Water Environment Federation

WEF Submits Comments on FDA Proposed Rule for Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption

WEF submitted comments regarding the FDA Proposed Rule for Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption (Docket No. FDA-2011-N-0921 / (RIN) 0910-AG35)

WEF noted the following:

. . . . Supporting local Water Resource Recovery Facilities (WRRFs) with education, training and technical support on biosolids management is a core mission for WEF. WEF supports beneficial recycling of biosolids through land application that is best suited to meet the needs of local communities, and we are pleased that FDA’s proposed a framework that will allow for continued use of biosolids in growing produce for human consumption. This position is consistent with decades of scientific research and years of field practice that have clearly established the value and environmental benefits of biosolids, when properly treated and managed. It is also consistent with the position of U.S. Environmental Protection Agency’s (EPA) and other federal agencies, which encourages the beneficial use of biosolids through policies and regulations, including the Clean Water Act. Land application of biosolids provides a variety of environmental benefits. In addition to adding nutrients and organics for soil improvement, the organic matter provided by biosolids can play an important role in replenishing soil organic carbon (SOC) lost through climate change-induced wind and water erosion. Additionally, biosolids can reduce agricultural carbon footprints through both fertilizer production offsets and biosolids use to meet plant nutrient requirements. The Clean Water Act-mandated Part 503 regulations provide regulatory guidelines for biosolids management practices of land application that are protective of human health and the environment. In the years since promulgation of these regulations, US EPA, Water Environment Research Foundation, and others have investigated a variety of scientific topics related to land application. The overwhelming conclusion of this monitoring and research continues to be that no documented negative human health impacts have been experienced when biosolids meet all of the requirements of Part 503 and when good management practices are followed. WEF supports continued research to add to the understanding of effective practices for biosolids management, strengthening the science on which sound practices are based, and addressing emerging issues as they arise.

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The National Biosolids Partnership – Advancing environmentally sound biosolids management practices