URGENT: Request to renew sewage spreading ban in Ottawa

08/04/2015

Dear Mayor Watson and Councillors, and Members of the Ottawa Board of Health,

We are writing to request you renew the City of Ottawa's earlier ban on the spreading of sewage sludge "biosolids"  from the Robert O. Pickard  sewage plant on agricultural lands in the Ottawa area. For the two years the former moratorium was in effect, this sewage was safely buried in landfills with garbage. This can be done again, so there is no necessity to spread it on farmland this spring. 
 
In previous correspondence we drew your attention to the fact that there is 4 times more phosphorus than corn plants can use at the application rate for utilizing all the nitrogen, and requested a study of the field run-off during rain and snow melt flooding to determine the extent to which this is contributing to the toxic algae blooms in our rivers and lakes.  

The scientific awareness of the risk to human health and the environment from the pathogens and chemical wastes in sewage sludge has greatly increased in the years since Ottawa resumed disposal by spreading it as free fertilizer for some farmers willing to incorporate this hazardous waste into their soil.  It is past time to properly review and study the health problems and environmental contamination this is causing for rural and urban residents of our city.

Until this can be done we ask that you invoke the Precautionary Principle and suspend all sewage spreading. For the short term, it can be buried in approved land-fills. As mentioned in our earlier letter, the former Plasco Demonstration Facility, now at a bankruptcy price since it is not economical for garbage, may well have the potential to be adapted for safe and beneficial disposal of all Ottawa's sewage sludge. If it is not suitable, there are other proven high temperature facilities that can be built to serve this purpose. During the public participation phase of Ottawa's Environmental Assessment of the initial 5 year sewage spreading program, some 70% of the 100 or so participants hearing the presentations chose high temperature incineration as the preferred disposal method; with spreading it on agricultural land, and landfilling it, receiving only 15% support each. Yet afterwards city staff chose to ignore the wishes of the informed public and recommended spreading sewage on farmland as their only preferred option, continuing to this day.  

The Organic Consumer's Association is campaigning to stop the spreading of sewage sludge on farmland. They say on their website:

"Toxic sludge is poison - Sewage sludge contains everything the sewage treatment plant was able to remove from the sewage - plus every new chemical and pathogen formed in the mad synergy of this chemical soup, including virulent, antibiotic-resistant bacteria created through horizontal gene transfer. Scientific evidence has confirmed that municipal sewage sludge contains hundreds of dangerous pathogens, toxic heavy metals, flame-retardants, endocrine disruptors, carcinogens, pharmaceutical drugs and other hazardous chemicals coming from residential drains, storm water runoff, hospitals, and industrial plants. Sewage sludge is a form of hazardous waste and needs to be contained and isolated, not spread on our gardens and farmland!"  (Ottawa's sludge also contains the chemicals in garbage leachate collected from the Trail Road and other landfills).   See

https://www.organicconsumers.org/campaigns/stop-toxic-sludge

Ontario guidelines permit 2 million e-coli in each half cup of sewage sludge, as markers for all the other pathogens and chemicals in sludge. Ottawa's sludge is spread at a rate of 10 tonnes per acre to fertilize corn crops.  Keep in mind that beaches are closed to swimming if water samples exceed 200 e-coli, and 1 e-coli in well water makes it unfit to drink. The e-coli remain in the sewage particles, so wherever e-coli readings from Ottawa's sewage are found, all the other chemicals and pathogens in the sewage are present too. Canada's guidelines are based on the US EPA's sludge regulations.  The creation of these regulations was a deeply flawed process, as documented by EPA whistleblower Dr. David Lewis. See

http://www.independentsciencenews.org/health/how-epa-faked-the-entire-science-of-sewage-sludge-safety-a-whistleblowers-story/

For evidence of the hazardous chemicals in sewage sludge and the failure to prevent environmental contamination from them that the EPA admits to, see the following EPA references:

http://water.epa.gov/scitech/wastetech/biosolids/tnsss-overview.cfm

http://www.epa.gov/oig/reports/2014/20140929-14-P-0363.pdf
 

One of the fastest growing unaddressed health concerns is the risk of transmission of all forms of fatal dementia through sewage sludge.  See

http://alzheimerdisease.tv/alzheimers-disease-spreading-faster-via-biosolids-reclaimed-water/

http://www.nejm.org/doi/full/10.1056/NEJMoa1404401

As well, Dr. Adriano Aguzzi at the University of Zurich has found that the risk of infection from breathing dementia causing prions in aerosols is many times greater than from ingesting them. The high infection rate varied very little with the concentration of prions in the mixture,  it depended on the length of time it was breathed.  Almost all lab animals breathing the aerosols for more than a minute contracted fatal prion disease.  See

http://www.wired.com/2011/01/airborne-prions-disease/

All the prions excreted by all the residents of Ottawa with dementia are concentrated in the 45,000 annual tonnes of Ottawa's sewage sludge biosolids.  The sludge is being mechanically separated into tiny bits and aerially spread on farm fields for up to 5 days at a time, with no regard to wind speed or direction, and no warnings issued to those downwind who are breathing the pollution cloud. Recent research has determined there is no safe distance downwind of sewage spreading or tilling of soils containing sewage sludge contaminants. This makes sewage spreading a disaster in the making for transmission of deadly disease outbreaks such as e-bola, where the virus or bacteria is in the sewage particles windblown in the pollution cloud. See

http://pubs.acs.org/doi/abs/10.1021/es200566f

http://www.eng.yale.edu/peccialab/research_biosolids.html

http://www.biomedcentral.com/1471-2458/2/11

However guidelines continue to allow it to  be spread 50 meters from a rural neighbour's property line, and 500 meters from residential areas. If you can smell the stench you are breathing in potentially harmful chemicals and pathogens. The daily spreading has been known to continue for 5 days on large fields. The prions persist indefinitely in the soil, and even after being disked in, up to 10% of the sludge remains on the surface, to blow in dust that is breathed many kilometers downwind in dry weather.

It is generally acknowledged that rural residents are suffering a higher rate of dementia than urban residents. A study in Portugal in 2006 found a 40% higher incidence.  See

http://www.biomedcentral.com/1471-2377/10/42

However no study has been done to see if the incidence is highest in people who are close to sewage spread fields.  Since sewage spreading on some of Ottawa's fields has now been happening over a period of more than 15 years,  we are asking the Ottawa Board of Health to commission a longitudinal health study to determine if there is a higher rate of dementia in people living in close proximity to these sewage contaminated farms now and in subsequent years.

Also, a double blind study in Ohio published in 2007, found that residents living within a kilometer of sewage spread fields had a higher incidence of a wide range of illnesses than those rural residents living further away. See

http://www.ejnet.org/sludge/aeoh2007.pdf

This study contradicted the earlier self-reporting study of some farmers who used sewage biosolids in Ohio, that has been relied upon by the sludge spreading industry (and by former Ottawa M.O.H. Dr. Cushman in his report to Ottawa Council)  to assert that sludge spreading had proved harmless.

We would like to see Ottawa's Board of Health commission a repeat of the 2007 Ohio double-blind study in the Ottawa area, to determine if the same higher incidence of illness near sewage spread fields is affecting our residents. If so the fact that the study results are repeated in 2 different studies would be conclusive scientific proof of harm. 

Please note that city councillors voted for the moratorium despite the recommendation of M.O.H. Dr. Cushman that sewage spreading be continued using the Best Management Practices he proposed. At the time of that vote Mayor Chiarelli told Council that in the two years since amalgamation the sewage spreading was the single issue that councillors had spent the most time and were best informed on, and so he believed they would make the proper decision. The moratorium lasted 2 years until the following election, after which the moratorium was lifted at the request of city staff by the deciding vote of uninformed new councillors who did not hear the case against spreading because Ottawa Citizens Against Pollution by Sewage were not given notice of the proceedings. This failure to notify us was contrary to the city's long standing policy of openness to public participation. After the vote City Staff apologized for failing to include us, but said the vote to reinstate was final, and the matter could not be reconsidered for at least 2 years.   

We remind you that it is the fiduciary duty of both City Council and the Ottawa Board of Health to protect the well being of all the residents of Ottawa from the potential harm to health in the city's sewage sludge.  It is not acceptable to refuse to properly investigate because it is inconvenient or costly to do so, or because "risk management" says the ease of getting rid of sewage sludge this way is deemed to outweigh the health risks to the much smaller rural vs urban population. The Hippocratic Oath says to protect people from harm, it does not say it's okay to overlook harm to a relative few,  for the convenience of the many!  People are all equal in Canada as decreed in our constitutional Charter of Rights and Freedoms, " 15. (1) Every individual is equal before and under the law and has the right to the equal protection and equal benefit of the law without discrimination".   

For the record, we requested a month ago to speak to the Ottawa Board of Health about this issue, and have to date received no reply.  It is unacceptable for concerned rural residents to be ignored on city practices with the potential to cause untold harm to their families and neighbours!  Until this matter is considered in the light of fresh evidence and mounting concerns about harm, and  resolved to the satisfaction of rural people,  we ask that you reinstate the moratorium on the spreading of Ottawa's sewage sludge.  

This is an urgent matter, as without City Council's intervention, the spreading will begin as soon as the snow melt is complete and fields dry out sufficiently to hold the tractors, trucks, and heavy equipment.  We do not think it is coincidence that the spring and fall outbreaks of antibiotic resistant diseases that close hospital wards often coincide with the spring and fall aerial spreading of sewage sludge containing these pathogens throughout rural Ottawa.

Also, if the federal government had not misinterpreted the Fertilizer Act by declaring it doesn't apply to fertilizer that is given away for free because it is only deemed a commercial product if it is for sale, the sludge spreading would be banned because it does not meet the standards for health and environmental protection in the Fertilizer Act. While Ontario recognizes the sewage sludge is a hazardous product, it has left it to the agricultural sector to administer the spreading program. This means the only way to get the awareness of the Ministry of Health about health problems is via the Boards of Health at the municipal level of government in our municipalities.  That is why we are asking for a proper investigation into the health risks of spreading Ottawa's sewage on Ottawa and area farmland by Ottawa's Board of Health, which can then make recommendations to both City Council and to the Province on behalf of our citizens. 

As a final thought to consider, would anyone who has read and looked into this want to live next to or downwind from fields being spread with Ottawa's sewage sludge? Would you knowingly stand downwind of sewage spreading with your family in the belief it is perfectly safe? Would you want your children exposed in their school playground to sewage being spread in an adjacent field? If in all honesty you are not willing to subject your family and pets to the risk of harm from nearby spreading of city sewage sludge, how can you in good conscience force it upon others?  Please do the right thing and put a stop to this noxious practice now!  

Sincerely,

Jim Poushinsky   MSW (retired)
Chair, Ottawa Citizens Against Pollution by Sewage
RR#1 Edwards, Ontario K0A1V0