Industry Fights Back Against Biosolids Report

A negative analysis fails to consider decades of research, say biosolids associations

Industry Fights Back Against Biosolids Report

Here's a before-and-after shot of biosolids land application. The Hegarty mine reclamation site is located in Clearfield County, Pennsylvania, where approximately 15,000 wet tons of biosolids were applied in an effort to reclaim 85 acres. (Photos courtesy of the Mid-Atlantic Biosolids Association)

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In the 1970s, a research project analyzed the effects of biosolids land application on an area devastated by coal mining — the first comprehensive bioassay on the topic, considering impacts to the entire ecosystem, down to the health of fauna and insects in the soil.

The study found that the benefits of the application were plentiful, and despite a number of trace contaminants, the Environmental Protection Agency has maintained a stance that land application is a low-risk activity.

Since then, thousands upon thousands of sites have taken biosolids application, and a proportionate number of studies across the years have shown little to no negative impact, especially in comparison with the positive effects.

A report in November casting doubt on the safety of biosolids and recommending that the EPA change its official stance on its use has put the industry at odds with the EPA’s Office of the Inspector General, which issued the report.

According to several regional biosolids associations, OIG’s criticism of the current biosolids program fails to consider the wider contributions of industry advocates and historical studies.

“In a nutshell, it’s like doing a movie review of only 10 percent of the movie, and then leaving the remaining 90 percent subject to interpretation,” says Maile Lono-Batura, executive director of Northwest Biosolids. “That’s essentially what the OIG report did. It left out a huge chunk of knowledge that goes along with biosolids recycling.”

A routine analysis

The OIG is required to conduct an assessment of the EPA’s various programs routinely, so this isn’t the first time a report like this has been released, just the first time it has been so critical of biosolids.

The main takeaway from the OIG report is that biosolids are undermonitored and understudied. Analysis has reportedly shown up to 352 pollutants present in biosolids, and the reduction of staff and resources in the EPA biosolids program over time has made it difficult to properly assess the danger of these pollutants, according to the report.

“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,” a report summary says.

While OIG’s conclusions that there are many unknown factors and potential contaminants in biosolids is valid, the implication that unknown equals danger is debatable.

“There is abundant literature and research scientists at universities around the country, around the world really, looking at these questions all the time,” says Ned Beecher, executive director of the North East Biosolids and Residuals Association (NEBRA). “There are thousands of published papers looking at this question of contaminants in the environment from biosolids.”

Beecher and Lono-Batura argue that the decades of land application and accompanying studies showing no negative effects outweigh the fact that many of the contaminants haven’t been studied explicitly by EPA.

“Ongoing research is something that is ingrained in biosolids. That was part of developing the regulations, having that solid base of knowledge, and it’s something that our field is rooted in,” Lono-Batura says. “To have that part of it completely left out of the story is a difficult one, because then people just think, ‘Well jeez, they’ve been flying under the radar this entire time,’ and that’s just not true.”

Perhaps the most contentious point listed in the report is the recommendation that the EPA’s Office of Water change their official stance on biosolids from a low-risk activity to potentially hazardous.

Beecher summarizes the entire issue simply: “Decades of research and experience with biosolids use on soils — including two National Academy reviews — has found minimal risk and many benefits to soil health and sustainability. EPA is well aware of this research and experience and, therefore, considers biosolids recycling to be a low-risk activity. In addition, EPA has many other controls in place and relies on other (e.g. state) regulations and best practices that also help ensure protection of public health and the environment with respect to biosolids recycling.”

Under advisement

The Office of Water issued a response to the conclusions of the report, with its main contention relating to the idea that the 352 pollutants pose eminent danger, as opposed to simply being unknowns.

“They’re aware of that, they understand how that relates to the potential risks to biosolids, but they don’t have the data to do their formal risk assessments,” Beecher says. “That’s basically what the report said, but they made it sound like it was a really big deal.”

There are points of agreement — for example, the conclusion that the biosolids program is underfunded.

In total, EPA’s Office of Water has resolved or agreed to address eight of 13 recommendations in the OIG report. Five of the recommendations remain unresolved due to disagreement between the Office of Water and OIG, and discussion is ongoing. 

Concern doesn’t equal danger

Despite some legitimate concerns about the EPA’s biosolids program and risk assessment procedures, conclusions drawn from the existence of unknown factors overstate the dangers of biosolids application.

“The nutrients in biosolids appear in percentages, 2 to 6 percent of nitrogen or phosphorus and things like that, which are great for the ecosystem, so you get these positive responses,” Beecher says. “The trace chemicals are showing up in parts per million, parts per billion, parts per trillion — I mean we’re talking about tiny, tiny amounts in comparison to the positive aspects. So that’s why the positive results are very clear, and really people have not measured negative outcomes to the biota around those systems.”

Biosolids associations have not stood by to let this report diminish the industry’s ability to utilize biosolids — in addition to NEBRA and Northwest Biosolids, responses to the OIG report were put out or signed by WEF, Mid-Atlantic Biosolids Association, Virginia Biosolids Council, California Association of Sanitation Agencies, US Composting Council, National Association of Clean Water Agencies. As for the practical impacts of the report, “It could lead to a change in regulation or a change in best practices,” Beecher says. “We would recommend and get people to start implementing those changes — it’s not going to be that land application should cease entirely.”


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