludge (aka “biosolids”) on nearly 900 acres of nearby agricultural land uphill from where they live, garden and farm. The area they defended includes their natural watershed.

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 Creek 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.

Despite this victory, sewage sludge is still being applied to thousands of acres of agricultural soils in Washington every year. There will really be no victory until the practice of spreading sewage sludge on farmland is relegated to the dustbin of history where it belongs.

Hundreds of industrial, pharmaceutical and organic pollutant contaminants are known to be present in sewage sludge but are completely ignored by Department of Ecology biosolids regulations. The Department routinely approves sewage sludge for land application based on just two pathogen indicators and whether concentrations of only nine metals (Arsenic, Cadmium, Copper, Lead, Mercury, Molybdenum, Nickel, Selenium and Zinc) are within its arbitrarily-set parameters for those metals. With respect to what is known to contaminate sewage sludge, this degree of oversight is inadequate to assure safety.

Current regulations allow permit holders to repeatedly apply biosolids (sewage sludge) to agricultural lands with no regard to accumulations of pollutants beyond the nine metals.

Numerous irregularities, omissions and incomplete responses were present in the permit application for land application of sewage sludge near Mill Canyon (Site Specific Land Application Plan for Rosman Farms Unit, a Component of Fire Mountain Farms, Inc. Application for Coverage Under the General Permit for Biosolids Management, Permit No. BT9902) which call into question the integrity of ALL such permit applications as well as Department of Ecology’s capacity and desire to adequately administer the entire state sludge program in fulfillment of its mission to “protect, preserve and enhance Washington’s environment for current and future generations.”

Therefore, I demand that Washington State Department of Ecology Director Maia Bellon and Washington State Governor Jay Inslee immediately impose a state-wide emergency moratorium on approving all pending permits for land application of sewage sludge until a thorough review of the science is completed and the findings incorporated into re-worked regulations pertaining to sewage sludge disposal in Washington state.

<Your Name>
<Your Email>

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


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Voices of our Supporters

Here's what we heard from folks during our campaign to save our watershed from sewage sludge last year. (Open)

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This is the kind of support that helped us prevail. The work is not over. 2019 is the year we take sewage sludge off your kitchen table and put it on the legislative table. We won’t accept it and we’re going to bring it into the public policy conversation in a big way.

“Hello, I am a member of a small group of Mason County, WA residents who are working to stop construction of an 18 million gallon septic filtrate lagoon.  We would very much like to stop this, and the application of septage on ag land, but likely too late for us. Some of us will continue to the fight.  Thanks for the inspiration.”

“I’m appalled at the prospect you face of having sewage sludge put on the land above you, and having the possibility of your land being contaminated by the sewage sludge.I don’t have lots of money to help you with, but would like to help in other ways.”

“Very disconcerting to learn of the biosolid threat.Hopefully, common sense will prevail.”

“I have signed the petition.I am not in a position to do much else at present, but I have implored my loved ones and social media followers to participate.This situation horrifies me and I want to keep apprised of how it advances.Thank you, and I am hoping with all my might for a favourable outcome.”

“Wishing you all success. We have been fighting this practice in my Virginia County since 2004. Our Department of Environmental Quality has never denied a permit and industrial waste from a paper mill has been approved by the Commonwealth’s Department of Agriculture and Consumer Services as a registered “fertilizer.” Keep up the fight against a practice that is nothing more than a transfer of liability from WWTP to rural land.”

“I want to help and I want to stay updated about this issue.”

“Today I read the excellent article in the Davenport Times. It is an outrage that there is even a possibility that bio-solids could be put on highly erodible land that is also near water!Glad you are standing up for what is right.Please keep me posted.”

“Thanks for organizing this.”

“I live near”ish” to Mill Canyon. No way do I want sludge spread as a fertilizer.”

“Thanks for getting this info out! Totally unacceptable – no matter how the issue is spun.”

“We must all stand for sustainable, healthy water & equitable access to it, everywhere, or we will all suffer, everywhere.”

“We must protect our food, land, and more from this threat to contamination to our water, air and soil. “

“The use of sewage sludge on food crops , and anywhere near a drainage ditch, stream, river, lake, or Puget Sound should not be allowed.”

“I do not support the use of bio-solids near my community or home.”

“Owner of an Eastern Washington small non organic wheat farm. We farm with inorganic nitrogen for fertilizer. Although bio-solids can increase yields slightly, they are toxic and may show up as dangerous chemicals in the wheat. Use cow manure not bio-solids!”

“Good to see other farmers and ranchers fed up with toxic bio-solids being peddled as ‘beneficial fertilizer’ …this nasty retoxification of farmland and watersheds needs to be stopped. Keep up the good fight!!”

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A library of background scientific information on sewage sludge and the Protect Mill Canyon Watershed campaign timeline. Contact us if you know of scientific documents that should be listed here that aren’t already.


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Scientific Documents (updated 06.15.2021) |  Sludge Permit Applications | Community Comments  | Maps | Protect Mill Canyon Watershed ‘In the News’
| Other Media |  Etc.

Scientific Documents

New! October 2020 WA Dept. of Ecology Advisory Committee Webinar PFAS Chemical Action Plan

The meeting notes from Ecology’s October 2020 PFAS Webinar gives us an idea of how Ecology is responding to concerns about PFAS in Biosolids – the usual. They claim there are no valid PFAS test methods (although multiple states and local jurisdictions are conducting tests), and no funds for testing. So what’s their approach to the problem? Ignore it and continue to spread sludge as always.


New! Sludge in the Garden – Toxic PFAS in Home Fertilizers Made From Sewage Sludge

A new report released in May, 2021, 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.
Press Release
Study Page and Interactive Map

New! PFAS in Biosolids, 2020, Sierra Club Grassroots Network ‘s Wastewater Residuals Team. Includes reviews of recent studies, observations and recommendations.


Are Agricultural Soils Dumps for Microplastics of Urban Origin? Luca Nizzetto, Martyn Futter, and Sindre Langaas of the Norwegian Institute for Water Research, Oslo, Norway, the Research Centre for Toxic Compounds in the Environment, Masaryk University, Czech Republic and the Department of Aquatic Sciences and Assessment, Swedish University of Agricultural Sciences, Uppsala, Sweden, 2016

Beneficial Reuse of Residuals and Reclaimed Water: Impact on Soil Ecosystem and Human Health. W3170 Multistate Research Project (formerly W2170), The Western Association of Agricultural Experiment Station Directors (WAAESD).

Biosolids, Beyond Pesticides

Case for Caution Revisited: Health and Environmental Impacts of Application of Sewage Sludges to Agricultural Land, Ellen Z. Harrison, retired Director, and Murray McBride, Director, Cornell Waste Management Institute, Dept. of Crop and Soil Sciences, Rice Hall, Cornell University, Ithaca, NY.

Comments to New York State Department of Environmental Conservation regarding Proposed Revisions to Part 360 Rules (New York State’s Solid Waste Management Facilities Regulations) – Submitted by: Ellen Z. Harrison, Director, Cornell Waste Management Institute. 02-28-2002

Contaminants of Emerging Concern EPA

Emerging Substances of Concern CANADA

Environmental Protection Agency not protecting human health and the environment from biosolids, audit finds

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.

The OIG website has a page devoted to this report, including this audio podcast which is an excellent summary of the findings and recommendations.

EPA Contaminants in Biosolids-Table

EPA Response to NAS-NRC 2002 Report

EPA Targeted National Sewage Sludge Survey Statistical Analysis

Focus for Health, Environmental Toxins & Biosolids

Food and Sewage Sludge – Legalizing the Poisoning of our Food

Guidance for Controlling Potential Risks to Workers Exposed to Class B Biosolids. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, July 2002

Impact of Long Term Sewage Sludge Additions to Biological Function in Scottish Soils

Investigation of Alleged Health Incidents Associated with Land Application of Sewage Sludges, Cornell Waste Management Institute Center for the Environment, 2002.

Land Application of Treated Sewage Sludge: Community Health and Environmental Justice. Amy Lowman, Mary Anne McDonald, Steve Wing, and Naeema Muhammad of the Department of Epidemiology, University of North Carolina, Chapel Hill, the Department of Community and Family Medicine, Duke University, Durham, North Carolina, the Concerned Citizens of Tillery, Tillery, North Carolina, 2013

Organic chemicals in sewage sludges. Ellen Z. Harrison, Summer Rayne Oakes, Matthew Hysell, Anthony Hay, Cornell Waste Management Institute, Department of Crop and Soil Sciences, Ithaca, NY and Cornell University, Department of Microbiology and Institute for Comparative and Environmental Toxicology, Ithaca, NY, 2006

Rainfall-Runoff of Anthropogenic Waste Indicators from Agricultural Fields Applied with Municipal Biosolids. National Water Quality Laboratory, U.S. Geological Survey, Denver, Federal Center, Denver, Colorado, 2016

Review of ‘emerging’ organic contaminants in biosolids and assessment of international research priorities for the agricultural use of biosolids. Bradley O. Clarke, Stephen R. Smith, Department of Civil and Environmental Engineering, South Kensington Campus, Imperial College London, London, SW7 2AZ, United Kingdom, June 9, 2010

Scientists’ open letter on the dangers of biosolids, Letter to the Editor of the Hamilton Spectator, Hamilton, Ontario by Sierra Rayne, PhD, John Werring, MSc, RPBio, Richard Honour, PhD, Steven R. Vincent, PhD. Sierra Rayne is an independent scientist; John Werring is a senior science and policy adviser for the David Suzuki Foundation; Richard Honour is the executive director for The Precautionary Group; Steven R. Vincent is the Louise Brown Professor of Neuroscience with the department of psychiatry at the University of British Columbia.

Sewage Biosolids Land Application Reported Health Incidents

Sewage Sludge, Humanure and Biosolids – The Dangers of Sewage Sludge, Water Technology Engineering Ltd.

We Should Expect More out of Our Sewage Sludge, Jordan Peccia and Paul Westerhoff, Department of Chemical and Environmental Engineering, Yale University and School of Sustainable Engineering and The Built Environment, Arizona State University, respectively.

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Sludge Permit Applications

Site Specific Land Application Plan for Rosman Farms Unit (SSLAP). 7-16-2013 (Withdrawn)

Site Specific Land Application Plan for Rosman Farms Unit (SSLAP). 9-23-2016 (As submitted)

Final, approved Site Specific Land Application Plan for Rosman Farms Unit (SSLAP). 12-13-2017

Community Comments

Don Hanson’s comments. 7-27-2016

Community Committee of Concerned Residents and Landowners in Green Canyon and Mill Canyon Letter to Washington State Department of Ecology. 9-23-2016

Marie Brito’s’s statement. 10-12-2016

Sierra Club Comments re: Permit BT 9902, Fire Mountain Farms Application to spread sewage sludge on Rosman Farm in Lincoln County. 10-26-2016

Comments by Corrina Barrett Regarding Rosman Farms Biosolids Application. 10-27-2016

Ernie Barrett’s biosolids management letter. 10-27-2016

Morton Alexander’s Testimony to Ecology hearing. 10-27-2016

Statement of Laura Harris re March 2014 Mill Canyon Flood. 10-27-2016

Morton Alexander & Ernest Barrett Comments on FMF-Rosman Site Specific Land Application Plan Proposal (SLAPP). 10-31-2016

Carla Martinez Biosolids Letter. 10-31-16

Stash Jackowski Bio-solids Testimony. 10-31-2016

Tim Pellow Comments on FMF-Rosman Site Specific Land Application Plan Proposal (SLAPP). 10-31-2016

Department of Ecology’s Response to Comments – Public Hearing for Fire Mountain Farms/Rosman Unit Application for Coverage Under the General Permit for Biosolids Management, Hearing Held October 11, 2016 at the Lincoln County Courthouse Davenport, Washington

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Map of Threatened Mill Canyon Watershed

Map of Mill Canyon Showing Location of Tolstoy Farms, a Certified Organic Farm.

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Protect Mill Canyon Watershed ‘In the News’

PMCW Press Release: Citizens’ Group Reports Victory in Battle Against Sewage Sludge, issued Dec. 19, 2017.

A Small Committee of Lincoln County Neighbors Goes Up Against the Waste-Industrial Complex of Sewage Sludge Slingers, Nature’s Advocate, a publication of the Upper Columbia River Group, a Sierra Club chapter, Fall 2017, page 1.

Sewage Sludge Threatens Mill Canyon Aquifer and Organic Farms, The Crest, Washington State Sierra Club Journal, Volume 36, Issue 3, Pg. 11 – Fall 2017

Guest Opinion: Keep Sewage Sludge Off Farmland, Morton Alexander and Chrys Ostrander, Spokesman Review, October 14, 2017.

Lincoln County residents fight biosolids on nearby farm by Jim Camden, Spokesman Review, September 27, 2017

Making a Stink By Samantha Wohlfeil, The Pacific Northwest Inlander, Sept. 21, 2017

Letter to Inlander Editor From Committee Member Morton Alexander

WA group starts campaign to stop use of biosolids on ag land by Matthew Weaver, Capital Press, September 7, 2017

Press Release: Citizen Committee Opposed to Dumping of Sewage Sludge on Agricultural Land Calls for Statewide Moratorium on Permits to Spread Sewage Sludge on Agricultural Lands. Issued Sept. 6, 2017.

PMCW Press Release: “Protect Mill Canyon Watershed,” a citizen committee opposed to dumping of sewage sludge on agricultural land, calls press conference for Wednesday, Sept. 6 at 3pm at Department of Ecology Building in Spokane. Major announcement regarding the Department and sewage sludge is scheduled. Issued Sept. 3, 2017.

Mill Canyon residents organize to protect air and water, The Fig Tree, Vol. 34, No. 7, Sept., 2017

Ecology: No threat in biosolid use on ag lands, Capital Press, August 14, 2017

Spokane Public Radio News, Aug. 10, 2017 (mp3 audio file)

Committee forms to ‘protect’ Mill Canyon area from application of bio-solids in grain fields, Davenport Times, Aug. 10, 2017.

KYRS Spokane, Earth Matters Now, Aug. 8, 2017 (mp3 audio file)

PMCW Press Release: Municipal sewage sludge threatens residents in rural eastern Washington, Issued August 8, 2017

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Other Media

Biosolids: mix human waste with toxic chemicals, then spread on crops, The Guardian, Oct. 2019.

“Sewage sludge … it’s what Sierra Club environmentalist Nancy Raine calls ‘the most pollutant-rich man-made substance on Earth’”.

“The waste management industry [says it] treats sludge in several ways before labeling it fertilizer – air drying, pasteurization and composting are among common methods. Lime is employed to raise the pH level to eliminate odors, and about 95% of pathogens, viruses and other organisms are killed in the process.”

“’It has a technical song that sounds pretty good. However, nothing that is done to the sludge removes the chemicals,’ Raine said. ‘They just spend a little money on PR to convince us it’s nice fertilizer and fail to mention all the other things that are in it.’”

KING 5 TV Investigation: Grounds for Concern – Human Waste Being Used In Fertilizer In Washington State. 11-21-2000

Video: Crapshoot – The Gamble with our Wastes, directed by Jeff McKay. (Film: National Film Board of Canada)

Biosolids hit the fan, Sound Consumer, March 2012

How EPA Faked the Entire Science of Sewage Sludge Safety: A Whistleblower’s Story, Independent Science News, June 9, 2014

It’s Time to Talk (Again) about Sewage Sludge on Farmland, In These Times magazine, July 11, 2017.

The problem with biosolids, Opinion Piece, Capital Press, August 16, 2017

Wisconsin case shows how sewage plants spread unregulated toxins across landscape
Steven Verburg
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…”

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Sewage Sludge Action Network

Ecology grants Webb Hill facility final coverage, grace period. Arla Shephard Bull, Mason County Life, published Nov. 6, 2017

       Additional conditions and final coverage issuance to Bio Recycling Corporation (Bio Recycling) Biosolids North Ranch General Permit Coverage. Washington State Department of Ecology Waste 2 Resources Program, Oct. 24, 2017.

It is unfortunate that the Dept. of Ecology has decided not to honor the call for a statewide moratorium on further sewage sludge land application permits made by Protect Mill Canyon Watershed and hundreds of our supporters around the state. On Oct. 24 , Ecology instead granted a permit to Bio Recycling Corporation, a very troubled sludge application company in Centralia, WA. Some of the groundwater in fields where Bio Recycling has been dumping sludge for years have reached unsafe levels of nitrate contamination. The company has inadequate storage facilities and has been told to bring them into compliance or curtail operations. Neighbors of the sludge facility are very concerned. This article from Mason County Life, published on Nov. 6, describes the issues involved. Here’s a quote from a concerned neighbor from the article: “‘This was an ill-conceived idea from the very beginning with applying toxic things into the ground,’ said Union resident Pat Vandehey at the March hearing. ‘They never thought about what happens when it’s reached a saturation point and they’re not going to be able to put it on anymore. Something has to be done at that point, but nobody seems to look ahead to the future.’”

Below the link to the article is a link to a copy of the permit Ecology granted. The permit includes numerous “conditions” that belie a history of poor management practices on the part of Bio Recycling. These “conditions” also expose how high risk the practice of dumping sewage sludge is that it requires such complex rules and conditions, further eroding the validity of Ecology’s assertions that dumping sewage sludge on agricultural land is safe. It should be noted that Ecology is, in this permit, mainly concerned with one pollutant contaminant, nitrates, out of the hundreds of pollutant contaminants know to occur in sewage sludge (Ecology only monitors 10 contaminants– nitrogen and nine heavy metals, which Protect Mill Canyon Watershed asserts is dangerously inadequate oversight).

With the issuance of this permit, defenders of a clean, safe environment need to redouble our efforts calling for a sludge moratorium and end sewage sludge dumping on ag land once and for all.

Video of the March 5, 2014 Mill Canyon flood can be viewed at

Sewage Sludge Information Web Page, Center for Food Safety

Gardening Answers Knowledgebase record #760, University of Washington Botanic Gardens, Elizabeth C. Miller Library, University of Washington School of Environmental and Forest Sciences, College of the Environment,
Q: “I noticed at the Flower and Garden Show that King County Master Gardeners were giving away samples of biosolids for use in the garden. Is sewage sludge really safe? Is it acceptable if you garden organically?”
A: (excerpt) “The short answer is that there is some uncertainty about the safety of using biosolids in the garden, and if you are attempting to garden organically, it may be best to avoid using them.” See page for details.

Sewage Sludge is Sold as Compost for Food & Gardening – What Are the Hidden Dangers? Northwest Toxic Communities Coalition (NWTCC), 2014.

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Ecology’s foot-dragging is entirely unjustified when it comes to testing for PFAS.  There is PLENTY of data on PFAS, many testing methodologies. Expand the following to see just a Sampling of articles and studies about PFAS from the Interstate Technology and Regulatory Council, a project of the Environmental Council of the States (ECOS) which works to improve the capability of state environmental agencies and their leaders to protect and improve human health and the environment of the United States of America. ECOS is the national nonprofit, nonpartisan association of state and territorial environmental agency leaders. The Washington State Department of Ecology is an official member of ECOS! To claim ignorance in the face of this avalanche of data is utterly disingenuous. Ecology claims they “are tracking information regarding biosolids work happening elsewhere” (such as what is referred to below) and yet they seem prepared to ignore what they find and instead are asking the public to provide documentation along with their public comments to back up our assertion that biosolids are too dangerous to be allowed to be land-applied. Ecology will suffer a reckoning someday for its malfeasance on this issue unless it abandons its blind conformity with an obviously unjustifiable legislative mandate to promote biosolids’ “beneficial use.” And be sure to remember, PFAS is just one family of toxic pollutants found in sewage sludge. There are hundreds more that are present and completely unregulated.

Sampling of articles and studies about PFAS (Open)

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It is the intention of ITRC to periodically update the document as significant new information and regulatory approaches for PFAS develop. The guidance document …
pfas-1.itrcweb.org › fact-sheets
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PFAS Fact Sheets. This page includes links for the ITRC PFAS fact sheets. The fact sheets are available as PDF files. Several tables of supporting information …
pfas-1.itrcweb.org › 2-2-chemistry-terminology-and-acronyms
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PFAS are characterized by carbon atoms that are linked together with fluorine atoms attached to the carbons. A more specific and technical definition of PFAS …
pfas-1.itrcweb.org › 1-introduction
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Per- and polyfluoroalkyl substances (PFAS) are a very large family of thousands of chemicals that vary widely in their chemical and physical properties, as well …
pfas-1.itrcweb.org › 2-pfas-chemistry-and-naming-conventions-history-an…
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The PFAS Team developed two training module videos with content related to … and chemical properties of PFAS impart oil, water, stain, and soil repellency, …
pfas-1.itrcweb.org › 5-environmental-fate-and-transport-processes
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PFAS fate and transport describes the behavior of these compounds following their release to the environment. This includes the physical, chemical, and biological …
pfas-1.itrcweb.org › PFAS_Fact_Sheet_Naming_Conventions_April2020
File Format: PDF/Adobe Acrobat
1 Introduction. The following topics are covered in this fact sheet: • Polymer vs. Nonpolymer PFAS. • Perfluoroalkyl substances. • Polyfluoroalkyl substances.
pfas-1.itrcweb.org › 11-sampling-and-analytical-methods
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Sampling conducted to determine PFAS concentrations in water, soil, sediment, air, biota, and other media is similar to that for other chemical compounds, but with …
pfas-1.itrcweb.org › 12-treatment-technologies
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State of Development: GAC is an established water treatment technology proven to effectively treat long-chain PFAS (such as PFOS, PFOA, and PFNA). The …
pfas-1.itrcweb.org › 6-media-specific-occurrence
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This section focuses on occurrence in air, soil and sediment, groundwater, surface water, and biota. PFAS occurrence in several media types is an active area of …
pfas-1.itrcweb.org › 14-risk-communication
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Additional human health and exposure factors that heighten risk perception for PFAS are summarized in Section 14.2, Risk Communication Challenges. This …
pfas-1.itrcweb.org › 3-firefighting-foams
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AFFF is a highly effective type of Class B foam that is especially effective on large liquid fuel fires. AFFF is of particular concern because it contains PFAS. As …
pfas-1.itrcweb.org › PFAS_Fact_Sheet_History_and_Use_April2020
File Format: PDF/Adobe Acrobat
Certain PFAS, most notably some of the perfluoroalkyl acids (PFAAs), such as perfluorooctanoate (PFOA) and perfluorooctane sulfonate (PFOS), are mobile, …
pfas-1.itrcweb.org › 2-5-pfas-uses
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The unique physical and chemical properties of PFAS impart oil, water, stain, and soil repellency, chemical and temperature resistance, friction reduction, and …
pfas-1.itrcweb.org › 13-stakeholder-perspectives
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PFAS — Per- and Polyfluoroalkyl Substances … PFAS, including PFOA and PFOS, have been detected in biosolids produced at a wastewater treatment plant  …
pfas-1.itrcweb.org › 2-6-pfas-releases-to-the-environment
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industrial facilities that produce PFAS or process PFAS, or facilities that use PFAS chemicals or products in manufacturing or other activities (Section 2.6.1); areas …
pfas-1.itrcweb.org › 2-3-emerging-health-and-environmental-concerns
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PFAS — Per- and Polyfluoroalkyl Substances. HOME … Like other emerging contaminants, knowledge and concern about PFAS in the environment has evolved …
pfas-1.itrcweb.org › pfas_fact_sheet_remediation_3_15_18
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File Format: PDF/Adobe Acrobat
Certain PFAS have recently been the subject of regulatory actions and attempted soil, sediment, and water remediation. These compounds have unique chemical  …
pfas-1.itrcweb.org › 4-physical-and-chemical-properties
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Apr 14, 2020  For an individual PFAS compound (or mixture of PFAS) that exists as a liquid at ambient temperatures, density can influence its behavior in the …
pfas-1.itrcweb.org › uploads › 2020/04 › ITRC_PFAS_TechReg_April2020
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File Format: PDF/Adobe Acrobat
Apr 1, 2020  Substances (PFAS). Technical/Regulatory Guidance. April 2020. Prepared by. The Interstate Technology & Regulatory Council (ITRC).
pfas-1.itrcweb.org › 2-4-pfas-reductions-and-alternative-pfas-formulations
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1 3M Voluntary Phaseout of Certain Long-Chain PFAS. In early 2000, 3M was the principal worldwide manufacturer of PFOA and POSF-derived PFAS (for …
pfas-1.itrcweb.org › 10-site-characterization
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There are also “secondary sources,” such as PFAS concentrating into one portion of a plume (for example, groundwater into surface water) that then acts as a …
pfas-1.itrcweb.org › 7-human-and-ecological-health-effects-of-select-pfas
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The best studied PFAAs are PFOS and PFOA, although considerable information is available for some other PFAS, including PFNA, PFHxS, PFBA, PFBS, and the  …
pfas-1.itrcweb.org › 9-site-risk-assessment
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For PFAS chemicals as of September 2019: Tier 1 values are peer-reviewed toxicity values published on the USEPA’s Integrated Risk Information System ( IRIS).
pfas-1.itrcweb.org › 8-basis-of-regulations
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Providing blood testing for PFAS for all DOD firefighters during their annual physical exam; Ensuring that no water contaminated with PFOA or PFOS above …
pfas-1.itrcweb.org › acronyms
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PFA, perfluoroalkoxy polymer. PFAA, perfluoroalkyl acid. PFAI, perfluoroalkyl iodides. PFAS, per- and polyfluoroalkyl substances. PFBA, perfluorobutanoate …
pfas-1.itrcweb.org › 17-additional-information
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Data presented include PFAS concentrations in water and particle phases. Water maximum: PFHxS: 281; PFOS: 2,920; PFHxA: 757; PFHpA: 277; PFOA: 767 …
pfas-1.itrcweb.org › 15-case-studies
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presented a detailed characterization of a subset of PFAS soil and groundwater concentrations, focused on PFAAs in the vicinity of a former unlined burn pit where …
pfas-1.itrcweb.org › PFAS_Fact_Sheet_Regulations_April2020
File Format: PDF/Adobe Acrobat
1. Regulations, Guidance, and Advisories for Per- and Polyfluoroalkyl Substances (PFAS). ITRC has developed a series of fact sheets to summarize the latest …
pfas-1.itrcweb.org › acknowledgements
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The PFAS Team was led by: Bob Mueller, New Jersey Department of Environmental Protection and Ginny Yingling, Minnesota Department of Health. The team …

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The WA Department of Ecology would do well to consider what the state of Wisconsin is doing to address the issue of PFAS and other toxins in sewage sludge and get similar testing programs going in our own state ASAP. Obviously, when a state like Wisconsin gets wind of what’s happening to dairy farms in Maine… Well, you get the picture. When will the Washington Department of Ecology begin to take the issue seriously?

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A couple of canyon-loving kids. Our children are the most vulnerable to pollution from the sludge.

Protect Mill Canyon Watershed
We are an informal committee of Mill Canyon residents. You can contact us using the following form. We look forward to hearing from you.

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