Beyond Pesticides Campaigns to Stop Use of Toxic Sewage Sludge (Biosolids) Fertilizer, Transition to Organic – Beyond Pesticides

Report on Contaminants in Sewage Sludge Fertilizer and Implications for Sustainable Development Goals

Executive Summary

This report addresses the significant environmental and public health risks associated with the use of sewage sludge, or biosolids, as a fertilizer in nonorganic agriculture and landscaping. Recent scientific studies and legal actions have identified numerous hazardous contaminants, including per- and polyfluoroalkyl substances (PFAS) and other Contaminants of Emerging Concern (CECs), within these products. Current regulatory frameworks, particularly those overseen by the U.S. Environmental Protection Agency (EPA), are inadequate for protecting human health and the environment. The land application of contaminated biosolids directly undermines progress toward several key United Nations Sustainable Development Goals (SDGs), including those related to health, clean water, and terrestrial ecosystems.

Identified Contaminants and Regulatory Deficiencies

Scientific analysis has revealed that sewage sludge is a repository for a wide array of harmful substances. The failure to adequately regulate these contaminants poses a direct threat to environmental and public health.

• Key Contaminants:
  • Per- and polyfluoroalkyl substances (PFAS): Recent testing has confirmed the presence of at least 14 different PFAS compounds in biosolids-treated farmland at concentrations high enough to confirm significant contamination.
  • Contaminants of Emerging Concern (CECs): A literature review identified 414 CECs in biosolids, including pesticides like neonicotinoid insecticides.
  • Other Persistent Pollutants: The EPA’s National Sewage Sludge Surveys have identified 726 chemicals, including heavy metals, polychlorinated biphenyls (PCBs), dioxins, pharmaceuticals, and pathogens.
• Regulatory Gaps:
  • The EPA’s classification of biosolids as Class A (“virtually free of pathogens”) is misleading, as it fails to account for chemical contaminants like PFAS.
  • The EPA Office of Inspector General (OIG) has found the agency’s regulation of biosolids to be inadequate, necessitating action at the state and local levels.
  • The Organic Foods Production Act already prohibits the use of sewage sludge in certified organic agriculture, acknowledging its inherent risks.

Analysis of Impacts on Sustainable Development Goals (SDGs)

The widespread use of contaminated biosolids directly conflicts with the global agenda for sustainable development. It creates a cycle of pollution that jeopardizes environmental integrity and human well-being.

1. SDG 3: Good Health and Well-being: The application of biosolids introduces toxic chemicals into the human food chain and public spaces like parks and athletic fields. Exposure to these contaminants is linked to severe health effects, including cancer, endocrine disruption, and reproductive harm, directly opposing the goal of ensuring healthy lives.
2. SDG 6: Clean Water and Sanitation: Contaminants such as PFAS are highly mobile in soil and can leach into groundwater and surface water. This practice threatens the safety of drinking water sources, undermining the goal of ensuring the availability and sustainable management of clean water.
3. SDG 12: Responsible Consumption and Production: Marketing contaminated sewage sludge as a sustainable fertilizer represents an irresponsible production pattern. Instead of creating a circular economy, it transfers hazardous waste from sanitation systems to agricultural and ecological systems, contaminating food, water, and soil.
4. SDG 15: Life on Land: The introduction of persistent toxic pollutants into soil degrades land quality, harms biodiversity, and poses a threat to wildlife and essential pollinators. This practice directly contravenes the objective to protect, restore, and promote the sustainable use of terrestrial ecosystems.

Legal and Advocacy Responses

In response to regulatory failures, legal and public advocacy efforts are underway to address the risks posed by contaminated biosolids.

• Litigation: Consumer protection lawsuits have been filed by Beyond Pesticides against major producers like ScottsMiracle-Gro and GreenTechnologies, LLC. These lawsuits cite test results showing PFAS residues in products and highlight the adverse effects on public health and wildlife.
• Call for Moratorium: A network of public health and environmental advocates is calling on state and local officials to ban the land application of biosolids until adequate and comprehensive testing for all toxic residues can be established and enforced.

Recommendations

To align with the principles of the Sustainable Development Goals and protect public and environmental health, the following actions are recommended:

1. Institute an immediate moratorium on the use of sewage sludge on farms, parks, and other landscapes pending a full regulatory review.
2. Develop and mandate comprehensive testing protocols for biosolids that include PFAS, CECs, and other persistent toxic pollutants.
3. Reform federal and state regulations to eliminate loopholes and ensure that sludge management practices do not lead to the contamination of food, water, and ecosystems.
4. Promote investment in alternative technologies for managing wastewater byproducts that are genuinely sustainable and do not perpetuate the cycle of contamination.

Analysis of Sustainable Development Goals in the Article

1. Which SDGs are addressed or connected to the issues highlighted in the article?

1. SDG 3: Good Health and Well-being
   • The article extensively discusses the adverse effects of contaminants like PFAS found in sewage sludge on public health. It mentions concerns about “acute toxicity, cancer, genetic mutations, birth defects, reproductive or developmental effects, neurotoxicity, endocrine disruption, or immune system effects.”
2. SDG 6: Clean Water and Sanitation
   • The article highlights that contaminants from biosolids applied to land “make their way to our food and water,” directly addressing the issue of water pollution from hazardous chemicals.
3. SDG 2: Zero Hunger
   • The use of contaminated biosolids on farms is a central theme. The article states that “Over 60% of biosolids are used in crops” and that “Chemicals such as PFAS have been found to migrate into food when grown on farms using contaminated biosolids.” This directly relates to food safety and sustainable agricultural practices.
4. SDG 11: Sustainable Cities and Communities
   • The article discusses the use of biosolids in urban and community settings, such as “landscaping,” “parks,” “golf courses,” and “athletic fields.” The contamination of these public spaces poses a direct threat to the environmental quality and safety of communities. The management of sewage sludge itself is a key aspect of municipal waste management.
5. SDG 12: Responsible Consumption and Production
   • The core issue is the environmentally unsound management of waste (sewage sludge) and chemicals (PFAS, PCBs, etc.). The article critiques the “standard means of ‘disposal'” and calls for proper testing and regulation, which aligns with achieving the sound management of chemicals and wastes.
6. SDG 15: Life on Land
   • The article points to the degradation of terrestrial ecosystems through soil contamination. It also explicitly mentions the “adverse effects of PFAS to public health, wildlife, and pollinators,” linking the issue to the protection of biodiversity and life on land.

2. What specific targets under those SDGs can be identified based on the article’s content?

1. Under SDG 3 (Good Health and Well-being):
   • Target 3.9: “By 2030, substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water and soil pollution and contamination.” The article’s focus on the health risks from 726 different chemicals, PFAS, and other pollutants found in biosolids directly relates to this target.
2. Under SDG 6 (Clean Water and Sanitation):
   • Target 6.3: “By 2030, improve water quality by reducing pollution, eliminating dumping and minimizing release of hazardous chemicals and materials…” The migration of contaminants from biosolids into water sources is a clear example of the pollution this target aims to reduce.
3. Under SDG 2 (Zero Hunger):
   • Target 2.4: “By 2030, ensure sustainable food production systems and implement resilient agricultural practices that… progressively improve land and soil quality.” The article argues that using contaminated biosolids in agriculture is an unsustainable practice that degrades soil and contaminates food, running counter to this target.
4. Under SDG 11 (Sustainable Cities and Communities):
   • Target 11.6: “By 2030, reduce the adverse per capita environmental impact of cities, including by paying special attention to air quality and municipal and other waste management.” Sewage sludge is a form of municipal waste, and its improper management, as described in the article, leads to adverse environmental impacts.
   • Target 11.7: “By 2030, provide universal access to safe, inclusive and accessible, green and public spaces…” The contamination of parks and athletic fields with hazardous chemicals makes these public spaces unsafe, directly challenging the goal of this target.
5. Under SDG 12 (Responsible Consumption and Production):
   • Target 12.4: “By 2020, achieve the environmentally sound management of chemicals and all wastes throughout their life cycle… and significantly reduce their release to air, water and soil in order to minimize their adverse impacts on human health and the environment.” This target is central to the article, which critiques the EPA’s inadequate regulation and calls for a ban on biosolids until there is proper testing and management of the chemical contaminants.
6. Under SDG 15 (Life on Land):
   • Target 15.5: “Take urgent and significant action to reduce the degradation of natural habitats, halt the loss of biodiversity…” The article’s mention of adverse effects on “wildlife, and pollinators” directly connects the issue to the loss of biodiversity.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

1. Number and Concentration of Contaminants:
   • The article provides specific numbers that can be used as indicators of pollution. These include the EPA’s list of “726 chemicals found in biosolids,” a study identifying “414 contaminants of emerging concern (CECs),” and research that “detected 14 different PFAS… above the limit of quantification (LOQ).” Measuring the reduction of these numbers in biosolids would indicate progress towards Targets 3.9, 6.3, and 12.4.
2. Prevalence of Contaminated Land Application:
   • The statistic that “Over 60% of biosolids are used in crops” serves as a baseline indicator. A reduction in this percentage, particularly for untested or contaminated biosolids, would measure progress in achieving sustainable agriculture (Target 2.4) and responsible waste management (Target 12.4).
3. Regulatory Adequacy and Legal Actions:
   • The article implies that the number of regulations and their enforcement is an indicator. It states that EPA regulation has been “found by the EPA Office of Inspector General (OIG) to be inadequate.” The number of lawsuits filed (e.g., against ScottsMiracle-Gro and GreenTechnologies) and state/local bans enacted can serve as indicators of progress in governance and accountability related to chemical management.
4. Impact on Biodiversity:
   • While not providing specific data, the article’s mention of “adverse effects of PFAS to… wildlife, and pollinators” implies that monitoring the health and population of these species in areas treated with biosolids could be an indicator for Target 15.5.

4. Summary Table of SDGs, Targets, and Indicators

Source: beyondpesticides.org