Sludge Watch ==> British Columbia -letter to Minister to stop avalanche of sludges

[Maureen Reilly]

   *A local group in BC is working on the sludge issue. They are
   looking for groups to sign on to the letter below. Since I know some
   groups here are working on sludge, I am passing this on. Please
   contact Rob at *rwiltzen at telus.net <mailto:rwiltzen at telus.net> for
   more info.


   * *


   * *

August xx, 2007

Hon. Barry Penner

Minister of the Environment
Legislative Buildings
Victoria, BC V8V 1X4

Dear Minister Penner:

The Soil Amendment Code of Practice, recently passed and due to come into 
effect September 1, 2007 will allow the landspreading of industrial toxic 
waste, including pulp mill sludge, fly ash and domestic and industrial 
sewage and water treatment sludge. We urge you to immediately reverse this 
decision and not allow any further spreading of hazardous industrial waste 
on B.C.’s farms and forests.

Industrial waste treatment and domestic sewage treatment result in sludge 
containing the harmful substances removed from liquid waste before treated 
effluent is returned to the environment. It is incomprehensible that this 
toxic sludge can be referred to as ‘beneficial’ for ‘soil amendment’ or why 
it is considered appropriate to return the removed toxins to watershed 
lands, where they will inevitably end up polluting clean water in the 
environment. Similarly, fly ash is captured by pollution prevention 
equipment on combustion facilities in order to prevent the release of toxic 
particulates into the atmosphere. The deliberate application of these 
captured toxins to animal grazing and food producing lands, as well as to 
watershed lands, defies logic.

There has been no comprehensive analysis of pulp mill sludge to identify all 
the potentially harmful chemicals it contains. We do know, however, that 
pulp mill sludge includes a range of heavy metals, benzenes and phenolics. 
Both industrial sludge and domestic sewage sludge can contain a wide array 
and variability of bacterial and chemical contaminants extremely harmful to 
human and environmental health. Many of these chemicals could have 
persistent effects on food-growing soil lasting well beyond the 38 months 
designated as the maximum time before planting food crops.

There has been no assessment of the impacts on wildlife of dumping hazardous 
waste in farms, fields and forests. Wildlife does not read ‘No Trespassing’ 
signs and nor do they refrain from ingesting food sources from these lands 
for any designated period.

There is significant history to the issue of landspreading pulp mill sludge 
and we refer you back to previous efforts to allow virtually unregulated 
landspreading. Environmental concerns that were raised then remain today 
unaddressed. The current Code of Practice is even weaker than the previously 
proposed regulations. It allows a wider range of industrial sources, it has 
an extremely limited list of chemical parameters for testing, and a severely 
flawed process with no allowance for any compliance monitoring or 
enforcement. BC citizens have no recourse as truckloads of sludge are dumped 
in their communities.

Studies have been completed on alternatives for disposal of sewage and 
sludge. The direct application of untreated waste has not been proven to be 
safe, while other options have been shown to be viable from an economic, 
technical and regulatory perspective.

Minister, we urge you to be guided by the Precautionary Principle in this 
matter and order thorough testing and consideration by independent 
scientists. Industrial waste needs to be contained as we work towards 
cleaner production, not spread by the truckload throughout the province.

Crofton Airshed Citizens Group

Reach for Unbleached