Monday, March 30, 2009

Frameworks

The problem of land application of biosolids and a proposed partial solution, HR 185 raises serious issues of right and wrong. The values most affected are those of human health, the environment, transparency of food systems, and the ethics of government agencies, specifically the EPA. Land application of biosolids has been in practice since the 70’s when the EPA declared it safe. Since then there have been allegations of the EPA aligning with industry to produce fraudulent and misleading studies. In the absence of untainted science the EPA assured, “no documented cases of illnesses” and “no public health concerns from the use of biosolids whatsoever” (http://www.sludgenews.org/resources/documents/Snyder.pdf). These statements occurred even after evidence was found that 3 deaths occurred after exposure to applied sewage sludge.

Although HR 185 would not disallow the land application of biosolids it would increase transparency in the food system, and could ultimately lead to discontinued use on land used for food. If consumers were notified that biosolids had been used to grow their vegetables or that their beef had been exposed it is reasonable to believe that they may opt not to purchase that product. As this occurred it would provide incentive for farmers to discontinue its use.

There are a great number of stakeholders involved in this issue. There are sludge application companies who make a profit from carting biosolids from treatment centers to rural areas, citizens (especially those who live near land treated with biosolids), the EPA, farmers, and food companies (such as Heinz and Del Monte). Intriguingly, this has also become an environmental justice issue as those with a voice have spoken against applying biosolids in their communities. Increasingly this issue has moved to more rural, less affluent communities who do not speak out.

If HR 185 does not pass the winners will continue to be industry and the losers will continue to be the citizens. I say continue because this bill has been reintroduced year after year since at least sometime in the ‘90’s and has yet to pass. It is possible that with changes in the EPA because of the new administration that outlook on sewage sludge may change as well.

This is an especially difficult issue because from what I have read so far there are not widely available substitutes. Land use became a solution for biosolids after an effort was made to clean up rivers, streams and oceans. Once waste treatment plants were able to separate the waste from the water they could return the water to its appropriate place but needed somewhere to put the solid waste. When the EPA was tasked with finding a solution in the 70’s they turned to land use. As Northeast Biosolids and Residuals Organizaiton (NEBRA), a biosolid friendly organization writes, “If you like clean lakes, rivers, and groundwater, you should support environmentally sound biosolids management. You can’t have one without the other.” (www.nebiosolids.com).

The issue is even further complicated by the science behind it. The EPA has been widely touted to have allied with industry, ignoring any research questioning the land use of biosolids and relying solely on industry friendly scientists who say there is “neglible risk” involved. One former EPA scientist David Lewis, fought for years against the current regulations only to be publicly ridiculed, have his research questioned and finally completely forced out of biosolid research by the EPA. So the science appears to be pretty cut and dry, most science either finds that land use of biosolids does not pose much risk, or that there is still a lot of research that needs to be done and until we can say it is safe there needs to be more regulation.

Unfortunately the policy design of current biosolid practice is backward. Instead of relying on science to form policy the EPA formulated policy and then looked for/created science to back that up. This has created a situation that has compromised the health of many people as well as animals and the environment. As stated previously, if HR 185 were to pass it would create an incentive to farmers to say no to biosolids. Currently, farmers are often not told of the dangers related to biosolid use and are often encouraged to accept this “free” form of fertilizer. If there were economic consequences in the form of reduced sales then farmers would most likely stop use. As it is now the opinions of these stakeholders are not widely available, but I will continue to search for this for my paper.

As has been clearly shown and will be much more so in my final paper the management of biosolid use by the EPA has been subpar. They have enacted lax regulation that has lead to death and serious illness in case after case. Instead of taking responsibility and researching the issue there have been lies and cover ups. With the election of President Obama the hope is that the EPA will go back to being a science based agency less mired in politics. Hopefully if this happens the current practice of biosolids will be evaluated and a better, safer solution can be found.

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