"David Stanley" <firstname.lastname@example.org> wrote:
>You wrote:"...Problem: Growers may use certain forms of sewage sludge even
>though it contains heavy metals and other toxins.
>Solution: Tell USDA that 205.2 should be changed to prohibit any form of
>sewage sludge, and that sewage sludge should be defined as synthetic..."
>Wouldn't it be more honest to call sewage sludge "human generated" or
>"potentially containing synthetic material", rather than stretching the
>definition of the term synthetic in such a legalistic manner? Why not leave
>the door open for some kind of certified sludge, say from small communities
>where every citizen is willing to sign contracts regarding proper use of
>their sewage system, and where other sources of, truly synthetic,
>contaminants (in runoff etc.) are kept separate and are regularly tested? (I
>know this would be difficult, if not impossible to pull off, but at least a
>remedy would be offered).
The reason for the importance of calling it "synthetic" is that this
triggers provisions requiring NOSB & public involvement in any changes,
otherwise it would be much easier to weaken the rules without anything
remotely resembling the reasonable terms you suggest.
It is my understanding that in the organic standard, "sewage sludge" means
the output of municipal treatment plants, over which as you point out it
is almost impossible to effectively control toxics under existing systems.
You have some good points. Implementing them on a significant scale would
probably require major reorganizations to existing infrastructures that are
not likely to happen soon, such as breaking up city sewage systems so they
are small enough that you can trace sources of contamination.
It would be great if there was more use of composting toilets. If they
accumulated a year's waste and only entered the recycling system once a
year, then it might even be possible to do a quick test on each source.
When it's entering the sewer system minute by minute, it's almost
impossible to control.
Sewage sludge is already being recycled for use in landscaping.
Another problem is transmission of parasites and other pathogens, even if
it's free of chemical contamination.
Rules for this kind of thing would take a lot of care to craft well.
If sewage sludge is excluded initially and is defined as "synthetic", then
the door _is_ open to formulate such rules with NOSB & public oversight.
Under the USDA proposal, there are serious loopholes and the public does
not necessarily have any control over changes, including changes to add
--- Walter Epp email@example.com
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