Letter to the Editor: Clarke County Biosolids Use

April 10, 2012

To the Editor:

Caroline Snyder’s letter to the editor of March 26 was a gross misrepresentation of the facts about the land application of biosolids. While Snyder often presents herself as a scientist by listing her previous association with the Rochester Institute of Technology, it must be noted that she taught in the College of Liberal Arts and not in the colleges of Science, Technology, Engineering or Health Sciences. Her undergraduate and graduate degrees are in Germanic Languages and Literature. She has done no peer-reviewed research in any scientific field—certainly not in biosolids.

The residents of Clarke County can rest assured, however, that thousands of real scientists have been studying the land application of biosolids for many decades and have concluded that it is safe and beneficial to farms and forests. This research and years of practical experience have yet to document any link between biosolids and adverse effects on human health, the environment or to wildlife and domestic animals. New research is continually adding to our knowledge about biosolids and leading to improvements in technology and processes.

Before going further, perhaps a definition of biosolids, based on information provided by the Virginia Department of Health, would be helpful:

Biosolids are the nutrient-rich organic materials resulting from the additional treatment of sewage sludge in a municipal wastewater treatment plant. During treatment, beneficial bacteria and other tiny organisms break the sludge down into simpler, harmless organic matter. The organic matter, combined with bacterial cell masses, settle out to form biosolids, which can then be safely recycled as a fertilizer and soil conditioner.

In 2007, the Virginia Department of Health published a study by three respected epidemiologists that represented an exhaustive review of the current scientific literature about biosolids and human health.  The primary conclusions were as follows: “… there does not seem to be strong evidence of serious health risks when biosolids are managed and monitored appropriately. Human health allegations associated with biosolids usually lack evidence of biological absorption, medically determined human health effects, and/or do not meet the biological plausibility test.”

In 2008 an Expert Panel created by the Virginia General Assembly concluded after 18 months of study that it had “uncovered no evidence or literature verifying a causal link between biosolids and illness.”

Snyder completely misrepresented the findings of the National Academy of Science panel on biosolids, which in 2002 issued its recommendations on ways to improve the scientific research supporting the land application of biosolids.  Snyder made the false claim that the NAS had said that the EPA’s Part 503 rules, which are the basis for Virginia’s regulation of biosolids, were “flawed,” “outdated science,” and “no science at all.”

Virginia’s biosolids regulations are administered by the Virginia Department of Environmental Quality (DEQ), which Snyder mistakenly called the DEP.

In the preface to its report, the National Academy of Science panel made it clear that its purpose was not to determine the adequacy of the Part 503 rule. Rather, its purpose was to focus “on identifying how current risk-assessment practices and knowledge regarding chemicals and pathogens in biosolids can be used to update and strengthen the scientific basis and credibility of EPA’s biosolids regulations.”

Dr. Thomas Burke, Chair of the NAS panel, issued a statement amplifying the panel’s findings. “First,” he said, “we found no evidence of an urgent public health risk from exposure to land-applied biosolids, based on our review of the scientific literature. Currently, there are no studies documenting adverse health effects from land application of biosolids, even though land application has been practiced for years.”

Finally, it seems highly presumptuous for Snyder, from a distance of more than 650 miles in New Hampshire, to criticize Virginia’s regulation of biosolids.  Virginia has recently completed an exhaustive four-year review and revision of the Commonwealth’s biosolids regulations.  These regulations, as administered by the DEQ, are among the most comprehensive in the nation and are based on the latest scientific research and practical experience. Virginia’s regulations are more stringent than the federal Part 503 rule on land application rates, slope restrictions, buffers, soil pH and nutrient management plan requirements.  These regulations have demonstrated that they are fully protective of public health and the environment.

The DEQ’s Biosolids Program includes 25 full-time personnel who monitor the land application of biosolids in Virginia. According to DEQ records, 93 percent of farms that received biosolids in 2010 were inspected by DEQ personnel.

In my 40 years in the water and wastewater treatment profession I have found that most people, when they have an opportunity to consider the facts, conclude that the beneficial use of biosolids is a win/win for everyone—for the farmers who apply biosolids to their land, for their neighbors who want to preserve the rural nature of their communities, for the environment, for public safety, and for the citizens of the municipalities that use this method of responsibly recycling a valuable resource.

I hope the facts presented here have been helpful to the citizens of Clarke County in understanding the safety of biosolids land application and its many benefits.

Barry Dunkley, P.E.

President, Virginia Biosolids Council

Barry Dunkley is Director of Water & Wastewater Treatment for the City of Danville, Virginia.  He is currently the president of The Virginia Biosolids Council, which includes municipal wastewater treatment facilities that produce biosolids, companies that produce compost, companies that apply biosolids to farms and forests and the landowners who benefit from this nutrient-rich soil conditioner. The organization’s website is www.virginiabiosolids.com.


  1. Wonder if Mr Dunkley lives next to a field being srayed with this stuff? Wonder why they tell farmers not to let livestock graze on these fields for a month after application?


  2. RX for our acres says:

    Great point, coming from the person selling the produce…

  3. Clarke County Annie says:

    There seems to be as many “sources” that promote use as there are in opposition.

    Many products were deemed bad were found later to be ok after all. One simple one… Eggs, bad for you- now are back to being… a good source of protein.

    Sigh. What is a person to believe?

    But, to hear first hand from some Clarke residents experiencing health issues after applications near them holds the best basis of not using this product.

  4. Bill Lukens says:

    The scientific method is a wonderful tool for proving or disproving specific theories or a hypothesis. Two major problems of the scientific method is that it only measures what one is looking for, and of controlling variables.

    I am always amazed at the people who completely discount scientific results. I am also amazed at people who believe that science has all the answers. Reality is in that large gray area between the two.

  5. This is nothing but a shut up letter! One of our officials had to of contacted this guy to stop all the phone calls and letters they’re recieving.

    Have we heard from any of our Supervisors on this subject? NO! They don’t have enough answers for all the questions so they stay silent. Silence doesn’t get rid of the smell or the residents that are being affected by this CRAP!

    In my opinion our Supervisors have been failing us!

  6. We as citizens can meet on this issue, create a petition or write individual letters and make calls to our state representatives in Richmond. This may be our only option to make a change, since this is now mandated to be used by the state governments, who must come up with a solution to our waste management issues.

    This particular one seems to be a profit making marketing spin on some of our most dangerous toxic wastes. This is certainly not the first time “the people” have been duped by such efforts, in the hope that no one will notice. Flame retardant chemicals have been mandated to be used on all fabrics that are used in public spaces, like in furniture upholstery, carpets and drapery fabrics (and kids pajamas).

    Guess what is in 100% of all biopsied breast tissue for breast cancer patients? Yes, flame retardant chemicals. Still mandated to be used by our government.

    Please contact me if you want to band together on this issue.