By Scott J. Crossen, May, 2012
Welcome to rural America, where people travel from afar to absorb the vistas, views and fresh fragrances of wide-open spaces. This is country life and the air is filled with the aroma of hay, wildflowers, livestock fertilizer and … sewage sludge. Sewage sludge? Yes, otherwise known as biosolids.
In the spring and fall, perhaps while running, biking or driving down a county road, you’ve noticed unmarked tanker trucks rolling through fields or smelled what they’re spewing. It’s the distinct smell of human sewage mixed with the stench of ammonia. It’s not the good old fashioned traditional smell of cow and horse manure – it’s different and it carries a lot of controversy along with the offensive odor.
The Harpers Collins Dictionary of Environmental Sciences defines biosolids/sewage sludge as “a viscous, semisolid mixture of bacteria- and virus-laden organic matter, toxic metals, synthetic organic chemicals, and settled solids removed from domestic and industrial waste water at a sewage treatment plant.” (The term biosolids is a crafty public relations euphemism the EPA and sewage waste water industry uses in place of sewage sludge).
Sewage sludge contents and health effects
The amount of chemicals, toxins, heavy metals, pollutants, pathogens, viruses, pharmaceuticals, steroids, and hormones found in sewage sludge is too numerous to list. The same can be said for the total number of potential negative health effects from sewage sludge contaminates. But, to provide an example, here’s a partial listing from Cornell Waste Management Institute’s report, Clustering of Reported Health Incidents from land application of sewage sludge, 2009, asthma, allergies, birth complications, congenital defects, respiratory complications and failure, eye problems, gastrointestinal complications, inflammation of the lungs due to irritation caused by the inhalation of dust, alterations in pulmonary function, chronic bronchitis, chronic emphysema, inactive tuberculosis, cardiovascular effects (increased blood pressure, altered EKG readings and heart muscle damage), headaches, lesions, skin rashes, nausea, nosebleeds, tumors, vomiting, fatigue and the list continues.
According to EPA’s Targeted National Sewage Sludge Survey , 2009, EPA found “all sewage sludge  contains toxic and hazardous materials, including large numbers of endocrine disruptors.” In the 2009 studies, EPA concluded “dozens of hazardous materials, not regulated and not required to be tested for, have been documented in each and every one of the sludge samples EPA took around the USA.” However, EPA determined that many of these potentially hazardous materials are not a threat to human health.
Here’s the catch, EPA’s position that toxic and hazardous materials found in sewage sludge do not pose a threat to human health was not determined through a series of exhaustive studies. On the contrary, it is the result of EPA lacking sufficient data to perform and complete tests. EPA’s Biosolid Biennial Review, March, 2012, states “Even though critical pieces of data (e.g., human health toxicity and concentration data) were available for 14 pollutants” (there are literally thousands), “critical information gaps remain (e.g., ecological effects endpoints, aerobic biodegradation in soil and water, anaerobic biodegradation in sediment, bioconcentration, and biotransfer factors). Therefore, at this time EPA has not identified any additional toxic pollutants for regulation under Section 405(d)(2)(C) of the CWA.” This doesn’t mean that there aren’t significant public health risks; it only means EPA has not been able to officially identify any, yet.
Across America, considerable controversy has surfaced in the last 20 years on whether EPA regulations are sufficient to protect public health and the environment. Many reputable scientists and experts, outside the sewage sludge industry and their bed partners, believe EPA’s 503 regulation governing what is allowed in sewage sludge does not sufficiently protect public health.
In the Denver Post article, Stewing Over Sewage Sludge, Jeremy P. Meyer, 2007, Dr. Ellen Harrison, Professor of Natural Resources at Cornell University, states “Not enough is known about the chemicals in sewage biosolid. When you clean wastewater, some things are degraded and chewed up at the plant, some things pass through in the water, some things go into the air. The nastier things go into the sludge.” In this report Dr. Harrison adds “The application of (Class B) sewage sludge on agricultural lands should be banned immediately.” Note; Class B sewage sludge is the material applied to most agricultural acreage across our country.
Of considerable concern is the distance that sewage contaminates can travel and infect people. According to The Gatekeepers, Land Application of Sewage Sludge, 1997-2010, Hallman & Wingate, LLC, “It can be concluded that pathogenically non-treated Class B biosolids are capable of generating potential pathogens in the air. This increased content might be responsible for reported health problems in nearby residents during the post-application period. Also, there is a possibility that the finer particles, which constitute approximately 50% of the total bioaerosols generated from the fields, can be transported some distance away from the Class B biosolids-applied field. These finer particles containing pathogens might be responsible for health problems in residents a mile away from the field.”
Not all sewage sludge is created equal. Each state can impose regulations of what is acceptable. Colorado applies stricter standards than other states; however, there is still dispute on whether the requirements are sufficient to protect public health since EPA’s questionable 503 regulation is the standard.
Drs’ Harrison, McBride and Bouldin, from Cornell University’s Soil Crop and Atmospheric Research Department, further the concern of sewage sludge safety in their report, Land Application of Sewage Sludges: an appraisal of the US regulations, 1999, “Although the US EPA and others made a major effort in performing the risk assessment supporting the Part 503 regulations, the authors of this paper demonstrate that there are fundamental errors in the assessment structure, a number of untenable assumptions made, and serious omissions (whether due to oversights or data gaps), which result in regulations that are not sufficiently protective. A precautionary approach such as that adopted by a number of other nations is more appropriate given the uncertainties inherent in such a complex risk assessment, potential long-term impact on agricultural productivity and the difficulty of remediating any impacts resulting from soil contamination.”
When one considers the variables, variety, volume and nature of potentially toxic sewage sludge material, it is hard to imagine there could ever be any level of reasonable certainty.
“This is something that we need to be aware of,” states Edward Furlong, a Denver-based research chemist for the U.S. Geological Survey, in the Denver Post article, Stewing Over Sewage Sludge, April, 2007 “Half of the biosolids produced in the United States are land-applied,” Furlong said. “What it does at those levels, we don’t know.” It is important to note that the volume of sewage sludge applied to land is not incrementally measured in pounds; it’s measured in tons. According to United Sludge-Free Alliance, Kutztown, PA “Eight million tons of America’s sewage sludge is land applied on farms, parks, playgrounds, golf courses and sold to home gardeners as a bagged “fertilizer.”
One of the most prominent scientists opposed to land application of sewage sludge is Dr. David Lewis, Sr. Research Microbiologist, formerly with the EPA’s Office of Research and Development for 31 years. Dr. Lewis closely studied the effects of sewage sludge and concluded in his report, Odor Causing Gases Generated by Sludge, 1999, “Exposure to high concentrations of gaseous organic amine vapors (derivative of ammonia) from sewage sludge (which may occur at any application site) can cause severe irritation of the eyes and skin, damage to mucus membranes leading to pulmonary edema (bleeding in the respiratory system). These toxic gases can also cause damage to the lungs, liver, and other internal organs. Initial symptoms include eye irritation, skin rashes, burning in the mouth, nose, or throat, generation of mucus, headaches, nausea and vomiting. Such damaged tissues can serve as a port of entry for bacterial or viral pathogens, leading to flu-like infections, pneumonia, or bacteremia /septicaemia” (blood bacteria).
Dr. Lewis’ extensive research uncovered a host of serious risks associated with land application of sewage sludge. EPA officials who developed the agency’s sewage sludge regulations and policies pulled funding and shut down Dr. Lewis’ research efforts when he began publicizing accounts of illnesses and deaths linked to agricultural application of sewage sludge. Dr. Lewis was eventually terminated by the EPA when his opposition became too public.
Through the past 20 years, a heap of negative public health effects from the application of sewage sludge on agricultural land has surfaced – including deaths. From 1993, to the present day, no fewer than five documented deaths of individuals ranging in age from 11 to 65 occurred resulting from land application of Class B sewage sludge.
In 2002, a 382-page report, Sludge Victims: Voices From the Field, compiled by Helane Shields, of Alton, New Hampshire, provided published newspaper articles and investigative reports that describe the plight of rural residents who experienced serious health problems after having been exposed to land-applied sewage sludge. Ms. Shields and others who attempt to educate the public about sewage sludge are frequently subject to the irritation of local farmers and land owners who either willing or unwittingly fail to see the danger of sewage sludge application not only to the general population, but also to themselves.
For those unlucky enough to be downwind from the spread of sludge, the effects are especially bad. Aside from the offensive odor, which can linger for many weeks depending on the application schedule, residents are exposed to a myriad of health problems that may occur in the short and long term. Regrettably, EPA and the sewage sludge industry’s response to public allegations is, prove it. The wonder of this response is that there are multiple numbers of cases that already demonstrate the negative effects of sewage sludge applications on public health. Nevertheless, this negligent retort is an effective argument for those who wish to continue spreading sewage sludge.
Due to the complexity of health issues including the variety of illnesses experienced, the timing, as well as the financial and logistical issues affecting whether a study can even be launched, proving cause and effect is difficult, at best. To complicate the process, medical professionals are generally not trained to recognize or identify health complications caused by exposure to the innumerable amount of pollutants found in sewage sludge. However, several Class Action lawsuits against the EPA, sewage sludge industry and landowners have been filed and won. The amount of these cases is not representative of the number of cases that could have been filed.
Why sewage sludge is used:
If sewage sludge is so potentially harmful to human health why is it being spread across agricultural land? The answer can be found in two words, it’s cheap. In most cases, a municipal waste treatment plant pays a sewage sludge transport company (resident fee dollars) to dump their sewage on agricultural land at no cost to the landowner. Landowners are told by the sewage transport company that sewage sludge is superior to other fertilizers despite reports indicating otherwise. From various studies and reports, the long-term effect of sewage sludge on farmland may produce negative results through the accumulation of heavy metals, chemicals and toxins that may take years if not decades to leave the soil.
Landowners are also generally not informed of the legal risks they assume by allowing sewage sludge to be spread on their acreage. According to United Sludge Free Alliance, What Farmers Are Not Told About Sludge, 2010:
- The financial risk and liability for any nuisance litigation from nearby neighbors exposed to sewage sludge causing property damage, well-water pollution, personal injury, illnesses or death.
- There is no financial liability to the sludge hauler or municipality after they discontinue dumping sludge on a property. In fact, the farmer can be held accountable to clean his own property if soil test shows high levels of heavy metals and toxins.
- Under the Clean Water Act, sludge is declared a pollutant and must be disposed of properly, an issue that is downplayed by companies spreading sludge on farmland because the farmer will be the one charged with breaking the law.
Of course, what is in the soil eventually ends up in the air, in animals that cross or feed on the produce or it seeps in to water sources – it is a continuous cycle. It doesn’t matter what side of the political spectrum one leans toward, land application of sewage sludge causes legitimate and serious concern. “It’s not like I’m some kind of an environmentalist, or something,” said a long time local resident who asked not to be identified. “I just don’t want my wife and kids getting sick from this s#@t, just so somebody can save some money”.
In a report by Dr. Caroline Snyder, The Dirty Work of Promoting Recycling of America’s Sewage Sludge – 2005, Dr. Snyder clearly states how the sewage sludge land application practice and policy came into existence.
“Reports of adverse health effects linked to the use of sludge as fertilizer have mounted, especially in the last ten years. Over the same time, EPA forged a powerful alliance with municipalities that needed an inexpensive method of sludge disposal and sludge-management companies that profit from this practice. The alliance’s primary purpose was to control the flow of scientific information, manipulate public opinion, and cover up problems, in order to convince an increasingly skeptical public that sludge farming is safe and beneficial. The alliance ignored or concealed reported health problems, threatened opponents with litigation, distributed misleading information to the media, legislators, and the public, and above all, attempted to silence critics. “
Dr. Snyder adds, “EPA uses industry-friendly scientists and corporate influence to defend an un-protective policy. It is a carrot-and-stick approach. Supportive scientists receive federal grants, while economic threats are used to silence unsupportive scientists, private citizens, and local governments.”
What is most disconcerting is that given the extreme amount of health problems experienced by a multitude of citizens across the country, EPA, state, and county governments continue to assume a laissez-faire attitude to land application of sewage sludge near residential areas. From Dr. Snyder’s report, “In 2002, a National Academy of Sciences (NAS) panel warned that treated sewage sludge is such a complex and unpredictable mix of biological and chemical wastes that its risks, when used for farming, can not be reliably assessed. Therefore, the panel concluded, standard strategies to manage the risks of land application do not protect public health.” Still, the spreading of sewage sludge continues.
Sewage sludge is not isolated to the U.S. – wherever there are cities and human waste there is some form of sewage and subsequent sludge. However, there are restrictions banning the land application of sewage sludge in different parts of the world. In 2003, Switzerland’s Federal Office of the Environment completely banned the application of sewage sludge on all agricultural land. From their Federal Environment Report, March, 2003, “Although (sewage) sludge contains plant nutrients such as phosphorous and nitrogen it also comprises a whole range of harmful substances and pathogenic organisms produced by industry and private households. For this reason, most farmers already avoid using sludge as a fertilizer since they are aware of the risk of irreversible damage to the soil, and the danger to public health and possible negative effects on the quality of the food they produce.” After enacting the ban, Switzerland developed a way to incinerate sewage sludge in an environmentally positive manner.
In the U.S.A, there are at least five locations (Meza, AZ, Flint, MI, Sanford, FL, Renton, WA, Rialto, CA) where cities have developed a healthier and more efficient approach to using sewage sludge without impacting public health. In most cases, sludge is safely converted to fuel to heat homes and run municipal vehicles. These are options that should be explored by all states.
Perhaps the biggest driver pushing the land application of sewage sludge is that human waste from municipalities is increasing and there is a growing need to cost-effectively dispose of the sludge product following sewage plant treatment. Arguably, there may be some short-term benefit to the land owner’s soil in the form of nutrients and cost. However, the potential harm to public health and the environment far exceeds the benefit. Landowners don’t want to see it that way because they envision a short-term financial gain. What they don’t know could come back to bite them on their own proverbial sewage source and they could end up paying considerably more in the long term than what they think they’re saving in the short term.
“In America today you can murder land for private profit…. You can leave the corpse for all to see, and nobody calls the cops.” Paul Brooks, PhD, Hydrology and Resources, University of Colorado, The Pursuit of Wilderness, 1971
If you are concerned about this issue, contact:
EPA, Region 8 1595 Wynkoop Street Denver, CO 80202-1129,
303-312-6312 or 800-227-8917
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, Denver, Colorado 80246-1530,
136 State Capitol, Denver, CO 80203-1792
Demand sewage sludge land application near residential areas stops immediately until more comprehensive studies and stricter regulations are adopted and enforced. At the very least, insist that until more thorough studies are complete and new protective standards are enforced that land application is banned within two miles of all parks, playgrounds, and residential areas.