A Case for Caution

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BIOSOLIDS:A CASEFORCAUTIO,ru

Prepared for the PEC Environmenta! Advisory CommitteeBySandra LatchfordCouncillor, PEC

Feb. 4, 2O0B


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Household Biosolids - Yesterday and TodayThe Biosolids generated today are significantly different from thosegenerated even twenty and thirty years ago.Since L945, thousands of chemicals (pharmaceuticals, cleaning products,personal care products, flame retardants, etc) have been introduced into andembraced by North American's; the products we use every day in ourhomes, the food that we eat, the clothes that we wear and the medicationsthat we take. These chemicals are washed and flushed into our waste watertreatment plants. Yet, surprisingly, despite the dramatic changes in what wewash and flush, there has been a remarkably slow response to chaft andrespond to those changes.What is new in household biosodlids?

Toxic cleaning products - As society has become increasing consciousabout being "clean", the variety and potency of householdcleaning products has increased dramatically. The averagehousehold disposes into waste water 15 - 40 kilograms of toxiccleaning products each year.Personal care products - The goal for cleanliness extends to personalcare with many new shampoos and soaps which containsurfactants such as triclosan ( Triclosan has been described asan emerging contaminant by Dr. Edward Topp a speaker at theWEAO seminar in London, ON, Dec, L2, 2OO7).Pharmaceuticals - Medicines, both prescription and over the countermedications, are being used at unprecedented levels by peopleof all ages. And indications are that usage levels will increase asthe population ages.Flame retardants - These chemicals have been linked to healthproblems in people and house cats (hypefthyroidism) and two ofthe three most commonly used flame retardants have beenremoved from use.Pathogens - Over the last twenty years antibiotic resistant bacteria(i.e. MRSA and others) have become a major concern for allhealth care facilities (hospitals, and nursing homes).

Compared to animaUchicken manureAnimal manure does contain pathogens (E.coli) but not in the concentrationnor variety that is present in biosolids. Also, animal manure does not contain


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the chemical cocktail (cteaning compounds, pharmaceuticals etc.) that ispresent in household biosolids.Ministry of Environment (MOE)I MOE Regulations and GuidelinesThe MOE generates regulations and guidelines for testing, transporting,storing and spreading of biosolids on farmland. It also carries theresponsibility for enforcing the regulations.Biosolids are routinely tested for:Pathogens - sPecificallY e-coliNitrogenPhosphates

Metals - for example; mercury, cadmium, lead[Funans & dioxins were monitored in the past and found to bevery low.lResearch has been done on the items listed above which has lead to thegeneration of regulations and guidelines for the transporting and spreadingof biosoilds.HOWEVERMOE does NOT routinely test biosolids for:

* Pharmaceuticals [use of over the counter and prescriptionmedications has increased dramatically over the last 20years.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 thatare currently in use and enter waste treatment plants.

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il MOE ENFORCEMENTThe MOE has the authority to enforce their regulations but concerns havebeen raised that they do not have sufficient front line personnel to carry outtheir mandate.At the seminar in London, Mr. Larry Schill, a farmer who spoke about hisexperiences with spreading biosolids on his property, indicated that he hadno complaints about MOE enforcement. However, another farmer in theaudience recounted the problems that he had experienced with MOEenforcement.Included in this report is a copy of an afticle "The Scugog Township Incident"which appeared in Better Farming, Oct. 2007. The article recounts abiosolids spill in Scugog Township.Policies, regulations, and guidelines are written based on current knowledgeand are usually generated with good intentions. However, there is often ahuge disconnect between what "should be" and what "actually happens."Enforcement of the regulations requires funding to hire enough trainedinspectors to do the job required.

Complex Problems dont haveBut the questions must still be asked.

Simple Answers


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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.) andpathogens are in biosolids?Have you and are you chafting the change in the amount and types oforganic 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 formother compounds?When they degrade do they break down into harmless products or dothey degrade into more harmful products?What are the degradation rates and profiles of thechemicatslpharmaceuticals, 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 intactin the plants to re-enter the human food chain?How can MOE establish regulations and guidelines for organicchemicals that are in unknown quantities, have unknowndegradation rates in soil and have unknown uptakecharacteristics in plants grown in that soil?

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

RESEARCH - ORGANIC CHEMICALS IN BIOSOLIDSI 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 articleils attathed in full at the end of this repott'lThe following are some points made by the authors in this article.* .. More data are needed on chemicals that are in sludges today and onthe temporal trends for those chemicals. Relying on existing lists of.chemicals such as priority pollutants will not identify many chemicals ofcurrent concern." P. 496* ..Few data exist on the fate of sludge-borne chemicals in field soils andsuch research is critical to assessing the risks posed by sludgeapplication." P.496{. "Degradation is an important component of loss, but may beincomplete or slow, even for relatively easily degraded chemicals suchas linear alkyl benzene sulfonates(LAS). LAS is present at such highconcentrations in sludges (up to 3olo by weight) that incompletedegradation coupleO witn repeated application could result inconsistently elevated I-1AS concentration in soils. This wasdemonstraied in one study that detected over 10mg/kg six years afterland application of sludge. Importantty, no further decrease was foundafter two more years, indicating that the residual LAS was resistant todegradation (Carlson et al.,2OO2 in Harrison, Oakes, Hysell &Hay'2006)." P.496* ..Evatuating the risks posed by individual chemicals, let alone mixturesrequires mirttipte assumptions that can lead to unacceptably high levelsof uncertaintY." P. 496


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"Current limitations in our knowledge base regarding the amount andtype of chemicals in sludges exacerbate this problern, as does thelimited availability of fate and toxicity data, for both human and non-human receptors ." p,496Another article of interest appears in the Cornell Univercity BreastCancer Newsletter, Vol.12 Issue 4, Fall 2OO7.In this article, Dr.Anthony Hay and Dr. Ellen Harrison are interviewed aboutcontaminants in Sewage Sludge. [A copy of this afticle isincluded in this report.lIn this interview, both Dr. Hay and Dr. Harrison continue to expresstheir concerns about the unknowns that surround biosolids.Dr. Hay notes:" Triclosan [a biocide widely used in antibacterial hand soaps,deodorants, toothpaste and many other productsl was found in allsamples of sludge in quite high concentrations.... We are seeingtriclosan increasingly in environmental samples. ... in fish, and in highconcentrations in breast milk. Triclosan is an inhibitor of the enzymesthat are involved in cleaning out other pollutants from our body; paftof phase-2 metabolism."

A fufther note on surfactants, appears in "Science, Risk, PublicPerception, 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. Becauseof a lack of scientific certainty relating to the human and witdlife effectsit may have through mimicking estrogen.At the London seminar, Dr. Ed Topp reported on research which isexpected to be published in the spring of 2008. His power pointpresentation titled "Fate of pharmaceuticals and personal careproducts following land application of tiquid municipalbiosolids." is available at

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http : //www. weao. orglcom m ittees/biosol ids/biosol ids. htm I g


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Dr, Topp and nine colleagues are compiling data collected on aselected group of pharmaceuticals and organic chemicals. They arelooking at their occurrence levels in biosolids, and after spread.ing onland their presence and persistence in run off water and soil as well astheir rate of degradation. Some of the products being investigated inthis 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 ata "definition of problem" stage"."As risk [exposure X hazard] for "emerging contaminants"is betterdefined, regulatory action may be taken."

"Just like the rest of us, scientists get comfortabre withdoing things the way they always have, even whenarguments arrive suggesting that change has to happen.,,Dr. D. DavisDirector 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. Infact, some PPms are moving targets. The ppm for lead for example has beenlowered at least twice since it was first established and the Center forDisease 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 besafe in the future.Once people, wildlife and the environment are exposed to metals/chemicalsthe harm is done and may be irreversible.


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LIABILIW . MUNICIPALIW AND/OR LAND OWNERQuestions have also arisen as to who carries the liability when biosolids arespread on land. Mr. Schill, the, farmer who spoke at the London seminarindicated that he was considering, in the future, of asking the nnunicipality toassume the liability as a condition for agreeing to accept biosolids. It appearsthat the insurance coverage for farms covers accidents related to normalfarm 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?* [Newspaper article from the Globe and Mail, Jan.25/08 included in thisreport.lWill the municipality be asked to pay for liability insurance for the landowner/farmer who agrees to accept biosolids? If such insurance is available.Will the municipality cover the legal costs of the land owner/farmer who hasclaims made against them?

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


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A Case for CautionWhy be cautious?1. Our ability to confidently predict risks from land applications is

very limited. we don't know the types of contaminants in biosolids.o we don't know the concentration of the contaminantsAlthough levels of metals and E.coli in biosolids have been well studiedit is the information that we don't have that should give us pause. Wedo not know what organic chemicals and pharmaceuticals occur inbiosolids, nor the quantity in which they occur nor how those chemicalsreact and degrade in soil. Once we know that information it may bepossible to set standards that will reduce their risk to humans, wildlifeand the environment. (Topp, 2008).2. Our present standards are based on a risk assessment withmany shortcomings. the tools to test for contaminants are still underdevelopment -limits of detection are insensitiven funding for independent studies and for long term studies isinadequate.3. Enforcement and monitoring are spotty.4. The health concerns that have been raised by neighbours

around land that has received biosolids are still underinvestigation.5. More and more of the public are becoming reluctant to beexposed to the risks of biosolids and want an alternate solutionfound.The public are not "uneducated" nor "paianoid" but neither are theynaive nor gullible. Past experience has shown that when scientistsdon't agree then we need to be wary. "Well known" researchers toutedthe 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 passageof 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 ourtime and energy on short and long term solutions that are environmentallysafe.If land spreading is ruled out, what other options do we have?Unfortunately, alternatives to land application were not presented at theLondon seminar.Possible short term alternatives:

1. Placement in an approved land fill site. [Matt Traceyestimates that the cost for sending biosolids to landfill is 14cents per gallon compared to 2 cents per gallon to spreadon land.l2. Incineration.

Possible long term solutions:1. Combine with compost material gathered in themunicipality and make into biofuel - which could sell for$40lcu.yd.*I should note that the province does not encouragebiosolids being included in regular composting programsbecause of the levels of heavy metals etc. Ontario has highstandards for compost that is to be sold for garden use.2. Gasification. This is a process that gasifies garbage,dewatered sludge, tires etc. turning it into syn gas which iscleaned and then burned to generate electricity.[Gasification is also an alternative to using land fill sites forgarbage.l

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SourcesAfticlesCornell Faculty Address Contaminats in Sewage Sludgesl The RibbonInterviews Dr. Anthony Hay and Ellen Harrison. Vol.12 Issue 4, Fall2oo7.I Co rn e tI lJ n i ve rs ity B rea st Ca n ce r N ews I etter]Glaser A., "The ubiquitous Triclosan." Pesticides and You.Yol' 24, No.3, 2004'Harrison, Oakes, Hysell & Hay,"Organic Chemicals in Sewage Sludges"' Scienceof the Tatat Environment 367 (2006): 48t-497.Kepner J., "Triclosan Hazards....Continued." Pesticides and You. Yol, 24, No. 4,2004-2005.Krogmann U. & Boyles L., "Land Application of Sludge (Biosolids) #7= OrganicCoritaminants." Rutgers Cooperative Research & Extension Fact Sheet, 1999...Ontario,s Waste Management Challenge- fs fncineration an Option?" Arepoft produced by the Canadian Institute fro Environmental Law and Policy(CIELAP), March 2A07.Rayne Sierra, & Ikonomou G., Polybrominated diphenyl ethers in an AdvancedWaStewater Treatment Plant. Paft 1; Concentrations, Patterns, andInfluence of Treatment Processes. Journal of Environmental Engineering andScience a(5): 353-367 (2005).Selvaratnam S. & Kunberger D.1., "Increased Frequency of Drug-ResistantBacteria and Fecal colifbrms in an Indiana Creek Adjacent to FarmlandAmended with Treated Sludge." Canadian Journal of Microbiology 5O(8): 653-6s6 (2004).Sandersor H., "Science, Risk, PubliC PerceptiOn, and Precautionr"Environmental Science & Engineering , March, 2OO4.*Sewage Biosolids Land Applicationr Reported Health Incidents." CornellWaste Management Institute http ://cwmi.css.cornell.edu/BooksDevra Davis, The Secret History of the War on Cancer. (New York: BasicBooks, 2OO7).

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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 ProceeCinossupreme court case spraytech v.'Hudson (Town), [2ooll s,c.J. No.42. Thesupreme court upheld a municiparity's ban on the uiebf pesticides.Web SitesBeyond Pesticideshttp : //bevondpesticides. orgCornell Waste Management Institutehttp : //cwmi.css.cornell.edu/Cornell University Breast Cancer Newsletter

http : //envirocancer. cornell. edu/http,' r"nui ro.u n.u...orn"l l. "d r/N "*rl"tt". ru.ti.l.,Environment CanadaNational Research Council of Canadahttp : //n rc-cn rc.qc. caWater Environment Association of Ontario

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A Case for Caution