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BC Groups Protest Sludge Landspreading to Minister of Environment |
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September 14, 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 effective as of September 1, 2007 will facilitate the land-spreading 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 therefore
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,
is unacceptable.
There has been no comprehensive analysis of pulp mill sludge to
identify all the potentially harmful chemicals it contains, and the
required analysis of the sludge (per section 6) is inadequate. Since we
are not fully aware of all the chemicals that could be in sludge, it is
impossible to conclude that the sludge is safe simply because dangerous
toxins have not been adequately screened for. 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, including pharmaceuticals and endocrine disrupting
chemicals, 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 do 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, and we encourage you to put efforts into these rather than
continuing to promote the application of sludge to agricultural land.
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. In particular, the use
of technologies that can recover resources from sludge – including
water, heat and biofuel – should be investigated and put into place to
avoid future pollution of our waters from sludge land application.
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.
Jay RitchlinDavid Suzuki Foundation
Stuart Blundell Pulp and Paper Workers of Canada
Lisa Matthaus Sierra Club of Canada
Andrea Reimer Wilderness Committee
Christianne Wilhelmson Georgia Strait Alliance
Pat Reichert Island Natural Growers
Tzeporah Berman Forest Ethics
Steve Lawson First Nations Environmental Network
Delores Broten Reach for Unbleached
Robert Wiltzen Crofton Airshed Citizens Group
Mae Burrows Labour Environment Alliance Society
Samuel Godfrey Islands Organic Producers Association
cc. Shane Simpson, NDP Environment critic
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