Sewage Sludge Disposal on Agricultural Land

Published by the Government Accountability Office on 1977-05-23.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

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              A V AT L A 6 L E

                                UNITED STATES GENERAL ACCOUNTING OFFICE
                                        WASHINGTON, D.C.   20548



             The Honorable Douglas M. Costle                         MAY z     1977
             Administrator, Environmental
               Protection Agency

             Dear Mr. Costle:

                  We are currently reviewing the Environmental Protection
             Agency's management of sewage sludge disposal practices. Our
             review includes a study of the municipal sewage sludge manage-
             ment systems of Chicago, Los Angeles, ;lnd New York-New Jersey
             metropolitan areas. Our objective is co determine whether
             current sewage sludge disposal practices emphasize beneficial
             uses of sludge which are safe and environmentally acceptable.

                  We have identified a potentially hazardous situation
             which we believe warrants your immediate attention, Sewage
             sludge products having high amounts of cadmium are being sold
             or given away to the public for uncontrolled use. We appre-
             ciate the difficulties communities have in disposing of the
             increasing volume of sludge; however, this practice represents
             a potential health hazard.

                  As you know, cadmium is a toxic heavy metal which has
             been classified by the Occupational Safety and Health Adminis-
             tration as a suspected carcinogen. The Food and Drug Admin-
             istration believes that the levels of cadmium in the American
             diet are close to the tolerable weekly intakes developed by
             the Wcrld Health Organization and the Food and Agricultural
             Organization of the United Nations.

                  In June 1976 EPA published for comment a draft technical
             bulletin on municipal sewage sludge management.   The bulletin
             stated that numerous conditions affect the level of heavy
             metals that may be toxic to plants or taken up by crops and
             eventually consumed by humans.   It recommended that projects
             using sludge on croplands coinform to any limitations recom-
             mended by the Food and Drug Administration (FDA) or the
             Department of Agriculture (USDA).


     FDA recomnuended in its comments on the technical bulletin
that sludges containing more than 20 parts per million (ppm)
of cadmium not be used on agricultural land and crops in the
food chain. USDA scientists recommended that sludges con-
taining more than 25 ppm of cadmium not be applied to pri-
vately owned agricultural land unless the cadmium-to-zinc
ratio of the sludge is less than or equal to 1.5 percent.
In commenting on the draft technical bulletin, EPA's Office
of Solid Waste Management suggested maximum allowable cadmium
levels similar to those recommended by USDA scientists.

     We found that sewage sludge products with cadmium levels
substantially higher than the levels suggested above are
available nationwide to the public for possible use on agri-
cultural land, including home vegetable galdens. Some of
these sludge products contain approximately 3 to 7 times the
maximum level of cadmium recommended by FDA and exceed the
cadmium-to-zinc ratio suggested by USDA scientists. The
literature or labeling for the products we have identified
do not caution against use on croplands and, in fact, a
brochure for one sludge product indicates that the product
would be beneficial for use in vegetable gardens.

     In addition to the current sale and the give-away
programs of sludge products, municipalities are considering
other programs which would result in the use of sludge to
grow cr-os.  Your Agency's April 1976 report, "An Overview
of the Sludge Management Situation", recognized that large
communities are becoming more interested in the land appli-
cation of sludge and the possibility of selling crops grown
on such land to help offset sludge disposal costs.

     Sludge products containing toxic materials may eventually
be defined as hazardous wastes and regulated under the
Resource Conservation and Recovery Act of 1976 (42 U.S.C.
6901). However, we believe that, in view of the substantial
margins by which some sludge products currently available to
the public exceed maximum suggested levels, EPA should take
immediate action to define which of these products could be
used to produce food.  Action is also needed to inform the
public of potential health hazards involved and to assist
communities considering adopting sludge disposal systems
which use sludge in food production.



     We recommend that you prov de interim guidance on sludges
that are acceptable for agricultural purposes, including use
on home vegetable gardens, until such time as the requirements
of the Resource Conservation and Recovery Act are i-plemented.
We recommend also that you provide for public notification of
the potential health hazard associated with using sludge
products which are given away or sold and are deemed unaccept-
able for agricultural use.

     We shall appreciate receiving your comments on this letter
and on any actions you plan to take. As you know, section 236
of the Legislative Reorganization Act of 1970 requires the head
of a Federal agency to submit a written statement on actions
he has taken on our recommendations to the House Committee on
Government Operations and the Senate Committee on Governme 'tal
Affairs not later than 60 days after the date of the report
and to the House and Senate Committees on Appropriations with
the agency's first request for appropriations made more than
60 days afte: the date of the report.

     Covies of this letter are being sent to the Chairmen,
Senate Committees on Governmental Affairs; Environment and
Public Works; and Appropriations, Subcommittee on
HUD-Independent Agencies; to the Chairmen, House Committees
on Government Operations; Appropriations; and Public Works
and Transportation; and to the Director, Office of Managemert
and Budget.

                              Sincerely yours,

                              Henry Eschwege