Published in Common Dreams on March 3, 2004

Juliet said to Romeo, "What’s in a name? That which we call a rose by any other name would smell as sweet." When Juliet spoke to Romeo in Capulet's orchard, she had nary a thought about sewage sludge. You might think that her suggestion, that a thing is what it is, not what it is called, would have the Environmental Protection Agency crying "O Happy Dagger" and plunging a knife into its heart; but alas, this is not post-medieval Verona but Orwellian Washington where the EPA would have us think that sewage sludge is compost.

The Environmental Protection Agency (EPA) is proposing that the government's definition of compost include sewage sludge. The rule change is couched in a December 10, 2003 Federal Register notice about proposed revisions to the Comprehensive Procurement Guidelines (CPG). It would consolidate all compost designations under one item called "compost made from recovered organic materials." The result would be a fooled public and further degradation health and the environment.

The EPA's preferred method of disposal of sewage sludge in the United States is land application. To get the public to accept this has required a concerted effort from government and the sludge-industry to make the public think that sludge is "organic," "nutrient-rich," and otherwise "beneficial." Calling sludge "compost" is the agency's latest trick. The proposal here to "compost" sludge is based on the dependable presence of human feces in sludge. Human feces do indeed consist largely of organic matter. But sludge consists only partly of human feces.

It is the purpose of wastewater treatment to extract from sewage—and to concentrate in sludge—all the pollutants in wastewater. The intended product of wastewater treatment is clean water. Sludge is the inevitable byproduct that, by definition and intention, consists of every waste material a given wastewater treatment plant is capable of removing, or is incidentally removed, from the sewage in the process of treating the wastewater. This means that, besides human urine and feces, tens of thousands of chemicals—organic and inorganic, teratogenic and carcinogenic, toxic and estrogen mimicking—will be present in the sludge.

The idea, therefore, of "treating" sludge so that it can become "compost," a "soil amendment," a "fertilizer"—is disingenuous. Once mixed together, the potential value of each and all of the materials concentrated in the sludge is lost. No "treatment" of sludge can "purify" the human excrement: once mixed with poisons, it too becomes a poison.

The problems deriving from sewage are indeed massive. Sewers give sewage. Treatment gives sludge. What to do? How to get rid of the sludge? The solution proposed here is only linguistic laundering: call sludge "biosolids", call "biosolids" compost, and, through the "Comprehensive Procurement Guideline V for Procurement of Products Containing Recovered Materials," legally oblige federal, state, and local entities, and contractors working for same to preferentially purchase sludge aka "biosolids" aka "compost" when purchasing "recovered materials." To put in bags of neat looking pellets to sell as "compost" to unwary gardeners. That will get rid of a lot of it, and it will take a long time for people to come to understand what happened to them.

At the end of Romeo & Juliet, the Prince says, "A glooming peace this morning with it brings; the sun, for sorrow, will not show his head: go hence, to have more talk of these sad things; some shall be pardon'd, and some punished: for never was a story of more woe than this of Juliet and her Romeo." The Prince, like Juliet, had never heard of sewage sludge. It too is a sad story and one with no pardon for EPA's deceits.

Laura Orlando

The EPA has an open docket on this proposed rule (public comments will be accepted until March 19, 2004), Comprehensive Procurement Guideline V for Procurement of Products Containing Recovered Materials, docket number RCRA-2003-0005 (the actual proposed rule is document number RCRA-2003-0005-0001).

You can tell EPA what you think of this proposed rule by sending them a letter or electronically filing your response (click "documents" to see what others have written).

Letters should be sent to: You may mail comments to: OSWER Docket Center, Environmental Protection Agency, Mailcode: 5305T, 1200 Pennsylvania Ave NW, Washington, DC 20460. Head your comments: Attention Docket ID No. RCRA 2003-0005.

RILES' comments sent to EPA on the rule change, co-signed by 36 other organizations, is listed as document number: RCRA-2003-0005-0348

Northeast Organic Farmers Association-New York (NOFA-NY) article, EPA Proposes to Re-define Sludge Composts as Organic, by Sue Smith-Heavenrich

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