Sludge Watch ==> Can a crop watered with sewage treatment plant effluent be 'certified organic'?

[maureen.reilly at sympatico.ca]

Sludgewatch Admin:

The question for organic certification organizations is: if you water the 
crop with sewage treatment plant effluent...can the crop be considered 
certified organic.

I'll ask my local certifiers....

The issue really has to do with the contaminant burden in the effluent I 
should think.
It may have less to do with the ecoli count from the toilet waste and more 
to do with
the chemical and toxin burden of the 'reclaimed' water.



--------------------------------------------------------------------------------
Is human wastewater organic?
  Point Reyes Light
Stacey Solie
2006-06-22
http://www.ptreyeslight.com/cgi/news.pl?record=113






The fields at the Coast Guard's Two Rock training center are irrigated with 
treated human wastewater and the grass is sold to local farmers. Is it 
organic? (Light photo by Stephen Nellis)

A West Marin dairy received organic certification even though it was using 
grass irrigated with human wastewater. The company which certified the farm 
organic has told The Light that farms being irrigated with human wastewater 
should not be certified organic. McClelland Dairy, which sells its milk to 
Clover Stornetta Dairies, used Coast Guard silage sprayed with human 
wastewater that had been treated with chlorine to kill pathogens. There are 
differing interpretations over whether human wastewater, or the chlorine 
that treats it, violates American rules of organic certification.

Sewage waste from the Point Reyes Station Coast Guard housing site is 
trucked out to its Two Rock training center in Sonoma County and pumped into 
ponds. After the waste separates into liquid and solids, the liquid is 
treated with chlorine to kill pathogens, and sprayed onto surrounding grassy 
fields.

In 2003, those Coast Guard fields were certified organic by Quality 
Assurance International (QAI), a large, for-profit certification company 
based in San Diego, and the grass was deemed fit to be fed to cows producing 
organic milk for Clover Stornetta Dairies, even though organic regulations 
prohibit the use of human sewage. QAI is one of the largest certifying 
agencies in the world, and certifies farms as far away as China. In that 
country, “night soil,” or human waste as a fertilizer, is the norm.

George McClelland, of McClelland Dairies, owns the lease and cuts the grass 
on the Coast Guard’s land for his dairy cows. When he was undergoing review 
for organic certification in 2003, QAI questioned McClelland about the Coast 
Guard’s water quality, and demanded tests. Once those were produced, he was 
granted the certification. However, after feeding the grass to his organic 
cows in 2003, McClelland stopped, offering it to his conventionally raised 
cows instead.

Shades of gray

When asked whether the Coast Guard’s process for treating their sewage would 
pass organic certification, QAI said “The process [used by the Coast Guard] 
is absolutely prohibited, and not allowed under

organic management,” said Ellen Holten, the spokeswoman for QAI.

“It doesn’t matter if they’re putting it on chocolate ice cream or hay, 
human sewage is not allowed” echoed Jean Schafer, the spokeswoman for the 
USDA’s National Organic Program, which sets the standards.

However, Mike Griffin of Clover Stornetta, the recipient of McClelland’s 
milk, worked closely with George McClelland to help him obtain 
certification. He said that by spraying the treated waste liquid into the 
air, or “aereating” it, the chlorine evaporates and turns what was 
previously “septage” (outlawed), into “secondary water,” which, according to 
Griffin, is allowed. This was all discussed thoroughly with QAI during the 
certification process, he said. “We were very, very concerned about it. The 
organic program is about due diligence. Due diligence is what you get hung 
on,” he said.

After talking to The Light, Griffin spoke with Holten at QAI about the 
certification, but neither Holten, nor anyone else at QAI could be reached 
by The Light for additional comments or clarification.

Erring on the side of caution

McClelland didn’t entirely trust the certification’s ruling, and has erred 
on the side of caution by withholding the silage from his organic herd since 
2003. “I was talking to Albert Straus,” he said, referring to West Marin’s 
original organic milk producer, “and he said, ‘I don’t think you’re supposed 
to feed ‘em that. . .’ I thought, ‘This is 35 acres out of the 800 acres 
that I farm,’ so I said, ‘It’s not worth it.’ So the last two years, we’ve 
taken it to our conventional cows.”

Still, his case raises the question of what, exactly, consumers are getting 
when they buy “organic.”

Interpreting the rules

“One of the issues back in ‘98 was to say there cannot be municipal sewage 
sludge used in organic,” said Ronnie Cummins, president and co-founder of 
the Organic Consumer’s Association. “The industry tried to allow that 
because that’s the norm on industrial farms.”

Consumers were concerned about the transmission of pathogens and parasites, 
as well as the chemical processes that wipe out pathogens, including 
chlorination. Nitrogen tends to increase during the decomposition process, 
and can combine with the chlorine to create nitrosamines, a known carcinogen 
also found in grilled food. People were also worried about other household 
wastes, such as detergents and paints that often go down the drain, in 
addition to human excrement.

“It’s sewage sludge that’s prohibited,” said Barry Baker, a technician at 
the Organic Materials Review Institute, a non-profit organization that 
specializes in the review of substances for use in organic production, 
processing, and handling. “Well, what’s sewage sludge? And animal manure is 
allowed. Well, what are animals?” he asked. “You have this gray area that 
nobody has really wanted to push the envelope on,” he said.

According to the USDA National Organic Program, sewage sludge is defined as 
“a solid, semisolid, or liquid residue generated during the treatment of 
domestic sewage in a treatment works. Sewage sludge includes but is not 
limited to: domestic septage; scum or solids removed in primary, secondary, 
or advanced wastewater treatment processes; and a material derived from 
sewage sludge.” This definition does not specifically mention how chlorine 
might change sewage’s composition.

The “Q & A” page on the USDA National Organic Standards Board website 
addresses the question of whether “reclaimed water” can be used on organic 
farms. “Generally, the National Organic Standards place no further 
restrictions on reclaimed water used for irrigation beyond those imposed by 
State Departments of Natural Resources. However, to fully answer this 
question, we would need to know how and from what source the water is being 
reclaimed,” it says.

“There’s been a lot of confusion, and the USDA needs to step up to the plate 
and rewrite the organic dairy requirements,” said Anita Sauber, an 
agriculture inspector with Marin County Department of Agriculture. “The 
problem with the standards right now is that there are many loopholes. The 
intent is clear in the requirement, but the way it was written there are 
loopholes, and they’re all being pursued.”
The future

Organic milk sells for about twice the rate as conventional milk, and is 
currently an $11 billion industry. Some are concerned that as large 
agribusiness conglomerates move into the organic arena, those companies will 
pressure conventional suppliers to make the switch hurriedly, and the 
standards will relax.

“The USDA seems to be very industry friendly, whereas the organic community 
grew up with rules that were very strict and consumer friendly,” said Ronnie 
Cummins, the executive director of the Organic Consumer’s Association.

Barry Baker at the Organic Materials Review Institute said he checks the 
federal registry for changes to the standards every day. “It’s going to be 
up to consumers and what consumers demand in how those big players are held 
accountable,” he said. “I think it’s important to be honest and shine a 
bright light on what’s going on.”

– John Hulls contributed to this report



©1995-2006 by the Tomales Bay Publishing Company / Point Reyes Light.


...........................................


>From David Keller:

Dear water and food consumers:

Is treated municipal wastewater suitable for use on feed crops for animals 
at farms with organic certification?
The Point Reyes Light presents this story this week.

This leads also to the question about the quality and use for Santa Rosa's, 
SCWA's and Petaluma's wastewater distribution plans, both for farms and 
released upstream of the intake pumps for SCWA's municipal water supplies.
See also, http://www.ccof.org/aboutorganic.php

The Sonoma County General Plan2020 is a good place to clarify this. The 
draft Water Resource Element of the General Plan comes up for Sonoma County 
Planning Commission review on Aug. 15.

Anyone with specific experience on regulations for crops produced with this 
water for organic food production - please share your thoughts.

Thanks!

David Keller
Bay Area Director, Friends of the Eel River
Petaluma


...........................................

>From Willard Richards:


All water contains human wastewater. Humans have been discharging waste for 
an unknown number of hundreds of thousands of years, and that waste 
permeates all water available to us. The only question is, what level of 
treatment is acceptable?

We generally accept that evaporation into the atmosphere then falling as 
rain is an adequate treatment, even though we know that rain is not always 
pure. We generally accept that Sonoma County Water Agency water is OK, even 
though there are wastewater discharges into the Russian River upstream of 
the SCWA intakes. It is my understanding that Sonoma County has more wells 
than any other county in California, and with some notable exceptions, we 
consider that well water safe even though leach fields are not far away.

If we say that water becomes unacceptable if it contains human wastewater, 
we say that all water is unacceptable.

The only question is the level of treatment and required purity. That 
question generates debate. While there is some consensus on allowable levels 
of coliform bacteria, arsenic, lead, etc., there is not a consensus on 
perchlorates from rocket propellant manufacturing. Many people become 
uncomfortable when the connection between wastewater and treated water is 
direct and obvious, but I do not think the directness of that linkage is the 
key question. As stated above, the key questions are adequacy of the 
treatment and the purity of the resulting water.

By and large, the chemical testing of water is straightforward and routinely 
done by the SCWA and many other laboratories.  It is very easy to determine 
the chlorine levels in the water sprayed on hayfields by collecting and 
testing it. Some are concerned about organic molecules, such as pheromones, 
which are not easily analyzed. (Are pheromones organic?)  My own position is 
that if water passes the SCWA tests and meets their standards, it is 
adequately safe. As we learn more, those standards will evolve.

I do not drink SCWA water because I do not like the chlorine taste. By the 
way, if we drink water with chlorine in it, why worry about spraying water 
with chlorine in it on a hayfield?

If there is a question about water quality and suitability, collect some and 
analyze it. If it passes the tests, it is OK.

Willard Richards

P.S. Water is not an organic molecule.