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Safe Fields, Safe Food: Keeping Toxic Industrial Off the Farm and Out of Our Food

Since the beginning of the industrialized age, many sectors of the American economy have In a March 1998 report, Factory Farming: Toxic sought to deposit the detritus of their own Waste and Fertilizer in the United States, 1990- industries upon farmers, food producers and 1995, researchers found that during the five-year consumers. Two examples of this "dumping" period studied, more than 271 million pounds of which have recently garnered national attention toxic waste tracked by the EPA's Toxics Release are the use of toxic industrial from steel Inventory (TRI) were sent to 450 fertilizer mills, cement kilns, paper mills and other manufacturers and businesses that appeared to industrial processes in fertilizers used to grow be farms. Sixty-nine toxic chemicals were food and garden crops; and the land application represented in those wastes [1]. of sludge from plants that accept toxic wastewater discharges from Many of the wastes being put into fertilizers are polluting industries. taken from control equipment at factories. In other words, industries dutifully FERTILIZER capture in scrubbers and other equipment, only to turn around and spread the Ironically, state and federal regulatory agencies captured wastes directly onto productive farm may have encouraged the use of these practices. land. The situation represents a major threat to Steel production, cement manufacturing and health and the environment. many other industrial techniques generate wastes that contain dioxin, , , and There are currently no federal regulations other pollutants. However, because these wastes requiring fertilizer manufacturers to test their also contain lime, calcium, phosphorus, zinc or products to determine the amounts of heavy other minerals that are beneficial to agriculture, metals, dioxin, or other pollutants they may the Environmental Protection Agency (EPA) and contain, nor are fertilizer companies required to other state and federal agencies have encouraged list anywhere the sources from which they the "" of the wastes into fertilizers. In obtain minerals. In fact, hazardous steel mill the award-winning exposé "Fear in the Fields," waste has a special exemption under federal Seattle Times reporter Duff Wilson noted that at law that specifically removes least 26 states have programs in place to match all standards and requirements for disposal (i.e. hazardous waste generators with recyclers. testing, manifesting and tracking) if it is used for Industry consultant and chemist Ed Kleppinger fertilizer. Dick Camp, president of the Bay Zinc said, "The last refuge of the hazardous-waste Fertilizer Company of Moxee City, Washington, scoundrel is to call it a fertilizer or soil seemed mystified: "When it goes into our silo, amendment and dump it on farmland." it's a hazardous waste. When it comes out of the silo, it's no longer regulated. The exact same issued a complex amendment to the rules material. Don't ask me why. [2]" regarding hazardous waste recycling land disposal restrictions as those rules apply to "zinc The ramifications of this lack of regulatory micronutrient fertilizers" derived from oversight combined with EPA's endorsement of hazardous wastes. Within the complicated recycling have been demonstrated in very real regulatory jargon lurked a telling statement: economic terms on farms across the country. EPA's finding that today's standards are • Central Washington farmers have lost crops, not below a ''minimize threat'' level is cows and horses and traced the problem based on the Agency's inability at the back to fertilizers they used. present time to establish concentration • In Tifton, Georgia, a mixture of hazardous levels for hazardous constituents which waste sold as liming material killed more represent levels at which threats to than 1,000 acres of peanut crops. human health and the environment are • A uranium processing plant in Gore, minimized [emphasis added]. As the Oklahoma sprayed its on Agency has explained a number of grazing land and local residents believe that times, determining these levels on a the waste caused mutations in animals as national basis … has not yet proven well as devastating health problems in local possible. [7] residents. • Most recently, state officials in Washington In plain English, this means that the Agency has [3], and investigative journalists at the not yet determined what levels of in Dallas Morning News [4] tested Ironite, a fertilizer might be safe, yet they continue to fertilizer made from waste and allow, even encourage, the products to be used which is sold in garden centers around the to grow America's food. EPA will hold country, and found industrial-cleanup levels "stakeholder" meetings in Seattle with members of lead and arsenic. of the fertilizer industry and environmental groups in the fall of 1998. These are but a few examples of this practice gone awry, costing innocent farmers and local The Governor of Washington has gotten a bill community members their livelihood and health. passed in Washington's short legislative session; that legislation adopts extremely weak Canadian There are urgent environmental and public soil standards for metals that will not stop toxic health concerns resulting from the use of toxic waste from being spread on farms and backyard waste in fertilizer. Farmers and farmworkers are gardens. The New York legislature has proposed exposed to it in the fields. Food crops can take an outright ban on the practice of using toxic it up. Wildlife as well as farm animals may waste in fertilizer. However, there are currently consume it. (Dairy cows actually ingest a lot of no federal plans to adopt a national prohibition soil as they graze, for example.) The toxic on this practice, and indeed, EPA continues to constituents run off into that feeds appear supportive of the process. into surface water bodies and can be blown with soil, where people and pets track the toxic dust SEWAGE SLUDGE into homes. House dust is a significant toxic exposure route for children; dust in farmworkers' "I am appalled at what I would term the 'total homes tends to have higher concentrations of disregard for human health' and the fact that the pollutants [5]. Environmental Protection Agency is actively promoting and is, in fact, lulling communities Initial political response by state and federal throughout the United States into initiating governments is a major concern. In August programs for the composting of sewage sludge," 1998, the Environmental Protection Agency said Melvin Kramer, an infectious disease epidemiologist who has been researching the issue since the late 1970s. He says the EPA's example, the Cornell plan for sludge disposal poses "a significant Institute estimates that 90 percent of the dioxins health hazard to the population in general, but in wastewater entering a POTW will be retained especially to the elderly, children, and the in the sludge [11]. When that sludge is applied infirm, both in terms of nuisances as exemplified to farm fields, the crops may take up the toxic by excessive putrid odors and minor allergic constituents. reactions . . . to life-threatening diseases. [8]" Dr. Stanford Tackett, a chemist and expert on Sludge is the non-liquid portion of the waste that lead contamination, has warned, "The use of flows through a sewage treatment plant. As with sewage sludge as a fertilizer poses a more "recycling" of hazardous industrial wastes for significant lead threat to the land than did the their mineral content, the use of sewage sludge, use of leaded gasoline," he says. "All sewage or "," is being touted by many as a way sludges contain elevated concentrations of lead to recycle the nutrient potential of . due to the nature of the treatment process. … In theory, this could be beneficial both to From the standpoint of lead alone, sludge is farmers and municipalities, if human waste and 'safe' only if you are willing to accept a lowered were segregated. As the Cornell IQ for the young children living in the sludge Waste Management Institute at Cornell area. And what about the other toxins?" [12] It University notes, "While recycling sludges is a is important to note that in the U.S. desirable goal, caution is warranted since many Environmental Protection Agency (EPA) "Part pollutants are persistent and agricultural soils are 503" rules "allow the application of sludges with irreplaceable [9]." Indeed, sewage sludge from metals up to the ceiling limits to be used in most major metropolitan areas does not contain home gardens." [13] only the wastewater from residential areas, but also the toxic effluent from industrial Many communities, including metropolitan dischargers deemed too small to require their areas, are already marketing their sewage sludge own National Pollution Discharge Elimination for agricultural uses, either through direct land System (NPDES) permit from the state application or through retail sales as fertilizer regulatory agency. These small industrial products. "Milorganite," which has been dischargers may include metal plating produced by the city of Milwaukee for 70 years, operations, dry cleaners, hospitals and dental is one such product. Milorganite production has clinics (which may discharge , solvents, been fraught with problems, including two and other toxic chemicals), and any number of explosions; $4.5 million in costs associated with other businesses that can dump legally small repairs and other expenses related to the amounts of , solvents, , accidents; and violation of its DNR air permit polychlorinated biphenyls, and other chemicals for the discharge of volatile organic compounds down the sewer. What's more, there may be [14]. Chicago, Houston and Los Angeles also hundreds of industrial dischargers to one commercially market their sludge fertilizer. publicly owned treatment plant, which means Other cities give away their sludge, because as that, in the aggregate, the "small" amounts of one consulting firm put it, "Regardless of the toxics released by individual businesses add up solids treatment process employed, the residual to tons of pollution. is the waste of a wastewater treatment process, a byproduct that is not highly sought after." [15] The primary and secondary treatment utilized by most treatment plants involve to digest In public comments on the draft national organic wastes and are in no way intended or standards for organic agriculture, consumers able to handle heavy metals or synthetic have voiced their resounding opposition to chemicals. Thus, those compounds -- over sewage sludge [16]. In addition to what many 60,000 toxic substances and chemical believe are true health and environmental risks compounds [10] -- pass through the treatment from agricultural use of sewage sludge, farmers plant largely intact and remain in the sludge. For and food producers must face the perception of risk by many consumers and the economic 5 "Pesticides in household dust and soil: Exposure impacts of buying decisions based on those pathways for agricultural families," Environmental perceptions. Consumers appear generally Health Perspectives. 103(12): 1126-1134. unaware of the extent and scope to which 6 Toxic Wastes Used in Fertilizer in Washington: An sewage sludge is already being used in Analysis of the Federal , 1990-1995, Environmental Working Group, 1998: conventional agriculture. Washington, DC. p. 1. 7 40 CFR Part 268 Hazardous Waste Recycling; CONCLUSION Land Disposal Restrictions; Final Rule, Federal Register: August 31, 1998 (Volume 63, Number 168) IATP's Food Safety Project will continue to 8 Melvin N. Kramer, Ph.D., executive summary of raise these important emerging food safety testimony given Oct. 1, 1992 before the U.S. House issues to consumers, farmers and policy makers of Representatives, Committee on Merchant Marine through education and through partnership with and Fisheries, Subcommittee on Coast Guard other groups active in these areas. We will also Navigation, Hearing on Ocean Dumping seek to document the extent of the problem -- Enforcement and the Current Status of Research Efforts, pp. 1-2, as cited in Toxic Sludge Is Good For particularly in the Midwest, where the You, Lies, Damn Lies And The Public Relations of industrial waste-derived fertilizers has Industry, John Stauber and Sheldon Rampton, received little media attention and where use of Common Courage Press, 1995, pp. 107-108. fertilizers to grow corn, wheat and soybeans is 9 The Case for Caution: Recommendations for Land high. Application of Sewage Sludges and an Appraisal of the U.S. EPA's Part 503 Sludge Rules Working The ultimate choices reside with the farmers, Paper, Ellen Z. Harrison, Murray B. McBride and when they make informed choices about what David R. Bouldin, Cornell Waste Management inputs they use on their fields to raise food; and Institute August 1997, p. 3. with consumers, when they select food to feed 10 Toxic Sludge Is Good For You, p. 104. 11 The Case For Caution, p. 3. their families. Everyone has the right to know 12 Stanford L. Tackett, "The Myth of Sewage Sludge what was used to grow their food, and to choose Safety," delivered at the Municipal Sewage Sludge the foods they believe are safest and healthiest. Conference, State College, PA, May 21, 1994, as cited in Toxic Sludge Is Good For You, p. 108. To learn more about IATP's work on agriculture 13 The Case For Caution p. 9. and the environment, visit our web site: 14 97-6 Milwaukee Metropolitan District http://www.iatp.org/. For information on the Report Summary, Food Safety Project, contact Jackie Hunt http://www.legis.state.wi.us/lab/97-6summary.htm 15 Evaluation of Alternative Technologies for Solids Christensen, Institute for Agriculture and Trade Handling at the Metro [Minneapolis/St. Paul, MN] Policy, 2105 1st Avenue South, Minneapolis, Plant, CH2M Hill, January 1998, p. 23. MN 55404. Phone: 612-870-3424; fax: 612-870- 16 "USDA to Make Fundamental Changes in 4846; e-mail: [email protected]. Proposed Rule on Organic Standards," USDA press release, May 8, 1998. Citations: 1 Factory Farming: Toxic Waste and Fertilizer in the United States, 1990-1995, Environmental Working Group, 1998: Washington, DC. p. ii. 2 Ibid. 3 Phone conversation with Robin Schoen-Nessa, Washington State Department of Agriculture, May 21, 1998. 4 "High Levels of Lead Found in Fertilizer; Arsenic, Metals Used Are Safe, Company Says," Dallas Morning News, March 30, 1998.