"We urge you to prohibit any further spreading of pulp mill sludge until testing has conclusively proven that it is safe for people in communities, workers and the environment."
Safe Water - A website about the on-going problems with Atlantic Packaging recycled paper sludge and the Ontario government's on again off again approval of its use as "Sound Sorb."
Letter To Minister Sawicki
February 16, 2000 Hon. Joan Sawicki Minister of the Environment Legislative Buildings Victoria, BC V8V 1X4
Dear Minister Sawicki:
Draft Three of the Pulp Mill Sludge Regulation and the Guideline for the Land Application of Pulp and Paper Mill Sludge will open the floodgates of land spreading of pulp mill sludge.
We urge you to prohibit any further spreading of pulp mill sludge until testing has conclusively proven that it is safe for people in communities, workers and the environment.
Why?
Pulp mill waste water contains a mix of hundreds of chemicals that harm the environment. In British Columbia we know this only too well, and it took years to get laws that made the mills install secondary treatment to clean up the effluent. Secondary treatment removes those bad chemicals from the water and puts them into the sludge. Now the Ministry wants to approve spreading toxic sludge on the farms, forests and parks of British Columbia.
No one knows all of the contaminants in pulp mill sludge. We do know that it contains a variety of heavy metals, benzenes and phenolics. We also know that other jurisdictions in North America that have experimented with spreading sludge have experienced unexpected problems, and frequently halt the sludge spreading programmes in a wave of citizen protest.
In 1998, when your Ministry finally agreed to commit $20,000 to independent testing of the sludge to find out what is in it and whether it could harm people or the environment, the Council of Forest Industries withdrew from the advisory table. Behind closed doors, your staff continued to draw up regulations to allow the sludge to be spread across the province. The only testing ordered in the Regulation is for chemicals listed in the Contaminated Sites Act. This is inadequate. The few tests available show a wide range of poorly understood chemicals, including a large amount of material that cannot be identified.
If the regulation is passed, BC citizens will have no recourse, no avenue to appeal when truck after truck of sludge is dumped in their communities. Workers will be forced into contact with the sludge that often contains harmful bacteria.
Minister, we urge you to be guided by the Precautionary Principle in this matter and order thorough testing and consideration by independent scientists before you open the flood gates to over 50,000 truckloads per year of this unknown material spread all over British Columbia.
British Columbia has suffered enough toxic pollution from kraft pulp mills. Let's stop this contamination before it start
Alberni Environmental Coalition, Port Alberni Biosphere Monitor, Quadra Island Canadian EarthCare Foundation, Kelowna Cariboo-Chilcotin Conservation Society, Williams Lake Comox Valley Naturalists Society, Courtenay Council of Canadians, Victoria Chapter Cortes Ecoforestry Society, Cortes Island East Kootenay Environmental Society, Kimberley Elliott-Anderson-Christian-Trozzo Watershed Committee, Winlaw FarmFolk/CityFolk Society, Vancouver Forest Protection Allies, Quesnel Fraser Headwaters Alliance, Dunster Friends of Clayoquot Sound, Tofino Friends of Cortes Island, Cortes Friends of the Slocan Valley, Victoria Georgia Strait Alliance, Nanaimo Granby Wilderness Society, Grand Forks Greenpeace, Vancouver Kaslo & District Environment Society, Kaslo Nelson EcoCentre, Nelson Ocean Voice International, Bamfield Okanagan Similkameen Parks Society, Summerland Qualicum Beach Environment Committee, Qualicum Beach Pulp, Paper and Woodworkers of Canada, Vancouver Reach for Unbleached! Vancouver Rivershed Society of British Columbia, Coquitlam Rogers' Environmental and Educational Foundation, Nanaimo Sierra Club of British Columbia, Victoria Sierra Club of BC - Quadra Island Group T. Buck Suzuki Environmental Foundation, Vancouver Thompson Watershed Coalition, Kamloops Silva Forest Foundation, Winlaw Valhalla Wilderness Society, New Denver West Arm Watershed Alliance, Nelson West Coast Environmental Law Association, Vancouver Western Canada Wilderness Committee
The BC Ministry of Environment Lands and Parks has issued Draft Three of a Sludge Regulation, which calls for some minimal testing of sludge before it is spread on farms, forests and parks. A further Ministry guideline on sludge handling and spreading warns that the sludge can contaminate ground water.
The pulp mills call it "bio solids." The government calls it pulp mill sludge. We call it Industrial Waste.
There has been no independent testing of this material to determine what's really in it. We do not know if this industrial waste causes genetic mutations or harms the hormone system of wildlife or people exposed to it. We do not know what gasses off the sludge to harm the workers who have to handle it.
What Is It?
Pulp mill sludge is a complex and changeable mixture of dozens or even hundreds of compounds, just like mill waste water. Some are well known, like heavy metals, dioxin and other organochlorines. Some, created by the bacteria in the treatment ponds, are probably unknown to science.
Environment Canada scientists in the Maritimes believe nonylphenol compounds are responsible for the decline in Atlantic salmon returns. We know that the pulp and paper industry uses one third of the nonylphenols in Canada, and we suspect these hormone disruptors wind up in sludge.
History of the Issue in BC
In 1994 a Kamloops farmer decided to experiment by feeding pulp mill sludge to cattle, until the Pulp, Paper and Woodworkers of Canada (PPWC) alerted the public. In 1996 a quiet rural neighbourhood near Krestova was upset when Celgar mill spread 80 tonnes of kraft sludge within 170 feet of a local well. The land was subsequently sold. In 1998 a neighbourhood near Quesnel BC was shocked to find Quesnel River sludge dumped on frozen land that sloped toward creeks and a local lake. The mill subsequently removed the sludge.
In 1996, the Ministry of Environment set up a Pulp Mill Sludge Advisory Committee that was to examine all aspects of pulp mill solid waste. Environmental groups like Reach for Unbleached! participated fully, repeatedly demanding that the waste material undergo testing before it was broadcast over the environment.
By 1998, when the Ministry of Environment agreed to do some independent testing, to see what really was in the sludge, the Council of Forest Industries (COFI) promptly withdrew from the committee, and the budget for testing was lost.
The Ministry produced the Draft Three Sludge Regulations and Guidelines in October 1999.
There has been some limited spreading of pulp and paper sludge in British Columbia under special approvals. Paper mill sludge is mixed with GVRD municipal sludge and spread on Scott Paper poplar plantations on islands in the Fraser River. Quesnel River Pulp spreads some of its sludge on farmland in the Quesnel area. Celgar kraft sludge has been spread on some orchards and agricultural land.
This regulation throws the doors wide open for over 50,000 truckloads of sludge per year to be spread in BC communities, with virtually no government oversight and no independent monitoring.
Widespread Concern
The Pulp, Paper and Woodworkers of Canada has called for sludge to be treated as regulated "toxic waste" until "the pulp and paper industry can supply verifiable and irrefutable proof (through valid scientific testing) that there are no ill side effects to the workers who handle these products"
The US Environmental Protection Agency (EPA) is considering listing paper mill sludge as hazardous waste.
Ontarians have been complaining about the spreading of pulp and paper sludge for years. In 1999 the Ontario Environmental Commissioner wrote: "The applicants cite concerns about the contamination of soil, ground water and surface water, as well as impacts on livestock, wildlife and soil microorganisms. Many have also complained about odour, and symptoms such as headaches, burning eyes and breathing difficulties associated with freshly spread sludges."
The State of New Hampshire abruptly cancelled a mill sludge spreading program in 1998 after the discovery of unexpected toxic chemicals leaching into ground water. Additionally the state is now facing a lawsuit over the spreading of mill sludge that should have been classified as hazardous waste.
In Ontario a multi million dollar lawsuit has just been settled over the death of 43 acres of grapes where paper sludge had been piled in between the rows at Hernder Winery in St. Catherines.
What We Want
Rigorous and independent testing of pulp mill sludge
Prohibit the land spreading of pulp mill sludge until these waste materials are known to be safe in the environment
Eliminate known toxic contaminants, such as nonylphenols and chlorine compounds, from pulp mill processes
* Peter Ronald, Campaign Coordinator, Georgia Strait Alliance; www.georgiastrait.org; (250)361-3621; fax: (250)361-3682; Box 5591, Victoria BC V8R 6S4 Canada
* Delores Broten, former Executive Director, Reach for Unbleached, Box 39, Whaletown, British Columbia Canada V0P 1Z0
Scientific Literature on Health Impacts of Bioaerosols Maureen Reilly - February 2000
Maureen Reilly is an environmental researcher with Uxbridge Conservation Association, Ontario. She would like to hear from organizations or individuals who have experience or information about this issue.
There appears to be growing literature on the health impacts of bioaerosols in both indoor and outdoor environments. From the experience of affected individuals from Beaverton, Cornwall, and Sault Ste Marie, there appears to be growing evidence that some individuals are becoming impacted by bioaerosols from paper mill sludge.
This is a health concern since properties adjacent to large land application projects are often subjected to unincorporated sludge operations as often as twice a year. Unincorporated refers to the practice of top dressing, or leaving the sludge on the surface of the soil without mixing it into the soil.
Often sludge piles are left to decompose for months or even years, and when these piles are opened there is often powerful impacts such as burning of nostrils, and breathing difficulty.
Thus there are a wide variety of conditions under which sludge decomposes and can have a variety of on site and off site effects.
The sludges appear to support a wide variety of microbial growths, and further work should be done to characterize the types of growths that are present in the sludge in various stages of decomposition. Bioaerosols are also a concern in the composting of sewage sludges.
Reported effects including tightening of the chest and allergic reactions. There is some concern about mutagenicity, and acute toxicity as well. Much of the literature on bioaerosols reviews the heath impact on healthy male employees at composting sites. It does not capture the impact of these bioaerosols on subject populations living adjacent to sludge operations. These individuals may be elderly, immunocompromised from transplants, cardiac surgery, diabetes, or may be children or infants in poor health. These individuals are subject to the bioaerosols on a 24 hour a day, seven day a week basis. Unlike an affected worker, they have no recourse to remedies available to workers such as changing jobs or duties, nor are they eligible for Workmans Compensation for injuries they have suffered.
For these reasons, the Ministry of the Environment and the Ministry of Health should require land applied sludges to be thoroughly investigated for bioaerosols, including, mould and fungal growth, mycotoxins and endotoxins, under a wide variety of environmental conditions. There are health standards for the presence of such growths in the environmental health and safety field, and this literature can be used as a starting point for investigating the levels of such agents present in rural land application initiatives, especially in those areas where health impacts are suspected. "
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