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 … › 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 … › 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 … › 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 … › 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, … › 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_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. › 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 … › 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 … › 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 … › 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 … › 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_Fact_Sheet_History_and_Use_April2020
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Certain PFAS, most notably some of the perfluoroalkyl acids (PFAAs), such as perfluorooctanoate (PFOA) and perfluorooctane sulfonate (PFOS), are mobile, … › 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 … › 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  … › 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 … › 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_fact_sheet_remediation_3_15_18
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Certain PFAS have recently been the subject of regulatory actions and attempted soil, sediment, and water remediation. These compounds have unique chemical  … › 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 … › uploads › 2020/04 › ITRC_PFAS_TechReg_April2020
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Apr 1, 2020  Substances (PFAS). Technical/Regulatory Guidance. April 2020. Prepared by. The Interstate Technology & Regulatory Council (ITRC). › 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 … › 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 … › 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  … › 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). › 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 … › acronyms
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PFA, perfluoroalkoxy polymer. PFAA, perfluoroalkyl acid. PFAI, perfluoroalkyl iodides. PFAS, per- and polyfluoroalkyl substances. PFBA, perfluorobutanoate … › 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 … › 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_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 … › 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?