Vol. 1, No. 1, September 1998

By Diana Dahl and Roy Smith
Hawaii Organic Farmers Association

[Note: Due to space limitations this article did not appear in the hard copy of this HEHN publication, but is posted here as a special web feature and will appear in our next published issue.]

When the USDA published its version of the Organic Rule for comment last December, the reaction of the public was shock and amazement. The Recommendations of the National Organic Standards Board (NOSB), having worked with organic farmers for over six years in developing a solid set of standards for organic agriculture, were ignored on many points. Four main areas on which the USDA strayed, owing to influence from large corporations and special interests, were to allow 1) ionizing radiation of organic food, 2) genetically engineered organisms, 3) sub-therapeutic antibiotics in livestock, and 4) sewage sludge in organic fertilizers. Over 250,000 comments from the interested public were registered in the ensuing four months, and the USDA did bend to the people's will, vowing to observe the recommendations of the NOSB on these four points by prohibiting their uses in certified organic farming practice.

The last issue, sewage sludge, remains particularly troublesome because of the rationalization for the use of sludge on crops: it contains plant nutrients, mainly the macro-nutrients nitrogen, phosphorous, and potassium (NPK). Farmers are always searching for sources of plant nutrients, and here sludge seems a panacea. However, the benefit is not equal to the risk. And risk there is, considering the seventy thousand manmade chemicals being produced in million ton quantities annually, many thousands finding their way into the waste treatment cycle. Farmland is no place to dispose of such a concentration of waste of unknown long-term consequences. Then why did the USDA try to make sewage sludge "organic?"

Millions of tons of sludge is generated yearly nation-wide. Just Maui alone generates over 20,000 tons/yr. It's logical to look for a use for it. It's not safe to leave lying around; therefore, something has to be done with it . . . such as making "sludge farms." The USDA continues to allow application of certain sledges on conventionally grown crops, in fact is inventing uses for sludge. Not to allow it for organics leads the public to question the safety of its use. Tragically, the currently designed system of centralized, water-based sewage treatment has allowed industry and the public to contaminate a potentially valuable resource with petroleum products, industrial solvents and other carbon-based toxic compounds, such as pesticides, as well as heavy metals, such as arsenic, cadmium, and lead. In fact over seventy thousand substances of unknown toxicity can be found in sewage sludge. Also, pathogens - viruses, bacteria, and parasites - some proven fatally hazardous to humans - are naturally concentrated in sewage sludge. In theory careful and proper treatment of sludge can render it harmless. In practice, however, many pathogens will still remain in the product randomly, and random contamination means 'bio-solid roulette.' You never know if you're getting a good batch or not, until its been irretrievably applied. The effects become obvious too late, effects such as livestock and human diseases, soil and water contamination and economic loss.

What is the future relationship between farming and sludge? According to the Cornell University's Waste Management Institute, Center for the Environment, lack of thorough testing of sludges makes farming with it a huge gamble. Furthermore, there continues to be inadequate assessment of ecological impacts, such as pathogens from fields leaching into wells and ground water. Moreover, there is inadequate enforcement of rules, as witnessed in the transporting of sludge on highways and rails from New York to Texas to be dumped (land farmed). In addition, there persists a lack of oversight - witnessed in the transporting of 'toxic waste for disposal' from Washington state to Idaho where it magically becomes known as 'fertilizer for sale.' Also, little or no labeling of sludge contents is required, nor is there guidance about proper use provided for the consumer. Finally, lack of funding to pursue these safety requirements persists, and although the problem keeps growing, budgets for assessment, enforcement, labeling, and oversight at the state and federal levels continue to be cut. This is not to say that Standards have not been developed for the use of sewage sludge in agriculture. They do exist; however, the US national standards are markedly less stringent than those of many other countries; moreover, they are the same for all applications - home use, agriculture, turf, and roadside. Most significantly the Cornell study concludes that to apply and enforce the standards requires education, training, testing, and long term monitoring, all which are inadequate with regard to use of sludge.

The Organic Standards as developed by the NOSB provide the only guaranteed safe guideline to the use of sludge, which is simply, don't. The Organic Standards are the only safeguard to insure a choice for the consumer, with or without sludge. Only when 1) industry is required to keep by-products out of the waste stream, 2) the product be adequately treated and tested, and 3) education on its use is made mandatory can the resource possible in sludge be made safe for use in agriculture. This is not likely to happen. The system of centralized, water carried waste is at the heart of the problem. Until our waste disposal system is changed the use of sewage sludge on crops imperils the population it is meant to serve.

© 1998, Hawaii Environment & Health News