Keep farms and food free from sludge

EAT, DRINK, PRAY, SLUDGE

Do Canadians want to eat food from fields fertilized with industrial and municipal sludges?

The Canadian Council of Ministers of the Environment (CCME) think so.

The Canada-wide Strategy for the Management of Municipal Wastewater Effluent was endorsed by the CCME Council of Ministers, February 17, 2009, in Whitehorse.  The purpose of the report was to develop a harmonized approach to better manage the wastewater being discharged from more than 3,500 wastewater facilities in Canada, many of which are currently in need of repair and upgrading.

http://www.ccme.ca/assets/pdf/cda_wide_strategy_mwwe_final_e.pdf

The upgrades to these sewage treatment plants mean that even more sewage sludge will be generated.  The issue of how to manage this sewage sludge is not being addressed by the CCME Wastewater reviewers, but was sent to a separate - much smaller -  group made up of one representative from each Province or Territory.

This is the CCME Biosolids Task Group.

http://www.ccme.ca/ourwork/waste.html?category_id=138

But while the CCME Wastewater Effluent Harmonization led to standards and wastewater treatment performance standards across Canada, the Biosolids Task Group has not developed sewage sludge management standards. 

Their proposed policy document is currently open for consultation.  This 13 page document proposes that sewage sludge should be renamed (rebranded)  as %u2018biosolids%u2019 and directed  toward use in agriculture and horticulture as a %u2018beneficial use%u2019 %u2013 without a review of health complaints or soil or crop or food or water contamination stemming from sludge use.  Even though each province or territory has different regulations regarding the recycling of sewage sludge onto farmland, the report provides no recommendations as to what standards or practices should  be set for the dozens of toxic chemicals in sludge like dioxin or mercury. There is no proposed regulation of sludge spreading practices %u2013 such as spreading sludge on pasture land or winter application. Instead, this document suggests the public should sign on to a policy that claims that the patchwork of conflicting and inadequate regulations and %u2018guidelines%u2019 for land applied sludge in Canada is automatically protective of public health and the environment.

  See: http://www.ccme.ca/assets/pdf/btg_phase_2_consult_doc_e.pdf

There is some discussion of whether the use of sewage sludge as a renewable energy fuel can be called 'beneficial'.

However, the Biosolids Task Force, who didn%u2019t see a need to review detriments from agricultural use of sewage sludge, decided that they needed to develop a tool to determine the greenhouse gas emissions from differing sludge management options.

A team of  pro-land application consultants from the USA were hired. They developed a model that suggests that land application of sludge is far preferable from a greenhouse gas generation perspective.  The model they use was developed from unpublished research, and they do not show how they arrive at their greenhouse gas calculations.

The result is that this 'Biosolids Task Group' has created a policy document designed to preferentially drive all of Canada's sewage wastes to farms and fertilizer products.  It is a replay of the US Water Environment Federation strategy to make sewage sludge seem like a safe and beneficial product.  The US EPA has backed off any preferences for putting sludges into agriculture. The EPA maintains that their role is to set standards and regulate all legal sludge management options - not prefer or impose one end point or technology over another.

Since local communities need to live with the consequences of their sludge management approach, and since sludge management is subject to environmental assessments that review the environmental consequences of the sludge end points - why is CCME promoting sludge onto farms?

Who will speak to clean soil, clean water, clean food?

This consultation on the management of sewage sludge is totally inadequate to address the real issues facing municipalities.  It doesn%u2019t look at the damage to soil ecology, it doesn%u2019t look at groundwater and surface water contamination. It doesn%u2019t look at food safety. It doesn%u2019t look at the role of land application in public hygiene %u2013 and the recent SARS and E.coli outbreaks.

The problem of sludge doesn%u2019t rest entirely with the Ministry of the Environment.  If CCME intends to push all of Canada%u2019s sewer wastes to agricultural lands, then we need to consult with farmers, food producers, consumers, health officials, physicians, water experts and soil specialists.  This consultation does not have adequate scope.

Suggestions

1        Invite your friends and associates to sign on to this Petition

2    By July 30, 20011 respond to the consultation document by calling for an end to the use of sewage sludge as a fertilizer

Prepare comments %u2013 however brief %u2013 on how we need to have a sustainable approach to agriculture.  Using farmlands to dispose of industrial and municipal sewer wastes puts our food, water, and farmland at risk. Send comments to lmanson@ccme.ca