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BIOSOLIDS

:

A CASE
FOR

CAUTIO,ru
Prepared for the PEC Environmenta! Advisory Committee
By

Sandra Latchford Councillor, PEC
Feb. 4, 2O0B

Household Biosolids - Yesterday and Today
The Biosolids generated today are significantly different from those generated even twenty and thirty years ago. Since L945, thousands of chemicals (pharmaceuticals, cleaning products, personal care products, flame retardants, etc) have been introduced into and embraced by North American's; the products we use every day in our homes, the food that we eat, the clothes that we wear and the medications that we take. These chemicals are washed and flushed into our waste water treatment plants. Yet, surprisingly, despite the dramatic changes in what we wash and flush, there has been a remarkably slow response to chaft and respond to those changes.

What is new in household biosodlids?
Toxic cleaning products - As society has become increasing conscious about being "clean", the variety and potency of household cleaning products has increased dramatically. The average household disposes into waste water 15 - 40 kilograms of toxic cleaning products each year. Personal care products - The goal for cleanliness extends to personal care with many new shampoos and soaps which contain surfactants such as triclosan ( Triclosan has been described as an emerging contaminant by Dr. Edward Topp a speaker at the WEAO seminar in London, ON, Dec, L2, 2OO7). Pharmaceuticals - Medicines, both prescription and over the counter medications, are being used at unprecedented levels by people of all ages. And indications are that usage levels will increase as the population ages. Flame retardants - These chemicals have been linked to health problems in people and house cats (hypefthyroidism) and two of the three most commonly used flame retardants have been removed from use. Pathogens - Over the last twenty years antibiotic resistant bacteria (i.e. MRSA and others) have become a major concern for all health care facilities (hospitals, and nursing homes).

Compared to animaUchicken manure
Animal manure does contain pathogens (E.coli) but not in the concentration nor variety that is present in biosolids. Also, animal manure does not contain

the chemical cocktail (cteaning compounds, pharmaceuticals etc.) that is present in household biosolids.

Ministry of Environment (MOE)

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MOE Regulations and Guidelines

The MOE generates regulations and guidelines for testing, transporting, storing and spreading of biosolids on farmland. It also carries the responsibility for enforcing the regulations.
Biosolids are routinely tested for: Pathogens - sPecificallY e-coli Nitrogen Phosphates Metals - for example; mercury, cadmium, lead [Funans & dioxins were monitored in the past and found to be

very low.l

Research has been done on the items listed above which has lead to the generation of regulations and guidelines for the transporting and spreading of biosoilds. HOWEVER
MOE does NOT routinely test biosolids for:

* * * * * *

Pharmaceuticals [use of over the counter and prescription medications has increased dramatically over the last 20 years.l Personal care products - i.e. Triclosan Toxic chemicals from household cleaning products Pathogens such as MRSA and others Flame retardants (PBDE) PCDDs (Polychlorinated dibenzo-p-dioxins) and PCDFs (polych lorinated dibenzeofu ra ns)

This is a very short list of the thousands of organic chemicals that are currently in use and enter waste treatment plants.
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MOE ENFORCEMENT

The MOE has the authority to enforce their regulations but concerns have been raised that they do not have sufficient front line personnel to carry out their mandate. At the seminar in London, Mr. Larry Schill, a farmer who spoke about his experiences with spreading biosolids on his property, indicated that he had no complaints about MOE enforcement. However, another farmer in the audience recounted the problems that he had experienced with MOE enforcement. Included in this report is a copy of an afticle "The Scugog Township Incident" which appeared in Better Farming, Oct. 2007. The article recounts a biosolids spill in Scugog Township.
Policies, regulations, and guidelines are written based on current knowledge and are usually generated with good intentions. However, there is often a huge disconnect between what "should be" and what "actually happens." Enforcement of the regulations requires funding to hire enough trained inspectors to do the job required.

Complex Problems

dont have

Simple Answers

But the questions must still be asked.

QUESTTONS, QUESTTONS, QUESTTONS ????????

It

is the questions that MOE can't answer that are a major concern to me.

What organic chemicals (pharmaceuticals, flame retardants etc.) and pathogens are in biosolids?
Have you and are you chafting the change in the amount and types of organic chemicals and pathogens in biosolids?

European countries have been testing biosolids for organic chemicals so why aren't we?

.

If you don't know at what level organic chemicals occur in biosolids,
how can you say theY aren't a Problem? When these chemicals mix with each other do they interact to form other compounds? When they degrade do they break down into harmless products or do they degrade into more harmful products?

What are the degradation rates and profiles of the chemicatslpharmaceuticals, etc. after they are applied to land?

* *

How long do organic chemicals persist in the soil?

Are organic chemicals taken up by plants? If so, do they persist intact in the plants to re-enter the human food chain?

How can MOE establish regulations and guidelines for organic chemicals that are in unknown quantities, have unknown degradation rates in soil and have unknown uptake characteristics in plants grown in that soil?

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..Absence of evidence is not evidence of absence." Dr. Ellen Z. Harrison Director Cornell Waste Management Institute (CWMI)

RESEARCH

- ORGANIC CHEMICALS IN BIOSOLIDS

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The article "Organic Ghemicals in Sewage Sludges"'by Harrison' Oakes, Hysell-& Hay, Science of the Total Environment 367

(2OO6i: igt-4;gl articulates many of the concerns' [The article ils attathed in full at the end of this repott'l

The following are some points made by the authors in this article.

* * {.

.. More data are needed on chemicals that are in sludges today and on the temporal trends for those chemicals. Relying on existing lists of. of chemicals such as priority pollutants will not identify many chemicals current concern." P. 496
..Few data exist on the fate of sludge-borne chemicals in field soils and such research is critical to assessing the risks posed by sludge

application." P.496 "Degradation is an important component of loss, but may be incomplete or slow, even for relatively easily degraded chemicals such as linear alkyl benzene sulfonates(LAS). LAS is present at such high concentrations in sludges (up to 3olo by weight) that incomplete degradation coupleO witn repeated application could result in consistently elevated I-1AS concentration in soils. This was demonstraied in one study that detected over 10mg/kg six years after land application of sludge. Importantty, no further decrease was found after two more years, indicating that the residual LAS was resistant to degradation (Carlson et al.,2OO2 in Harrison, Oakes, Hysell &Hay' 2006)." P.496
..Evatuating the risks posed by individual chemicals, let alone mixtures requires mirttipte assumptions that can lead to unacceptably high levels of uncertaintY." P. 496

*

"Current limitations in our knowledge base regarding the amount and type of chemicals in sludges exacerbate this problern, as does the limited availability of fate and toxicity data, for both human and nonhuman receptors ." p,496

II

Another article of interest appears in the Cornell Univercity Breast Cancer Newsletter, Vol.12 Issue 4, Fall 2OO7.In this article, Dr. Anthony Hay and Dr. Ellen Harrison are interviewed about contaminants in Sewage Sludge. [A copy of this afticle is

included in this report.l

In this interview, both Dr. Hay and Dr. Harrison continue to express their concerns about the unknowns that surround biosolids.

Dr. Hay notes:
deodorants, toothpaste and many other productsl was found in all samples of sludge in quite high concentrations.... We are seeing triclosan increasingly in environmental samples. ... in fish, and in high concentrations in breast milk. Triclosan is an inhibitor of the enzymes that are involved in cleaning out other pollutants from our body; paft of phase-2 metabolism."

" Triclosan [a biocide widely used in antibacterial hand soaps,

III

A fufther note on surfactants, appears in

"Science, Risk, Public Perception, and Precaution," Environmental Science & Engineering, March, 2OO4.
Dr. Hans Sanderson repofts that Nonylphenol (a non-ionic surfactant) in soaps and detergent was phased out in Denmark in 2000. Because of a lack of scientific certainty relating to the human and witdlife effects it may have through mimicking estrogen.

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At the London seminar, Dr. Ed Topp reported on research which is expected to be published in the spring of 2008. His power point presentation titled "Fate of pharmaceuticals and personal care

products following land application of tiquid municipal biosolids." is available at
http : //www. weao. orglcom
m

ittees/biosol ids/biosol ids. htm

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Dr, Topp and nine colleagues are compiling data collected on a selected group of pharmaceuticals and organic chemicals. They are looking at their occurrence levels in biosolids, and after spread.ing on land their presence and persistence in run off water and soil as well as their rate of degradation. Some of the products being investigated in this study are:acetaminophen, naproxen, ibuprofen, gemfibrozol, atenolol, cotinine, carbamazepine, fluoxetine, sulfapyridine, sulfamethoxazole, and triclosan.

Quotes from Dr. Topp's presentation:
'*overall, the issue of these chemicals as "emerging contaminants" is at a "definition of problem" stage". "As risk [exposure X hazard] for "emerging contaminants"is better defined, regulatory action may be taken."

"Just like the rest of us, scientists get comfortabre with doing things the way they always have, even when arguments arrive suggesting that change has to happen.,,
Dr. D. Davis Director of the Center for Environmental Oncology, University of Pittsburgh Cancer Institute, (2OO7) p.295

Standards - Parts Per Million (ppm)
Standards for exposure to metals and chemicals are not cast in stone. In fact, some PPms are moving targets. The ppm for lead for example has been lowered at least twice since it was first established and the Center for Disease Control is now suggesting that it be lowered further to 0-1 ppm. So, what was thought to be a "safe" exposure may in fact turn out not to be safe in the future. Once people, wildlife and the environment are exposed to metals/chemicals the harm is done and may be irreversible.

LIABILIW . MUNICIPALIW AND/OR

LAND OWNER

Questions have also arisen as to who carries the liability when biosolids are spread on land. Mr. Schill, the, farmer who spoke at the London seminar indicated that he was considering, in the future, of asking the nnunicipality to assume the liability as a condition for agreeing to accept biosolids. It appears that the insurance coverage for farms covers accidents related to normal farm practices but no coverage related to the application of biosolids.

Who is liable:

. . .

if neighbours proceed with litigation? if wetlands, creeks and streams are compromised? if in ten years we realized that the farmland is contaminated?

Who will pay: . to compensate the land owner? * . the neighbours? . to clean uP the land?
report.l

* [Newspaper article from the Globe and Mail, Jan.25/08

included in this

Will the municipality be asked to pay for liability insurance for the land owner/farmer who agrees to accept biosolids? If such insurance is available. Will the municipality cover the legal costs of the land owner/farmer who has claims made against them?

"When yesterday's "triumph of modern chemistry" turns out instead to be today's deadly threat to the global environment, it is legitimate to ask what else we don't know."
Denis Hayes in Davis (2OO7) P.391

A Case for Caution
Why be cautious?

1.

we don't know the types of contaminants in biosolids. we don't know the concentration of the contaminants Although levels of metals and E.coli in biosolids have been well studied it is the information that we don't have that should give us pause. We do not know what organic chemicals and pharmaceuticals occur in biosolids, nor the quantity in which they occur nor how those chemicals react and degrade in soil. Once we know that information it may be possible to set standards that will reduce their risk to humans, wildlife and the environment. (Topp, 2008).

very limited

Our ability to confidently predict risks from land applications is

. o

2.

Our present standards are based on a risk assessment with many shortcomings . the tools to test for contaminants are still underdevelopment limits of detection are insensitive n funding for independent studies and for long term studies is
inadequate.

3. 4. 5.

Enforcement and monitoring are spotty.
The health concerns that have been raised by neighbours around land that has received biosolids are still under

investigation.

More and more of the public are becoming reluctant to be exposed to the risks of biosolids and want an alternate solution found. The public are not "uneducated" nor "paianoid" but neither are they naive nor gullible. Past experience has shown that when scientists don't agree then we need to be wary. "Well known" researchers touted the safety of smoking (backed by million dollar ad campaigns), asbestos, dioxins, lead, the radiation emitted during nuclear testing in the fifties, and industrial chemicals such as benzene. Yet, the passage of time and the deaths of many people have proven them wrong. Public trust has been eroded.

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Where Do We Go From Here?
We need to exclude the spreading of biosolids as an option and refocus our time and energy on short and long term solutions that are environmentally
safe.

If land spreading is ruled out, what other options do we have?
Unfortunately, alternatives to land application were not presented at the London seminar.
Possible

short term alternatives:

1. 2.
Possible

Placement in an approved land fill site. [Matt Tracey estimates that the cost for sending biosolids to landfill is 14 cents per gallon compared to 2 cents per gallon to spread on land.l

Incineration.

long term solutions:

1.

Combine with compost material gathered in the municipality and make into biofuel - which could sell for $40lcu.yd. *I should note that the province does not encourage biosolids being included in regular composting programs because of the levels of heavy metals etc. Ontario has high standards for compost that is to be sold for garden use. Gasification. This is a process that gasifies garbage, dewatered sludge, tires etc. turning it into syn gas which is cleaned and then burned to generate electricity. [Gasification is also an alternative to using land fill sites for garbage.l

2.

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Sources Afticles
Cornell Faculty Address Contaminats in Sewage Sludgesl The Ribbon Interviews Dr. Anthony Hay and Ellen Harrison. Vol.12 Issue 4, Fall2oo7. ews I ette r] I Co rn e t I lJ n i ve rs ity B rea st Ca n ce r N
Glaser A.,

"The ubiquitous Triclosan." Pesticides and You.Yol' 24, No.3, 2004'

Harrison, Oakes, Hysell & Hay,"Organic Chemicals of the Tatat Environment 367 (2006): 48t-497.

in Sewage Sludges"'

Science

Kepner J., "Triclosan Hazards....Continued." Pesticides and You. Yol, 24, No. 4, 2004-2005. Krogmann U. & Boyles L., "Land Application of Sludge (Biosolids) #7= Organic Coritaminants." Rutgers Cooperative Research & Extension Fact Sheet, 1999.

..Ontario,s Waste Management Challenge- fs fncineration an Option?" A repoft produced by the Canadian Institute fro Environmental Law and Policy
(CIELAP), March 2A07.

Polybrominated diphenyl ethers in an Advanced WaStewater Treatment Plant. Paft 1; Concentrations, Patterns, and Influence of Treatment Processes. Journal of Environmental Engineering and Science a(5): 353-367 (2005).
Rayne Sierra, & Ikonomou G.,

Selvaratnam S. & Kunberger D.1., "Increased Frequency of Drug-Resistant Bacteria and Fecal colifbrms in an Indiana Creek Adjacent to Farmland Amended with Treated Sludge." Canadian Journal of Microbiology 5O(8): 6536s6 (2004). Sandersor H., "Science, Risk, PubliC PerceptiOn, and Precautionr" Environmental Science & Engineering , March, 2OO4.

*Sewage Biosolids Land Applicationr Reported Health Incidents." Cornell Waste Management Institute http ://cwmi.css.cornell.edu/
Books
Devra Davis, The Secret History Books, 2OO7).

of the War on Cancer. (New York:

Basic

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Press Afticles

"Too many unknowns - interview with Ellen Harrison.- Ontario Farmer,
December 2OA7.

"Farmer wants to see any biosolids liability resting with nrnunicipality.Ontario Farmer, December
ZOOZ.

"The scugog Township rncident," Better Farming, october, zao7.

Judicial ProceeCinos
supreme court case spraytech v.'Hudson (Town), [2ooll s,c.J. No.42. The supreme court upheld a municiparity's ban on the uiebf pesticides.

Web Sites
Beyond Pesticides http : //bevondpesticides. org Cornell Waste Management Institute http : //cwmi.css.cornell.edu/ Cornell University Breast Cancer Newsletter http : //envirocancer. cornell. edu/ http,' r"nui ro.u n.u...orn"l l. r/N "d Environment Canada

"*rl"tt".

ru.ti.l.,

National Research Council of Canada http : //n rc-cn rc.qc. ca

Water Environment Association of Ontario

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