A Critical Review of the U.S. EPA's Risk Assessment for the Land Application of Sewage Sludge

Abstract

Sewage sludge is a complex mixture of inorganic and organic materials and pathogens generated by the treatment of domestic sewage. Section 40 of the Code of Federal Regulations Part 503 regulates the land application of sewage sludge based on pathogen content and sets standards for nine inorganic chemicals. It is believed that the Part 503 standards are protective of human health and the environment and that sewage sludge applied to land poses little risk. A critical inspection of the pertinent literature, however, reveals that the standards were based on outdated methods, outdated data, inaccurate data, and flawed assumptions, leading to underestimation of risk. The standards are not sufficiently protective, and even if changes were made, sewage sludge is so complex that it is very unlikely it could be monitored to ensure the protection of human health and the environment. For these reasons, the practice of land application of sewage sludge must be discontinued.