7/24/20
W4170 Provides Scientific Rebuttal to EPA Office of Inspector General 2018 Critique of Biosolids
The U.S. Department of Agriculture’s Multistate Research Committee, known as W4170, has completed a scientific rebuttal to the U.S. Environmental Protection Agency (EPA)’s Office of Inspector General (OIG) report issued in November 2018 titled “EPA unable to assess the impact of unregulated pollutants in land-applied biosolids on human health and the environment.” The W4170 is the latest iteration of USDA research committees that have been studying the beneficial
use of residuals to improve soil health and protect public and ecosystem health. This research work has been going on for 45 years and helped establish the basis of current EPA biosolids management regulations found in 40 CFR Part 503– the EPA biosolids regulations.
Nicholas Basta, PhD, Professor of Soil and Environmental Chemistry, The Ohio State University, discusses the W4170 response to the EPA OIG biosolids report at the annual scientific meeting of the W4170 at USDA headquarters in Beltsville, MD, June 2019. Dr. Basta and one of his PhD candidates helped lead the W4170 response work.
The 2018 OIG report criticized EPA for failure to assess 352 pollutants found in biosolids/residuals, including 61 considered acutely hazardous or defined as hazardous or priority pollutants under other federal environmental laws. Some of the list of pollutants came from EPA’s own Biannual Review that is required under Part 503. The OIG report also cited 291 “unlisted” pollutants that, they claimed, EPA had not assessed. The report by W4170 addresses both the listed and unlisted pollutant exposure risks from beneficial reuse of biosolids and tries to put them in perspective.
The OIG report has been used as justification to discontinue or hinder beneficial reuse programs across the country. The W4170 research committee’s response to the OIG report is a much welcomed, albeit delayed, refutation of what EPA’s Office of Water characterized in its initial response to the OIG report as lacking science and context as well as being alarmist and biased. EPA pointed out that the mere presence of the pollutants mentioned in the OIG report does not indicate risk. The W4170 response agrees, concluding: “The OIG report alleged that ‘…[EPA] lacked the data or risk assessment tools needed to make a determination on the safety of 352 pollutants found in biosolids...’ Our review of literature showed extensive data and risk assessment, some conducted by USEPA, exists for the pollutants listed by OIG. In short, the above statement in the OIG is inaccurate and alarmist.”
The W4170 report points out that – concentration-wise – there are many other much greater sources of human exposure to almost all of these pollutants than from their presence in biosolids/residuals. There were, however, several chemicals that the W4170 report suggests require further study, including several persistent pharmaceuticals. The work on the W4170 report included extensive literature research/citations. The review of the unlisted chemicals was broken down into groups of chemicals such as antibiotics/antimicrobials, metals, brominated flame retardants, dioxins, pharmaceuticals, hormones, pesticides, and pathogens. The report also contains a section summarizing “PFAS: A Challenging Current Concern”.
In the aftermath of the OIG report, the Water Environment Federation (WEF) organized a national biosolids convening meeting in November 2019 at which EPA was urged to reinvest in its biosolids program and increase regulatory oversight and compliance activities with respect to the Part 503 program. At that meeting, EPA acknowledged that there were areas where improvements were needed. Before the COVID-19 outbreak, EPA was working on convening a meeting with all the state and tribal biosolids coordinators, hiring additional staff to do the risk assessment work, and fast-tracking the risk assessment work. WEF has continued to host monthly meetings with EPA and various stakeholders such as the Water Research Foundation, the National Association of Clean Water Agencies, and NEBRA and other regional biosolids organizations to
better coordinate activities to improve biosolids management and enhance opportunities for beneficial reuse.
Download report. Download the EPA OIG Memo in response: thanks, but we’re not interested in further discussion.