“The practice of using industrial residuals to enhance soil quality is neither new nor unique to British Columbia.  All jurisdictions in North America and Europe have rules or regulations governing how agricultural, industrial, and municipal residuals may be used on land.” 

1)    A limited list of materials that can be applied:  Unlike some jurisdictions, the Code only allows the use of specific materials for which we have data and a scientific track record of beneficial application to land.  Only a select number of materials fit this criterion.

2)    Maximum contaminant levels:  Consistent with the Organic Matter Recycling Regulation (OMRR), the Code uses the same quality parameters and maximum levels as for Class A municipal biosolids which are harmonized with the federal Fertilizers Act.

Comparison of Guidelines

3)    Land Application Plans:  The Code prohibits application of waste in quantities that would exceed the nutrient needs of the plants at the application site.  A qualified professional must prepare a land application plan.  In the land application plan, the qualified professional must predict the expected concentration of constituents in the soil, and calculate the amount of soil amendment that can be applied to provide for the plant or crop needs.

4)    Steps to ensure soil is enhanced:  The discharger is responsible for ensuring that the application of a soil amendment to land has a positive effect on the soil.  They must analyse the soil and the soil amendment, and then have a qualified professional calculate the predicted concentration of contaminants in the soil after land application.  The calculated level in the soil must stay below contaminated site criteria levels.

5)    Cannot cause pollution:  The final level of protection for any discharge of waste under a code of practice is the absolute prohibition against causing pollution as found in Section 6(4) of the Environmental Management Act.  This section prevents a person from introducing waste into the environment in a manner or quantity that would cause pollution. If pollution is being caused, a director may issue an order to address the environmental concerns.

the presence in the environment of substances or contaminants that substantially alter or impair the usefulness of the environment.

1. a rationale for excluding organic pollutants and pathogens from testing parameters;
2. an explanation for allowing Class B levels of contaminants to be landspread in a watershed, counter to OMRR regulations;
3. Verifiable, scientific analysis of the composition of representative samples of sewage sludge and pulp mill sludge – along with interpretations that demonstrate the rationale for allowing the practice.  It has been asserted in point 1 above that data and a scientific track record of beneficial application to land for this material exists;
4. Environmental and wildlife assessment studies completed and detailed baselines set prior to any land applications under the Code to evaluate the potential impact on flora and fauna that depend on the land and waterways for their sustenance; and a requirement for frequent and transparent monitoring to ensure swift action is possible in response to deviations from baselines.