A Resolution Calling on the NYS Legislature and Department of Environmental Conservation to Ban the Use of Sewage Sludge in Compost and as a Soil Amendment or Fertilizer due to PFAS Contamination.

January 30, 2023 

Summary: This resolution calls for New York State to ban the recycling and  use of sewage sludge (also known by the PR term “biosolids”i) as a fertilizer or soil amendment, including the co-processing (composting or anaerobic  digestion) of sewage sludge with food waste or yard waste, due to  contamination with PFAS and other toxic substances. 

WHEREAS, in the process of treating municipal and industrial sewage, wastewater treatment plants produce a solid, semisolid, or slurry residual material that is  commonly called sludge (or biosolids), as a by-product of wastewater treatment  processes.ii 

WHEREAS, following treatment, the sludge may be dried and disposed of at  landfills or applied as a soil amendment or fertilizer to agricultural croplands and  landscapes either without further processing alone or in combination with plant,  food or yard wastes.iii 

WHEREAS, sewage sludge is known to contain numerous contaminants:

1. EPA has identified 352 pollutants in sewage sludge including  pharmaceuticals, steroids and flame-retardants, but cannot regulate these  pollutants in sewage sludge since data as well as risk assessment tools are  lacking;iv and  

2. Testing of sewage sludge from municipal wastewater treatment plants  everywhere tested around the U.S. has detected per and polyfluorinated alkyl substances (PFAS), also known as “forever chemicals”v; and  

3. Sewage sludge may also be contaminated with heavy metals.vi 

WHEREAS PFAS are called “forever chemicals” because the strength of the  carbon-fluorine bond prevents them from breaking down naturally. This class of  chemicals includes more than 12,000 different compounds with various chemical  properties. PFAS are commonly used in thousands of products, from nonstick  cookware to firefighting foam and protective gear, because they have desirable chemical properties that impart oil and water repellency, friction reduction, and  temperature resistance. PFAS as a class have a wide variety of distinct chemical  properties and toxicities; for example, some PFAS can bioaccumulate and persist  in the human body and the environment, while others transform relatively quickly.  The PFAS that do transform, however, will become one or more other PFAS  because the carbon–fluorine bond they contain does not break naturally. It is for  this reason that PFAS are termed “forever chemicals.”vii 

WHEREAS organizations such as the International Agency for Research on  Cancer (IARC), the Agency for Toxic Substances and Disease Registry (ATSDR),  and the EPA have linked exposure to PFAS (particularly PFOA-perfluoroctanoic  acid and PFOS-perfluoroctanesulfonic acid) to multiple cancers, thyroid  dysfunction, small changes in birthweight, and high cholesterol.viii 

WHEREAS, in Spring 2022, the state of Maine banned all land application of  sewage sludge and other biosolids because of documented PFAS contamination of  soils, well water, farm products including milk, grains, and vegetables, farm  livestock, and the bodies of farm families as a result of the spreading of sewage  sludge on farmland;ix and 

WHEREAS PFAS “forever chemicals” and other hazardous chemicals in the  sewage sludge are known to contaminate the resulting compostx or anaerobic  digestate; and 

WHEREAS PFAS compounds are readily absorbed by plants and they  bioaccumulate up the food chain, whether they are in livestock feed, the human  food supply or plants or animals eaten by wildlife; and 

WHEREAS PFAS compounds leach into groundwaterxi and are extremely  persistent in soil (and the bodies of people and other animals),  

NOW, THEREFORE, in view of the foregoing substantial harmful and long lasting adverse impacts of the application of sewage sludge in any form on lands  and the coincident impacts on air and water resources, Zero Waste Ithaca, a  fiscally sponsored organization in New York State, hereby resolves as follows:  

1. Zero Waste Ithaca supports (1) a ban on the recycling of sewage sludge  (AKA biosolids) for use as a fertilizer or soil amendment; (2) the land  application of sewage sludge and fertilizers or compost made with sewage 

sludge; and (3) a ban on the co-processing of sewage sludge with food waste and/or yard waste in a composting operation or in an anaerobic digester.  

2. Zero Waste Ithaca further resolves to advocate for these bans and to  educate the public on their necessity to protect the environment, the food  supply, and public health.  

IN WITNESS WHEREOF, the organization named below acknowledge its  approval and support of this Resolution. 

Zero Waste Ithaca 



Passed unanimously by 19 members of Zero Waste Ithaca:

Caroline Byrne
Renee Carver
Sean Debromsky
Diane Cohen
Jessica Franken
Joel Gagnon
Susanne Jensen
Emily Jernigan
Yayoi Koizumi
Jonathan Latham
Maria Driscoll McMahon
Amina Mohamed
Gay Nicholson
Sasha Paris
Max Pospisil
Gretchen Rymarchyk
Sid Vaughn
Wendy Vaughn
Allison Wilson

Date: 1/30/2023 

If your organization is interested in passing a similar resolution, please contact sewagesludgeresolution@gmail.com managed by Zero Waste Capital District.

i John Stauber and Rampton, Sheldon. “The sludge hits the fan” (Chapter 8). Toxic Sludge is Good For You: Lies, Damn Les, and the Public Relations Industry. Monroe, ME, 1995: Common Courage Press.   

ii Wastewater treatment – Sludge treatment and disposal | Britannica.

iii What is Sewage Sludge? | Center for Food Safety. 

iv U.S. EPA Inspector General. Report: EPA Unable to Assess the Impact of Hundreds of Unregulated  Pollutants in Land-Applied Biosolids on Human Health and the Environment. Report #19-P-0002,  November 15, 2018  

v Arjun K. Venkatsan & Rolf U. Halden. May 15, 2013. National inventory of perfluoroalkyl  substances in archived U.S. biosolids from the 2002 EPA National Sewage Sludge Survey. Journal of  Hazardous Materials. vol. 252 – 253, pp. 413 – 418.  

vi Federal regulations require wastewater treatment plants to periodically test their sewage sludge for 9  metals. Through Freedom of Information Law requests, I (Tracy Frisch) obtained several sets of metal  test results for Glens Falls sewage sludge. On January 27, 2021, Murray McBride, PhD, a now emeritus Cornell soils professor whose specialty is metals, stated, “The levels of a number of metals that can be  

potentially harmful to soils or to crop quality, including copper, zinc, lead and cadmium are all at  concentrations much higher in the Glens Falls sludges than in uncontaminated New York soils. The  repeated application of these sewage sludges to agricultural fields as fertilizers will cause their  concentrations to increase in the topsoils . . .” 

vii National Academies of Science, Medicine, Engineering. Guidance on PFAS Exposure, Testing, and  Clinical Follow-Up. Washington, DC, 2022: National Academies Press.  

viii Ibid. 

ix Institute for Agriculture and Trade Policy. “Lessons from Maine: Food, Farms and Forever  Chemicals — Understanding and Addressing the Harmful Legacy and Ongoing Challenge of PFAS  and Agriculture” (Recording of May 18, 2022 webinar).  

x National Academies of Science, Medicine, Engineering. Guidance on PFAS Exposure, Testing, and  Clinical Follow-Up. Washington, DC, 2022: National Academies Press.  

xi “PFAS in Drinking Water – PHDMC.” PFAS in Drinking Water, Ohio Department of Health, 3 Dec. 2019.

Image from Sierra Club and Ecology Center (Michigan).

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