Submission to CCME Sewage Biosolids Discussion Phase 2, by Ottawa Citizens Against Pollution by Sewage

Submission to CCME Sewage Biosolids Discussion Phase 2, by Ottawa Citizens Against Pollution by Sewage (OCAPS)   29/07/2011

Ottawa Citizens Against Pollution by Sewage (OCAPS) has previously protested the fact that the first phase of the CCME public consultation on Sewage Biosolids never happened.  That is because the e-mail submission form that the CCME requested the public use could not acknowledge receipt of our submission.  The completed form was not copyable before sending, and our request for a copy resulted in the acknowledgment from CCME that they had no record of it.  While we did successfully send a follow-up letter to CCME,  the failure of our original submission to get onto the CCME public record raised the question of how many other submissions from the public failed to reach CCME awareness. Rather than correct the submission form and reissue the call for public submissions, CCME stated the public would be fully consulted in Round 2 of the proceedings.  That left the field open for the sewage biosolids spreading lobby of government and industry stakeholders to determine the format for Phase 2, without the inclusion or study of matters of concern to rural residents and the public at large. 

After reviewing the CCME questionnaire, it seems that all that is being requested in this consultation is whether one agrees with developing a Canada-wide approach for an already done deal that is, land application of biosolids. The CCME is not even paying close attention to their paper "Emerging Substances of Concern in Biosolids: Concentrations and Effects of Treatment Processes".  According to the CCME site, the purpose of the ESOC literature review and study was to inform the draft policy statement and draft supporting principles.  The study clearly demonstrates some major substances of concern in biosolids applied to land such as triclosan, triclocarban, ciprofloxacin, etc.  The fact that this information is being minimized with sentences in the study report such as "A small number (12/57) of pharmaceutical compounds were observed at concentrations exceeding..."   12 out of 57 sounds like a large number!  And "Many pharmaceuticals (nearly 30% of those tested) were not detected in the final biosolids products".  The converse of that is that 70% of those tested were detected in the final biosolids products, which is a lot more than were not detected!   Also from the CCME consultation document: "it is currently unknown what risk if any is posed by ESOC detected at these low levels, detection does not immediately imply a risk associated with proper municipal biosolids management. "  However, there is no mention that there likely are risks associated with at least some of these compounds and that the further assessment of risks is extremely important and should be conducted before major decisions with regard to land application.  These are all examples of alarming findings made to sound less alarming, both in the report and in the consultation document. 

 OCAPS has received a copy of a letter dated July 11th to an Ottawa City Councillor from  city sewage manager Dixon Weir, saying "The land application of biosolids in Ontario is a well established program with regulations developed by the Ministries of Health and Long Term Care, Environment and Agriculture Food and Rural Affairs. The Canadian Council of Ministers of Environment (CCME) also strongly supports this practice as a beneficial use of a valuable resource," and  "The CCME has also developed a model to estimate the green house gas emissions from biosolids management, which shows land application as one of the most favourable options."

When the senior city manager in charge of spreading sewage biosolids on farmlands in Canada's capital says the CCME "strongly supports this practice" because cycling into the agricultural food chain is a beneficial and green way to get rid of our most pathogenic and chemically toxic municipal sewage wastes, and says this weeks before the CCME public consultation on the matter is completed,  it certainly sounds like the fix is in at the highest level, and nothing groups of concerned citizens such as OCAPS has to say can change an outcome that has been predetermined by the sewage biosolids spreading lobby.  Note that the Ontario provincial sewage biosolids policy was enacted and has been continued without any input or participation from the rural people living in the vicinity of sewage biosolids spreading operations. The Biosolids Utilization Committee that is the stakeholders committee responsible for monitoring and recommending sewage biosolids spreading policy in Ontario is comprised entirely of those in government, industry, and colleges with a vested interest in spreading sewage biosolids on rural lands. Organizations of rural people living near sewage biosolids spreading operations (such as OCAPS) are denigrated as NIMBYs and denied participant status on the BUC.  This is akin to the tobacco industry and their researchers being the only voices allowed to advise government regarding the health risks of smoking.

However, because the CCME is made up of other provinces besides Ontario, we still have faint hope that our concerns will be heard and acted on. And we believe there is value in submitting our comments on this subject for the public record, so that they can be used in future class action lawsuits  by people who are suffering health problems,  by people seeking to stop environmental degradation, and by those who suffer a loss of property value because of  noxious sewage biosolids spreading by municipalities aided and abetted by provincial governments whose Ministries of Health, of Environment, and of Agriculture are ignoring their fiduciary duty to protect the public and the commons.  When government will not listen to nor investigate complaints and concerns,  telling people  "there has never been a problem with sewage biosolids spreading when done according to the Guidelines" is a self-fulfilling  prophecy, not fact.

A current outstanding and extremely troubling example of this failure to listen and investigate is the lack of response to our letter to Premier McGuinty requesting a rural health study of people living near past sewage biosolids spreading operations as far back as 15 years, to see if they have a higher incidence of dementias than people who have not been exposed.  A comprehensive rural health study would also determine if there are higher incidences of cancer, of immune diseases, and of antibiotic resistant diseases in the population  near sewage biosolids spread fields.  The fact that the outbreaks of antibiotic resistant superbugs that are closing Ontario hospitals frequently occur during the spring and fall months when the spreading of sewage biosolids containing these pathogens about the countryside is at peak, has been fastidiously ignored by government  Departments of Health and infection control researchers. 

Here is the letter submitted January 31, 2011 via the premier's web-site:

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Dear Premier McGuinty,

Are rural residents of Ontario who live near agricultural fields fertilized with municipal sewage sludge being infected with prions in the aerosol pollutant cloud during spreading?  Is this causing the higher incidence of dementia lately observed in the rural vs urban population?  Researchers at the University of Zurich have just determined that aerosolized prions are 100,000 times more infective than ingested prions  ( http://www.plospathogens.org/article/info:doi/10.1371/journal.ppat.1001257 ).  And a study in Portugal where 80% of municipal sewage has been spread on farm fields since 1991 or longer,  found a 40% increase in rural over urban rates of dementia (http://www.biomedcentral.com/content/pdf/1471-2377-10-42.pdf )

 If prion diseases are being spread to rural people breathing the pollutants from sewage spreading, there is a 10 to 15 year incubation period between the time of the exposure and the development of the disease. Since the widespread practice of spreading sewage on agricultural land only began 15 years ago in Ontario, one would expect an increased incidence of dementia in the rural vs urban population to show up over the past 5 years, and to increase with each subsequent year to match the increase in sewage spreading.  If we halt all sewage spreading now, those already infected will continue to develop prion disease and die in increasing numbers each year for the next 10 to 15 years.  

Please give this matter your urgent attention. A reasonable response would be to declare a moratorium on sewage spreading in the coming year while a comprehensive health study of rural Ontarians is conducted by the Department of Health. The location of all sewage spread fields is on record with the Ministry of Environment. People living in close proximity to sewage spreading sites can be identified and studied to see if they have a higher incidence of dementia.  If so, the temporary moratorium on spreading sewage can be made permanent.

We are bringing this to your attention because many thousands of lives may be at risk. Note that the responsibility for regulating sewage spreading is in the process of being transferred from the Ministry of Environment to the Ministry of Agriculture. The Ministry of Health appears to have bowed out altogether!  The Biosolids Utilization Committee that advises government policy is entirely composed of stakeholders with a vested interest in spreading sewage on farmland, and "hears no evil, sees no evil, and speaks no evil".

The sewage lobby has produced a study showing 90% of mouse prions are deactivated by anaerobic sewage treatment.  What they don't say is that other research found human, cow, and sheep prions are 100,000 times more difficult to deactivate than mouse prions, and therefore survive anaerobic treatment or composting intact. The contention that prions are not transmitted through urine and sewage has also been disproven, and research indicates this may be the route by which CWD is spreading in deer populations
( http://ww.biggamehunt.net/forum/detection-infectious-prions-urine-soto-et-al-2008 ).

Other research found that CJD is in the population at large but is being misdiagnosed 100% of the time, which invalidates the waste water industry claim that it is being kept out of sewage at source.   ( http://transmissiblespongiformencephalopathy.blogspot.com/2011/01/alzheimers-prion-and-neurological.html ) 

Finally, one would expect to find evidence of CJD in young people, if exposed to infectious prions as children.  New variant CJD is in fact most prevelant in 20 and 30 year olds, and misdiagnosed as mental illness ( http://www.healthtree.com/articles/dementia/causes/infectious-diseases/ )

We have reason to fear the beginning of a health disaster that will be thousands of times worse than the Walkerton tragedy and the tainted blood scandal combined, as any deaths that unbiased researchers can link to the spread of prion disease in Ontario and elsewhere in the past few years will represent just the tip of the iceberg. Your government inherited the sewage spreading policy as a fait accompli, so you have nothing to lose and our appreciation to gain by safeguarding Ontario's rural population from potential problems with it.

Sincerely,

Jim Poushinsky (MSW retired)
Chair, Ottawa Citizens Against Pollution by Sewage

Our appeal to AMMI Canada  (formerly the Canadian Infectious Disease Society) for support for our request that the Ontario government conduct a comprehensive rural health study invoked the following response:
 

Dear Mr. Poushinsky,

Thank you for your email regarding biosolids. It is very clear that this is an issue of importance to you and your group but it is not an issue for our small association to take on nor will it become a priority for this association.

Brett Filson
Executive Director - AMMI Canada

When the organization that is the voice of medical researchers and infectious disease control experts in Canada considers itself too small an association to even consider supporting a request for government sponsored research  into possible health problems arising from sewage biosolids spreading, the independence of professionals to act ethically and follow their conscience when faced with pressure from the sewage biosolids spreading lobby is obviously compromised. This is not speculation.  Some ten years ago OCAPS brought the case against sewage biosolids spreading to the attention of AMMI's predecessor, the Canadian Infectious Disease Society.  After examining the issue, CIDS publicly called for a moratorium on the spreading of sewage sludge. A week later they revised this call to say that there should be a moratorium "where proof of safety was insufficient".  When we asked why they changed their position, they informed us the sewage operators had mounted a lobby that jammed their phone and fax lines and effectively shut down their ability to function, and only relented when they reworded their call in a sufficiently vague way that sewage biosolids spreading operations could continue unabated. We believe such tactics of intimidation are the reason AMMI refuses to take a stand today, and the reason that no professional in Canada dares to publicly criticize the sewage biosolids spreading program out of fear of losing their job, ruining their career, and being sued.  Even the CBC is forbidden to examine the controversy around sewage biosolids spreading, and can only cover it from a "human interest" angle.  The Ottawa Citizen ran a story about a spill of sheep scrapie prions into the sewers from a government lab, and quoted authorities saying no harm would come from this. When we discovered the sewage biosolids containing the scrapie had then been spread on local farmland and asked the Citizen to correct the story they refused, telling us their readers did not know city sewage was being spread so would not understand the risk. Sewage biosolids spreading on agricultural land remains the best kept official secret in Canada.  

OCAPS is an organization of rural people in the Ottawa area who have long been concerned about the possible adverse health and environmental consequences of sewage biosolids spreading. OCAPS was founded in 2001 after the only two participants representative of the rural public on the Advisory Committee to the Environmental Assessment Review of Ottawa's initial 5 year sewage biosolids spreading program submitted a minority report objecting to the conclusions of the committee majority of sewage biosolids lobby stakeholders, and calling instead for a moratorium until proper scientific studies examining safety issues were conducted.

One of the safety issues we raised concerned the bland assertion from the sewage biosolids lobby representatives (including City of Ottawa, MOE, MOH, OMAFRA, and OFA) that spreading sewage biosolids on tile drained agricultural land was perfectly safe because the tile drains were all 3 feet down. Since studies showed sewage pollutants penetrated 2 feet into the soil, the tile drains ensured the water table could not rise up and leach the contaminants into the underlying aquifer rural people drew well water from, and also ensured pollutants would not reach the tile drains and be washed out to pollute surface watercourses.  When nobody would produce the technical criteria to prove tile drains were a minimum of 3 feet below the surface, I went to the local tile drain installation company and talked to their operations manager. He said the tile drains were started as low as possible in the field boundary ditches they drained into, but had to rise to ensure drainage. When they reached plough depth of 16 inches from surface, a cross ditch had to be dug and the drains started over. He also said it was difficult to keep to the minimum 16 inch depth in the field due to natural depressions that occur. Upon being confronted with this factual evidence that large areas of typical tile drained fields were within the 2 foot depth that pollutants sink to, the sewage biosolids lobby stakeholders dismissed this finding with the unsubstantiated remark that "any pollution resulting from this would be inconsequential".  In fact no field research had ever been conducted to measure cake sewage biosolids pollutant levels from tile drains, and the one test that was done of liquid sewage application by government in the London area found visible sewage flowing out of the tiles into the bordering drainage ditch 20 minutes after a light rain began.

Further investigation by OCAPS uncovered a wealth of information on problems arising from spreading sewage biosolids across North America. After screening and forwarding relevant articles and studies to Ottawa City Councillors, they voted to stop Ottawa's sewage biosolids spreading and instructed staff to find acceptable disposal alternatives.  Ottawa Mayor Chiarelli said before the vote that in the two years since amalgamation this was the single issue that the City Councillors had spent the most time considering and were best informed about. This information included a review of the scientific literature by Medical Officer of Health Dr. Cushman that found a surprising lack of scientific evidence, and concluded on the basis of a single peer reviewed published study of a small group of Ohio farmers that it was safe to spread sewage, although he also recommended further set-backs and restrictions than those in Ontario's MOE Guidelines. This study has since been contradicted by a peer reviewed and published much larger Ohio rural health survey which found a significant elevated incidence of a broad spectrum of illnesses in people living within 1 km of sewage biosolids spreading operations, compared to those living further away.

The majority of Ottawa City Councillors who reviewed the subject themselves disagreed with this Dept. of Health assessment.  In explaining the Health Department's position, Dr. Cushman told us "It took enough scientific research showing health problems with smoking to fill city hall to the rafters before the DOH could act, and you're nowhere near that with sewage spreading", and "Even if every rural well was contaminated by sewage spreading and you all got sick, that wouldn't constitute an epidemic because you're less than 5% of the city population."  When sewage was piled on a neighbouring farm field and made people downwind sick so they had to rush a young child to hospital with an infection, evacuate a home, and temporarily shut down a school bus maintainance business on the property, Dr. Cushman was immediately notified. He waited two weeks until the pile had been covered, people got better, and business operations resumed, and then concluded it was too late to investigate. Therefore the claim that nobody has ever been made sick because anecdotal reports don't count for the Department of Health remains officially correct in this instance.  Such inaction on the part of health officials who believe in risk management that maximizes economic benefits for those in the sewage disposal business at the expense of the rural population makes a mockery of the Hippocratic Oath to "do no harm". 

Ottawa's moratorium against spreading sewage biosolids lasted for two years, and was only reinstated after a new council had been elected.  Staff  recommended restarting the biosolids spreading to the new council without giving OCAPS notice and the opportunity to speak to the issue.  When we protested this violation of City policy regarding public consultation staff apologized, but the decision to resume spreading had already been made.  Even when allowed to speak in Committees,  members of the public are limited to 5 minutes each, while staff are given unlimited time to present their case for biosolids spreading.  They are also able to respond to the public without any opportunity for us to correct their misinformation.  At one committee meeting the OCAPS delegation was kept waiting for over 10 hours, by which time most of those wanting to speak had to leave.  And when I finally got to speak, I was cut off at 3 minutes by the Committee Chairman, not 5.   These are undemocratic tactics designed to suppress free speech, being used against rural residents by demagogues holding public office who couldn't care less about the rural townships forcibly amalgamated into the expanded city of Ottawa. 

The  Ministry of Health in Ontario has moved beyond inaction, to actively interfering to prevent attempts to do research on contaminants in sludge. When researchers in Sweden discovered levels of carcinogenic PBDE flame retardents in plastics were doubling every 5 years in breast milk, they traced the source to sewage sludge being spread on farmland, and  stopped this practice in their country. Consequently Dr. Rob Hale initiated a study of PBDE levels in North American sewage sludge biosolids being spread on farmland, and asked for samples from cities that he would analyze at no cost to participants. OCAPS asked the City of Ottawa staff to send a sample. They refused, saying a single sample would not be signiificant. Dr. Hale then offered to analyze multiple samples of Ottawa's sewage. Staff again refused. OCAPS then made arrangements to ship a sample at our time and expense. When the City staff refused to give us a cupful of sewage biosolids on the grounds that "all the sewage belongs to the city and you can't have any" we asked MOH Dr. Cushman for help in obtaining a sample. Instead he angrily accused us of "harrassing city staff" by this request, and said he would no longer speak to us.  Maureen Reilly in Toronto  succeeded in getting a Toronto City Councillor to get a sample for Dr. Hale.  Like the other samples he analyzed,  the PBDE level  turned out to be about 20 times higher than Sweden's. And unlike Sweden, some 95% of PBDEs in North America's sewage biosolids are the most carcinogenic form.  Why doesn't this matter to our Departments of Health, Environment, and Agriculture?

The blacklist of rural residents concerned about health problems with sewage biosolids spreading in Ottawa has apparently been passed on to Dr. Cushman's successor, as MOH Dr. Levy refused to respond to the request of residents of Vernon that he issue a stop order to prevent spreading biosolids upwind and adjacent to their rural community during the past H1N1 crisis. Dr. David Lewis' research while at the EPA has linked the chemical aerosols emitted from sewage spreading to a lowering of immune response in those breathing these aerosols, making them more susceptible to bacterial and viral illnessses. Since there was a shortage of H1N1 vaccine in Ottawa, it was common sense not  to  spread sewage upwind of a community that included those with immature or deficient  immune systems such as young children, pregnant women, babies, and people receiving immune suppressing drugs for cancer treatments, MS, etc. The community took up a petition signed by the majority of households in Vernon requesting the sewage spreading be stopped, at least until the H1N1 crisis was over,  but MOH Dr. Levy refused to even discuss the matter, despite appeals by several Ottawa city councillors that he do so. The sewage spreading lobby fix is evidently a fait accompli with the Department of Health in Ontario, which has bowed out and left the Ministry of Environment to deal with health related matters that arise from sewage biosolids spreading. 

When rural residents confronted the sewage biosolids spreading operation at the Vernon site, a truck driver hauling sewage on contract to the City threatened to ram an Ottawa Sun reporter's camera down his throat if he took his picture. The Ministry of Environment and City of Ottawa officials insisted the cloud rising from the spreading operation and blowing off the field was "just water vapour" that contained no pollutants whatsoever. When asked why it smelled so bad, and what chemicals were causing the odour, the MOE response was "smell doesn't matter".  When asked why the MOE and City were allowing the sewage to be spread on the flood plain of the South Castor River that flows past Vernon, the MOE response was "there is nothing in the regulations about flood plains". This fact of omission has permitted sewage sludge biosolids to be spread on prime agricultural land, which is mostly on flood plains, right across southern and eastern Ontario for the past 15 to 20 years.  Agricultural studies show some 10% of surface material remains on the surface after disking.  At an application rate of 10 tonnes per acre for the corn crops typically grown in sewage biosolids, this means 1 tonne per acre of sewage biosolids are available to be washed into surface waters in spring snow melts, heavy rains, and floods, and end up in rivers and lakes, yet no studies have been done by the Ministry of Environment nor by the Ministry of Agriculture to assess the damage this has caused over the past two decades. Instead these Ministries deny that such run-off can even occur, in the untested belief that leaving a 10 meter strip beside waterways is completely protective of the surrounding environment.

While OCAPS is an entirely volunteer organization with no funding whatsoever, we undertook to do some testing for run-off from sewage biosolids spread fields at our expense, following the collection procedures demonstrated to us by the city of Ottawa. In the case of the Vernon sewage biosolids field we got a reading of less than 10 e-coli in the field boundary ditch just before it emptied into the South Castor River. After a heavy rain the reading jumped to 990 e-coli per 100 ml pouring into the river. The river itself at that point had a reading of 150 e-coli, so the sewaged field ditch was adding a loading over 6 times higher than what was already in the river.  To put this in perspective, a reading of 200 closes beaches, and a reading of 1 e-coli in well water makes it unfit to drink. This spring we studied a second sewage biosolids field boundary ditch at Devine Road in Cumberland ward of rural south east Ottawa. The ditch also drained fields that had been spread with sewage biosolids the previous fall. Readings in the ditch during the spring spreading in dry weather were 100 e--coli. After a light rain a few days later the readings jumped to >4000 per 100 ml. The actual number could not be measured because the testing lab had not anticipated such an extremely high count.

In Ontario the operator of a sewage biosolids disposal site must obtain a Certificate of Approval from the MOE. The City of Ottawa is the holder of the Certificates for such agricultural sewage fields within the city's greatly expanded rural limits. The operator is required to notify the municipality and the MOE in case of a spill into the environment. When we reported the Vernon spill into the South Castor River to the city of Ottawa and to the MOE, the MOE referred us back to the city. City staff dismissed the reading on the grounds that e-coli readings in ditches are generally higher after rains due to bird droppings and such washing off fields. When we reported the second extremely high field reading, the same excuse was made. No effort was made by the City to conduct tests themselves. Since the city was not prepared to admit contamination, we assume they did not report to the MOE. When the operator of a sewage spreading operation is also the regulator charged with investigating spills, and when the Ministry of Environment defers to the city to explain away any possible contamination from sewage spreading, a closed loop is formed and there is little possibility of the city ever finding itself at fault and therefore liable, nor of either the city or the MOE doing follow-up research that would lead to changes for the protection of human health and the environment.  A reasonable response from government would be to thank us for our efforts and to undertake comprehensive field studies to determine the extent of pollution from sewage biosolids field surface and tile drain run-off following rains, and during spring snow melts and floods.  Unfortunately, it appears the fix is in at both city and provincial levels of government, both of which are totally unwilling to even consider the possibility that there are  problems with the sewage biosolids spreading program. 

In the Ottawa area where corn is the principal field crop fertilized with sewage biosolids, huge flocks of migrating Canada geese land and feed on the after-harvest stubble in fall and early spring. In spring the fields are flooded with snow melt when this occurs, so the geese are covered with and ingesting sewage sludge residue for several weeks before flying north, where they are the principal food for the Inuit for the two following months.  No research has ever been conducted to see if the Inuit and other First Nations who eat these geese on a regular basis are having  health problems related to the carcinogenic and toxic chemicals and pathogens in the sewage sludge the geese have ingested or are carrying on their bodies.  OCAPS wrote last year to the federal Health Minister advising her of the need for such a study, but we have received no reply from Health Canada. The first defence of bureaucracy at all levels in Canada appears to be to ignore information about possible problems arising from sewage biosolids spreading. The second defence is to delay responding until it is too late. When representatives from concerned citizens groups across Ontario went to Queen's Park during the SARS outbreak to give a press conference requesting the province not spread the SARS contaminated sewage from hospitals on farmland, the cabinet secretary who attended told us "this is a really important issue, but you aren't even on the government's radar screen!"  Despite our issuing this warning a month before the scheduled sewage spreading, the provincial government waited until a month after it had been spread before writing to thank us, with regret it was too late to take any preventive action. 

It is noteworthy that the Ontario Clean Water Act passed in reaction to the Walkerton tragedy set up River Conservation Authorities across the province, supposedly to protect the source of Ontario's drinking water. However in reality, only municipal drinking water intakes are being protected in the initial 5 year mandate, and the aquifers that rural Ontarians on private wells draw from are not protected at all. It is within this 5 year vacuum of avoiding any concern for rural aquifers that the rush to complete the acceptance of sewage sludge spreading on farms as "normal agricultural practice" is happening, along with the implementation of legislation that will permit sewage sludge to be composted with municipal green bin collections for unregulated use. We are told that the farmer's advisory committee that defines farm practice was not a party to including biosolids spreading as farming, rather this definition was imposed by government.

 At the public meeting required under the Environmental Regulations and held in Ottawa by the Ontario MOE with regard to the proposed Green bin composting of sewage biosolids,  OCAPS pointed out that the regulations would allow 99 e-coli and 1 salmonella in the finished compost as indicators for all other pathogens, yet no thought had been given to preventing explosive regrowth of pathogens in warm or cool and moist storage and field conditions, and no health warnings would be required on compost sold for unregulated use by the unsuspecting public. MOE chair Eileen Smith stopped us from speaking because we had "too much to say" and ended the meeting an hour early after a composting industry spokespeson angrily demanded to know why the MOE had not told them about the potential for pathogen regrowth.  Worse, when the indicators are deactivated or killed, more robust pathogens take over, esp. in Class A sludge.

The public outcry against such sewage pollution "normalizing" initiatives has led Ontario to the ultimate strategy of getting the CCME to recommend these proposals, which is an obvious reason for the present CCME sewage biosolids use discussions with the flagrant pro-spreading bias being trumpeted by sewage manager Dixon Weir in Ottawa. Missing from all of this is any awareness or incorporation of feedback from the rural people who have witnessed the deleterious effects of sewage biosolids spreading first-hand, and who want it stopped.  Also missing is any meaningful consideration of alternatives such as land-filling and energy from waste facilities like high temperature incineration, hypercritical oxygen, plasma furnaces, and other such solutions being employed in progressive countries of Europe and in Japan, and recently in start-up companies in the USA and Canada.  Nor has any thought been given to the loss of Canada's prime farmland when the full extent of contamination by pathogen and chemicals in municipal sewage wastes is understood, and these past spread fields  are quarantined as unfit for growing food for human consumption for the next 20 years as is happening in parts of Europe.  And no thought has been accorded the pollution of our surface waters and aquifers that Canadians rely on for drinking water by these same pathogens and chemicals, despite the growing awareness that pharmaceuticals and other chemicals in sewage are now detectable in our city drinking water intakes.  

The lack of ethics on the part of professional civil servants and politicians promoting sewage biosolids spreading is highlighted by the provincial strategy of giving away sewage sludge to farmers as a "free gift", which includes the unsuspecting municipal taxpayers paying for all trucking and storage and spreading and advertising costs.  Because it is a "free gift" the Federal Fertilizer Regulations do not apply, and the protection those regulations give farmers against being sold fertilizers that are contaminated with toxic substances that cause harm are by-passed. Similarly the Transport Regulations that protect  motorists and first responders by labelling hazardous substances do not apply because the sewage is not a commercial product. In Ontario trucks carrying 40 tonne loads of sewage sludge biosolids which contain up to 2 million e-coli per 100 ml (1/2 cup) as markers for all the other pathogens and toxic chemicals flushed down sewers, are permitted to travel the roads with no warning signage whatsoever, just the MOE's CofA number on the side and the company sign on the door. In Ottawa the contractor actually labelled these loads as "ORGANIC FERTILIZER" in large letters, and the MOE said this was perfectly acceptable, because the dioxins and most other carcinogenic chemicals  were carbon compounds and thus "organic". Neither the MOE nor the Department of Transport nor the River Conservation Authorities have given any thought to a truckload of such sewage spilling into a river upstream of municipal water intakes, nor to the safety of motorists and first responders to the crash of a vehicle carrying such unlabelled hazardous substance. The present rush to have the CCME give it's stamp of approval to the practice without comprehensive research to determine if it has caused health problems in rural people and pollution of the environment is part and parcel of this attitude of official negligence, while enabling the sewage biosolids spreading lobby to expand to the max. 

Extreme care is taken to protect sewage workers in municipal plants from the noxious contents in sludge, yet no thought is given to protecting the public who may come in contact with it during transport, storage, and spreading on agricultural fields.  The priority of all involved appears to be to hide what is happening from public awareness and to deny any deleterious effects that arise.  When Ottawa City Council was first asked to approve spreading the city's sewage biosolids on farmland, they were told the big lie that "all pathogens are killed in the sewage treatment plant".  Since there were no pathogens  the Council unanimously approved the initial sewage spreading program. Councillors were never shown the study conducted by the U. of Ottawa that found that despite a 1 log reduction in numbers there remained 1.5 million e-coli per 100 ml in the finished sewage biosolids.  The same study found many other bacterial pathogens and viruses and parasites were hardly reduced at all.  When we participated on the EA Public Advisory Committee assessing Ottawa's initial 5 year sewage biosolids spreading program, we asked to speak to the scientist chairing the EA technical advisory committee about pathogens in the sewage biosolids. When he appeared his first words were " There's nothing to worry about because all the pathogens are killed in the sewage plant."  I slapped the Ottawa U study on the table in front of him and said "you have obviously never read this!" So all-pervasive and effective was this lie that when OCAPS asked a private lab to analyze a sample of sewage field run-off years later, the lab director said "why bother, the pathogens are all killed in the sewage treatment plant".  He was shocked by the resulting reading of 990 e-coli from the ditch bordering the first field, and more than 4000 e-coli per 100 ml from the second field ditch. 

The European E-coli outbreak killed 50, with 800 more contracting life-threatening illnesses, and 4000 getting sick.  It was traced to contaminated Egyptian seeds. This particular strain 0104:H4 is only found in human feces.  Although there is no proof that the Egyptian seeds were grown with waste water, the use of human waste to grow crops is a common practice in Egypt. Research indicates that Egyptian sludge is  very high in pathogens. This serious outbreak is yet another wake-up call to phase out the  application of waste water and sewage sludge on land where we grow our food and feed.

It is very difficult for those relatively few of us with knowledge of the risks to human and animal health and the environment associated with the spreading of municipal sewage biosolids on agricultural land to watch the escalation of spreading under the guise of officially sanctioned propaganda. This year Ottawa doubled the amount of sewage spread to 45,000 tonnes, and bragged that it was the first city in Ontario to spread all of it's annual sewage wastes on farmland. The Devine road spreading operation was two km. upwind of an elementary school in the rural village of Vars. When the City began aerial spreading 100s of tonnes in winds gusting to 90 km per hour blowing directly towards the school, I visited the school and asked the principal to keep the children indoors until the spreading was over. This he could not do without the authorization of the School Board, and there wasn't time for that.  As I watched the children in the playground inhaling the aerosols and pathogens in the sewage dust I wondered how many would get sick as a result of this exposure, and thought how these youngsters don't even have the status of guinea pigs because the doctors their parents take them to will not know the source of infection was sewage spreading.

Airborne toxins and pathogens and persistent organic chemicals which blow in the winds and precipitate down elsewhere from sewage spreading are non-existent as far as the MOE, DOH, and DOA are concerned.  In 2001 I spoke in place of environmentalist Maureen Reilly at the Biosolids 2000 Conference at Queens Park in Toronto.  I highlighted the airborne modelling research by the U. of Arizona that had concluded people were safe if they were 10 kilometers downwind of sewage spreading, because the incidence of airborne bacterial infection was reduced to 1 in 10,000 at that distance.  I asked how the sewage industry could ignore this research and continue spreading 45 meters from people's homes?  In response the sewage lobby faulted the model used. The U. of Arizona revised their research to say that you were actually safe 35 meters downwind, and have since received the lion's share of research money to continue churning out studies "proving" sewage biosolids spreading is absolutely safe, and the original sludge rule "guesstimates" that were based on permitting the average toxic and pathogen loadings in sewage biosolids to be applied as fertilizer to our foodlands were totally protective of human health and the environment.  This despite Dr. David Lewis, the EPA Director responsible for doing the safety studies, publicly stating they were never done, and the USA National Academy of Scientists agreeing after a literature review that the research is insufficient to show sewage biosolids spreading is safe.  
 
What little research has been done by authorities in Canada is also questionable.  A study done in Ontario to see what happened to dioxins in sludge that had been applied to a farm field couldn't find the dioxins that were known to have been in the sludge. The study concluded that this proved it was "perfectly safe" to apply sludge containing dioxins to farmland. When I questioned this conclusion and asked what happened to the dioxins, i.e. did they leach into surface waters, did they get incorporated into the crops, did grazing animals ingest them, did they volatize into the air and come down elsewhere; the answer was "it doesn't matter because the amount was so small it was safe to begin with,  we just did the study to assure the public."  We now know dioxins and hormone disrupting chemicals damage organisms in parts per trillion.  So the argument of "small amounts are harmless" is no longer valid.

Another study in Ontario found a significant amount of heavy metals had disappeared from a sewaged field spread years earlier. While some metals were found in the surface ditches and deeper in the soil, the bulk of the missing metals were unaccounted for. The only "clue" was the observation that weeds growing beside the field had elevated heavy metal readings. The obvious hypothesis that the missing metals had gone into the crops grown on the field was never made.  The failure of officials to follow-up any research indications of problems affecting the food and water supply and causing  health and environmental contamination constitutes an ongoing whitewash of sewage biosolids spreading and of deficiencies in the regulations under which it is conducted.  The spreading may well be causing untold harm, but we do not know at this time because the practice is so strongly defended by government and industry as a cheap and easy solution to disposing of North America's municipal sewage wastes. 

The economic argument underpinning this belief does not stand up to scrutiny.  In the case of Ottawa,  a decade ago it was costing  $35 per tonne to bury garbage in the city owned landfill at Trail Road. The city initially said it would cost $85 per tonne to bury sewage with the garbage, however OCAPS was able to get an admission from the city that the actual cost was "less than $15 per tonne".  City staff justified the $85 per tonne figure by saying since they owned the dump they could charge themselves whatever they wanted. The intent of such creative accounting was to maintain the myth that it cost much more to landfill sewage biosolids than to spread it on farmland. As the cost of such spreading was $35 per tonne at that time, it would in fact have cost the city less than half the cost of spreading on agricultural land to simply landfill it at the city dump, a savings of over a million dollars per year.  Today with storage, trucking, and spreading costs at $85 per tonne and climbing, the savings from landfillling Ottawa's sewage would be over $2 million per year.

Likewise the argument that sewage sludge "wastes space in the landfill and shortens the life of the dump" is riduculously overblown. In fact the City cake sewage biosolids are 70% water which disappears, shrinking them to just 30% by volume. The solids decompose anaerobically into methane gas which is captured and either flared to convert it to CO2 or used as biofuel to generate electricity.  Only about 15% of the initial volume is left, and it mostly disappears into the spaces in the solid garbage.  The real reason behind the push to keep sewage biosolids out of landfills is because real estate tycoons are making fortunes building subdivisions on lands adjacent to dumps that are better suited for industrial purposes, and don't want the smell of sewage in the air to upset potential home-buyers.  Yet the same authorities who seek to protect city residents from the obnoxious odours of sewage biosolids several kilometers away have no problem forcing it upon rural home-owners who live as close as 45 meters from the spreading of hundreds or thousands of stinking tonnes that continues for days or weeks.  This policy has effectively reduced rural residents to the status of second class citizens, unworthy of the protections for health and quality of home life extended to their urban counterparts.  As for the report to CCME that allegedly proves spreading sewage biosolids on farmland is the best way to prevent greenhouse gases, how can this be better than landfilling it and capturing the gases under a cap to convert to CO2 which is 30 times less harmful than the methane generated by anaerobic decomposition?  The sewage biosolids spread and ploughed under farm fields anaerobically decompose just like the land-filled sewage biosolids, but the methane produced in farm fields is not captured and goes into the atmosphere.  Understanding this is just common sense!

The Canadian Council of Ministers of the Environment has the power to fully investigate the case against spreading sewage biosolids on farmland.  At present you have only been listening to the sewage biosolids spreading lobby, with their vested interest in maintaining control of the huge amounts of taxpayer money that has been diverted to this practice over the past 15 years. We request that you delay making any decision or recommendation on the disposal of sewage biosolids in Canada until you have fully and adequately consulted those with knowledge of the case against spreading it on agricultural lands. This would best be done by conducting hearings at a conference in which funds would be made available to bring such expert witnesses as Dr. David Lewis, Dr. Caroline Snyder, Dr. Rob Hale, Dr. Marilyn Cameron,  Dr. Murray McBride,  Maureen Reilly, and others, including representatives of the various citizen groups fighting sewage sludge spreading in their rural communities, and representatives from major organizations opposed to or with major concerns about sewage biosolids spreading such as the Sierra Club, Rodale Institute, National Academy of Sciences,  Cornell Waste Management Institute,  National Farmers Union,  etc. 

If you will not do this, you will have to live with your conscience, knowing that you failed to fairly hear and weigh both sides of this matter, and Canadians will ultimately all suffer the negative consequences of your rash actions and hold you responsible.  Instead we urge you to please join in doing the right thing for all of us, and for the future generations of life on this planet.   

sincerely,

Jim Poushinsky  MSW (retired)
Chair, Ottawa Citizens Against Pollution by Sewage (OCAPS)