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The sludge story is a long one, dating to antiquity. (See related story, Civilization and Sludge). In China, it was used directly for farm fertilizer for thousands of years. In rural pre-industrial Europe, outhouses were sufficient. Dealing with human waste was not a real problem until the large concentration of people in cities. Then outbreaks of cholera and other diseases carried in human waste began in earnest, especially during rainy seasons. In England, for instance, waste was often disposed of in alleyways, then carried by rainstorms through the streets of London. Conditions went from awful to differently awful with the invention of the flush toilet by Thomas Crapper in 1837 (we are not making this up).

The flush toilet enormously increased the water usage of cities and moved the sewage from the streets to the Thames River, which became an open sewer, and from which London obtained its water supply. Following the pattern of repairing the system rather than re-thinking and re-designing, British engineers developed the first modern sewage treatment plant, which attempted to remove most of the water added by the flush toilet. It concentrated the waste into a vile, smelly substance they called "sludge," named after the deposits at the bottom of ponds.

The English model has been copied throughout the industrialized countries. As industrial chemicals came into common use, they, too, were washed into the sewage system, and out again into the sewage plant outfalls. In the U.S., the pollution from older wastewater treatment plants and the efforts of environmental advocates spurred passage of the Clean Water Act. This provided huge subsidies for communities to "improve" their treatment plants to remove toxic pollutants from the plant outflows. This often translasted into concentration of the toxic chemicals in the sludge.

By the late 1970s, cities were beginning to have difficulties with their modern treatment systems. Sludge incinerators began to be recognized as major polluters, and many were shut down. Ocan dumping of sewage sludge, used by major cities such as New York, began to backfire. The sludge, unbroken by the sea, had deadened large areas of the bays and harbors and fouled the fishing banks. Under pressure from the environmental movement and fishing interests, Congress passed the Ocean Dumping Act, which would end the practice by 1992.

By 1981, the Reagan EPA recognized the need for an alternative to ocean dumping and incineration. Together with the Federation of Sewage Works Associations they worked out a plan to sell the idea of land application of sewage sludge to the public. The Federation changed its name to sound totally innocuous: the Water Environment Federation. They held a contest to rename sewage sludge to sound better, and the winner - "bio-solids" became the trade name (euphemism, actually) for sewage sludge used in the public relations campaign to change the perception of sewage.

By the time the Ocean Dumping Act took effect, there were companies waiting to convert municipal "bio-solids" into an "effective soil conditioner and natural fertilizer" (actual quotes from a Wheelabrator BioGro advertising flyer). Schemes abounded, from composting to heat drying and pelletization to direct land application of raw sludge.

In 1992, the EPA passed regulations, called Section 503 (or Part 503) of the Clean Water Act amendments, that regulated land sludge application. Formulated by a committee led by a scientist who was also a consultant and stockholder of a sludge processing company, the regulations allowed land application of materials that would previously had been classified as hazardous waste. It allowed an unbelievable 840 parts per million (ppm) of lead, 57 ppm mercury, and 85 ppm cadmium, for application to non-agricultural land (homes, golf courses, forests, etc) and 300 ppm lead to cropland. (In contrast, if soil in Massachusetts is contaminated with 300 ppm, it must be reported as hazardous waste. Yet here was the EPA ruling that 300 ppm lead was perfectly fine for sludge applied to land.) Furthermore, the regulations leave dozens of other metals, thousands of organic chemicals, asbestos, and radioactive isotopes completely unregulated and untested.

By 1997, several large companies, such as Wheelabrator BioGro and N-Viro, were involved heavily in sludge composting and heat drying. Because the EPA's Section 503 regulations legally allow huge amounts of toxic materials in "fertilizer," companies such as N-Viro can legally add ash from cement kilns and incinerators to their products. The situation is complicated by the fact that some mainstream environmental groups openly support land application of sludge, ignoring the implications of industrial waste contamination in the sludge.

In August, 1997, the Cornell Waste Management Institute completed a major study of sludge application and composting, and agreed with the assessment of some environmental activists and researchers that the EPA's regulations were flawed and did not protect the public health. However, even the Cornell researchers' recommendations for sludge standards did not really question the practice of land application, and left in place the lead level of 300 ppm as acceptable for land application.

Grassroots activists have the heavy responsibility of not only uncovering environmental threats, crimes, and disasters, and pushing for cleanup of the environment, but also providing alternatives to their communities and answers to the politicians and bureaucrats. It is not enough to say "no sludge here" because in the next breath they will ask "So where do we put your toilet waste?"

Long-term, we at CQS believe the answer lies in wholesale conversion to home/apartment composting toilets and community greywater (kitchen, bath, and laundry washwater) treatment systems. Home composting toilets are available for less than $1000 each, and last for many years. That is less than 10 years of New York City's costs per home for sludge processing alone. Similar economics apply to many other cities and towns. Industrial wastes must be removed at their source: there is no excuse for toxic substances in community wastewater. The goal must be zero discharge.

Short-term, we can demand:

1. Standards based on "background" concentrations of heavy metals - the amount found in unsludged, non-irrigated West Coast farmland. The Dutch sludge standard is also a good starting point. (See the Sewage Sludge Fact Pack, available from Environmental Research Foundation.)
2. Zero tolerance of organochlorines, other organic chemicals and solvents, asbestos, and radioactive isotopes.
3. Low-heat drying or composting of all sludges to eliminate pathogens and runoff, and disposal in secure (concrete-lined) landfills.