Discussion Document:
Evaluation of Possible Actions to Eliminate Sewage Sludge from Organic Agriculture
Paige Tomaselli & Lisa J. Bunin
1 June 2010
Introduction:
Despite its paramount role in promoting and regulating America’s organic agriculture industry,
USDA’s actions have, unfortunately, failed to provide strict regulatory oversight of fertilizer and
compost labeled “organic.” These organic agriculture amendments commonly contain sewage
sludge, a prohibited substance under the National Organic Program (NOP) known to harbor
harmful heavy metals, toxins and pathogens. Underlying this problem is a complication that allows
states to regulate fertilizer contents. As such, they define “organic” by its chemical definition, rather
than by using the definition contained in the Organic Foods Production Act (OFPA) and the
supporting organic rules. Obviously, broad state definitions of “organic fertilizer” that allow sewage
sludge as a fertilizing ingredient are in direct conflict with federal organic standards. This not only
misleads farmers, gardeners and the public but it also undermines organic integrity by allowing
prohibited methods and materials to be spread on organic farms and gardens, often without the
knowledge or consent of its users. This conflict results in inconsistencies in the quality of the
organic food produced and the organic inputs used from state to state.
Possible Actions:
The Center for Food Safety is currently considering several actions that would encourage USDA to
address this inconsistency between state and federal regulations. These actions include:
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Submit a legal petition (already drafted by CFS and circulated to NOC) to USDA asking it to
revise the NOP regulations to prohibit use of the word “organic” in compost that contains
sewage sludge. This petition would also give USDA the option of providing regulatory
guidance on this issue.
Forgo the petition and utilize another method to get NOP to issue regulatory guidance. Any
suggestions?
Issue a consumer advisory.
Address as part of the “Farm Bill “to do” list.
Definitions:
Sewage Sludge: Solid waste separated from wastewater through a digestion and settling process in
wastewater treatment.
Main Office: 660 Pennsylvania Ave., S.E., Suite 302, Washington, D.C. 20003  Phone: 202-547-9359  Fax: 202-547-9429
California Office: 2601 Mission Street, Suite 803, San Francisco, CA 94110  Phone: 415-826-2770  Fax: 415-826-0507
Email: [email protected]  www.centerforfoodsafety.org  www.foodsafetynow.org
Biosolids: A public relations term created as an alternative to the term sewage sludge. Often times,
“biosolids” is used to describe “processed” sewage sludge. Processing includes heating, drying, composting,
anaerobic digestion, or liming in an effort to make the sludge less toxic.
Fertilizer: A substance that adds nutrients to the soil.
Composting: The practice of facilitating the breakdown of natural materials - like leaves, food scraps, and
manure - in order to make their nutrients available for agricultural crops.
organic vs. Organic: the word “organic” refers to carbon-based matter. This differs from the legal
standard of “Organic” as per the USDA National Organic Program (NOP). The NOP prohibits the use of
sewage sludge as fertilizer or in fertilizing products used on fields which grow Organic crops due to toxic
contaminants found in sewage sludge.
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