Another Look at Triclosan

In July, 2016, our article entitled, “Triclosan?  Just Wash Your Hands!” appeared in Keystone Water Quality Manager Magazine.  At that time, we reported that indicators and research pointed to a minimal risk to humans of the trace amounts of triclosan found in land-applied biosolids.  We also noted that, since such anti-microbial compounds provided no additional benefit to the consumer over washing with plain soap and water, these active ingredients could be removed from products such as antibacterial wash products without putting the safety of the general public at risk.

A couple months later, the FDA reached a similar conclusion when they released their findings that companies could not prove that the inclusion of such ingredients in consumer wash products provided better protection against spreading certain infections and preventing illness than diligent hand washing alone.  In September, 2016, the FDA issued a final ruling that over-the-counter (OTC), anti-bacterial wash products that contain one or more of 19 specific active ingredients, including triclosan, will no longer be able to be marketed.  This only applies to those products that are intended to be used with water and rinsed off.  It does not affect consumer hand “sanitizers” or wipes, or antibacterial products used in hospital and food service settings.  Manufacturers will have one year to comply by either reformulating or removing the products from the market.

This ruling by the FDA is a follow-up to their proposed rule in 2013 when data showed that long-term exposure to these active ingredients could pose minimal health risks, including bacterial resistance and hormonal effects.  The new ruling concludes that, since there is no benefit to including the ingredients – and, in fact, there is a slight negative health risk – there is no need to use them at all.  The Centers for Disease Control recommends that, if soap and water are not available, consumers should use an alcohol-based hand sanitizer instead.  Other ingredients that have shown anti-bacterial properties in alternative products include hydrogen peroxide, thyme oil, and citric acid.

The FDA has deferred ruling on three other ingredients used in consumer antiseptic wash products until more safety and effectiveness data is submitted.  The three ingredients are: benzalkonium chloride, benzethonium chloride and chloroxyleno (PCMX).

All of this is good news for the biosolids sector.  Eliminating potentially harmful ingredients in the manufacturing of consumer products will subsequently reduce their presence in biosolids and thus reduce the risk and public anxiety over the presence of these microconstituent contaminants in the future.

The 19 banned ingredients are:

  • Cloflucarban
  • Fluorosalan
  • Hexachlorophene
  • Hexylresorcinol
  • Iodophors, which are iodine-containing ingredients
  • Iodine complex, which is ammonium ether sulfate and polyoxyethylene sorbitan monolaurate
  • Iodine complex of phosphate ester of alkylaryloxy polyethylene glycol
  • Nonylphenoxypoly, or ethyleneoxy, ethanoliodine
  • Poloxamer, an iodine complex of Povidone-iodine 5 percent to 10 percent
  • Undecoylium chloride iodine complex
  • Methylbenzethonium chloride
  • Phenol greater than 1.5 percent
  • Phenol less than 1.5 percent
  • Secondary amyltricresols
  • Sodium oxychlorosene
  • Tribromsalan
  • Triclocarban
  • Triclosan
  • Triple dye
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Draft Supplement to Nutrient Management Technical Manual

The State Conservation Commission (SCC) is in the process of writing draft guidance for the next edition of the Nutrient Management Technical Manual dealing with Act 38 participants who utilize Food Processing Residuals (FPRs) and/or Biosolids (Exceptional Quality or Class B) as a nutrient source or soil amendment for agronomic purposes.   On October 24, 2016 the SCC distributed a draft supplement for comment to Nutrient Management Planners.

If you would like Garvey Resources to draft comments on behalf of your organization, please call or email.

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Biosolids Presentation Updates

Diane will be presenting at three upcoming events in September.  Two of the presentations at EPWPCOA will deal with permitting for land application of biosolids and the WEFTEC presentation will cover a paper addressing biosolids hydrolysis and high solids liquid fertilizer .

EPWPCOA Meeting and Trade Show in Leesport, PA

Friday, September 16, 2016

The title of the presentation is: “The Phosphorus Index and the Impact on Land Application of Exceptional Quality and Class B Biosolids.”

The conditions of the General Permits for Land Application will be revised and reissued in April 2017 to include an evaluation of each field for the Phosphorus Index.   This presentation will evaluate the impacts of this change and provide recommendations to prepare for these new regulatory requirements.

WEFTEC 2016 – Technical Exhibition and Conference in New Orleans

Technical Session #410, “Sludge Hydrolysis,” Tuesday, September 27, 2016 at 2 PM

This will be a presentation of a paper written by Diane Garvey et. al. entitled, “Hydrolysis Process and High Solids Liquid Fertilizer Reduce Land Application Costs & Complies with Nutrient Management Regulations”

The Issue: With the growing interest in Resource Recovery, many biosolids producers are keen to continue to recover the nutrients and organics in their biosolids through land application to agricultural lands. The traditional land application of dewatered biosolids, however, often raises concerns from regulators and the public about odors, dust and nutrient run-off. In addition, newly implemented or soon to be implemented Nutrient Management Regulations in each state will limit how much and where biosolids may be used in agriculture.
The Solution: Over the last 8 years a number of biosolids producers in Canada have made use of a biosolids hydrolysis process to overcome stakeholder concerns. This process produces a high solids EQ biosolids liquid that can be land applied in a way that offers a number of benefits to the ratepayer, the public, environmental regulators, and the farmer.


EPWPCOA Event “Beneficial Use of Biosolids in Mine Reclamation” in St. Clair, PA

Session entitled “General Permitting for Beneficial Use” on Friday, September 30, 2016 at 10:45 AM

This presentation will cover the process of General Permitting for the Beneficial Use of Biosolids, including the requirements for biosolids quality, preparation of sampling plans for biosolids permitting, and the preparation of Biosolids Quality Enhancement Plans for use in the Land Application and Beneficial Use of Biosolids.

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Triclosan in Biosolids – No Cause for Concern

In recent years, there has been much concern and scrutiny regarding the microconstituents found in biosolids and whether or not they present a human health risk.  Several research projects have focused on one type of microconstituent – antimicrobial compounds.  In particular, many studies have looked at the antimicrobial Triclosan (TCS), a common ingredient in many household and personal care products. TCS is routinely detected in treated biosolids and wastewater effluents.  But what exactly does this mean to human health?  Is it harmful in the amounts found?  Does it get into the food grown on biosolids-amended farm fields?  If so, is that a problem?  Researchers have looked at these issues and concluded that there is a negligible risk to human health in any of these circumstances.

Let’s clear one thing up first: antimicrobials are not the same as antibiotics.  While “all antibiotics are antimicrobials…not all antimicrobials are antibiotics.”[i]  Antibiotics are molecular substances produced by a microorganism.  Antimicrobials, on the other hand, may be natural or synthetic.  They also tend to have a narrow window of effectiveness for specific microorganisms and are thus less likely to cause bacterial resistance with repeated use.

Now, back to the antimicrobial, Triclosan, whose primary use is in antibacterial soaps and washes.  Research focused on TCS has been reported on by the Food and Drug Administration (FDA) and Water Environment Research Foundation (WERF) as well as in several industry journals.[ii]  All reports conclude that there is a minimal risk to humans from TCS in land-applied biosolids or in its presence in crops grown in fields amended with biosolids.  The FDA had first reviewed TCS in 2010 and again in 2013, concentrating only on antibacterial soaps and body washes that are used with water, not hand sanitizers, wipes, or antibacterial soaps used in health care settings.  In both studies, they concluded that the presence of TCS in biosolids was not hazardous to humans, but did warrant further study because it was so prevalent in household products.

A fascinating result of the FDA’s research was the finding that the benefits of using antibacterial soap products are unproven and that “…no evidence that OTC (over the counter) antibacterial soap products are any more effective at preventing illness than washing with plain soap and water.”[iii]  This raises the question of the need for antibacterial soaps and washes for the general public and whether TCS and other antimicrobials are necessary in consumer products at all.  Might it not be more efficacious to launch a public education campaign to discourage the use of antibacterial products while promoting more thorough hand-washing?  A novel thought, indeed!  In this way, less TCS and other microconstituents would find their way into biosolids while the health and well-being of the human race would not be compromised by avoiding antibacterial products.  Sounds like a win-win!

That being said, because of this particular antimicrobial’s ubiquitous nature in products worldwide and its inefficient removal during wastewater treatment, some researchers have recommended that TCS be placed on the priority list of emerging microconstituent contaminants and its use in products regulated.[iv]

In other words…keep an eye on it.

________________________________________________________________________________________________  [i] “Antimicrobials: An Introduction” Antimicrobial Resistance Learning Site for Veterinary Students. Michigan State University, East Lansing, MI. 2011.
[ii] Versylcke, T; Mayfield, D. B; Tabony, J. A; Capdevielle, M; Slezak, B. “Human health risk assessment of triclosan in land-applied biosolids.” Environmental Toxicology and Chemistry. 14 January 2016.
[iii] Versylcke, T; Mayfield, D. B; Tabony, J. A; Capdevielle, M; Slezak, B. “Human health risk assessment of triclosan in land-applied biosolids.” Environmental Toxicology and Chemistry. 14 January 2016.
[iv] Versylcke, T; Mayfield, D. B; Tabony, J. A; Capdevielle, M; Slezak, B. “Human health risk assessment of triclosan in land-applied biosolids.” Environmental Toxicology and Chemistry. 14 January 2016.


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Regulatory Update and WEFTEC 2016

The Department of Environmental Protection, through an announcement in the Pennsylvania Bulletin dated March 26, 2016 (46 Pa.B. 1611 and 1612), stated that the General Permits for the Beneficial Use of Biosolids by Land Application (PAG-08), the Beneficial Use of Exceptional Quality Biosolids by Land Application (PAG-07), and the Beneficial Use of Residential Septage by Land Application (PAG-09) have been extended until April 2, 2017 to allow DEP more time to review and update the Permits. The DEP is most likely going to propose changes that will include language to bring the General Permits into compliance with PA Nutrient Management Regulations.

IN OTHER NEWS:  We will be presenting a paper in September, 2016 at the WEFTEC conference in New Orleans.  The title is, “Biosolids Hydrolysis Process and High Solids Liquid Fertilizer Reduces Land Application Costs and Complies with Nutrient Management Regulations.”  The solution?  Over the last eight years, a number of biosolids producers in Canada have made use of a biosolids hydrolysis process to overcome stakeholder concerns. This process produces a high solids EQ biosolids liquid that can be land applied in a way that offers a number of benefits to the ratepayer, the public, environmental regulators, and the farmer.  We will be presenting data showing how the benefits of the biosolids hydrolysis process and how its use can help farmers comply with Nutrient Management Regulations while reducing land application costs.

Three take-away points from this presentation include: #1 – All states will be impacted by the Natural Resource Conservation Service Nutrient Management requirements and biosolids recycling programs must make adjustments to remain viable.  #2 – Thermal hydrolysis may take place before or after digestion. In addition to producing Class A biosolids fertilizer product, it greatly reduces the odors at the processing and land application sites.  #3 – There are advantages to the handling, transportation, storage and land application of high solids liquid biosolids product.



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Investigative Reporter “Discovers” Biosolids!

The Mid Atlantic Biosolids Association (MABA) recently reported on a three-part, “so-that’s-how-it’s-done!”  video presentation outlining the cycle of human waste management in New York City.  The video, produced by VICE Media LLC, is entitled, “You Don’t Know S…,” and tracks the human sewage waste output of the residents of Manhattan’s West Side from flush to flow.  Despite the scatological title (and annoying overuse of the word throughout the presentation), these videos do provide the general public with an idea of what happens to human waste after the flush.

The “investigative reporter” who appears on the videos is a bit over-the-top and seems determined to dramatize the process and act like this is amazing news and was a big, dark secret until now!  But wastewater treatment plants (now known as “water resource recovery facilities”) have been processing human waste for decades.  They were engineered for this purpose.  For thousands of years, human waste was left to decompose on its own or was used as is for fertilizer.  However, as cities grew, so did the need to process large quantities of waste material.  Wastewater treatment plants were developed to mimic and speed up the process of bacterial breakdown of the organic material in waste.  But today’s plants go further than simple decomposition.  Since 1992, when ocean dumping was banned, the wastewater treatment sector has grown and continues to develop new methods for dealing with our waste, turning raw sewage into reusable biosolids and clean water.  Treated biosolids are often disposed in landfills, but that is not a sustainable practice.  So other methods of treatment are used to turn biosolids residuals into various types of products that can be used as fertilizer and, in some cases, fuel.

The video shows the steps that must be taken to process waste, including transporting waste via municipal infrastructure to treatment plants, separating liquids from solids, and the subsequent treatment of each of these products.  In cities, this can be a major engineering and logistical feat.  The VICE video follows the sewage sludge as it is pumped to, and then processed in, a new state-of-the-art, $4B treatment plant at Newtown Creek in Brooklyn.  The sludge is then transported by boat to a dewatering plant on Ward’s Island.  Here, the sludge undergoes further processing into wastewater and biosolids that are then available for beneficial use as a fertilizer.  The videos concentrated on the use of biosolids as fertilizer and didn’t explore the other creative uses for biosolids.

It seems that the shock value of a four-letter-word for human waste was used to attract an audience other than those in the wastewater sector in order to then explain the treatment process.  It’s unfortunate that this language is used since this video could be a valuable educational tool for schools to begin the dialogue about issues surrounding our waste production and how we are handling it.  Biosolids use is the ultimate in recycling and discussions of waste treatment and disposal could easily be incorporated into an environmental curriculum.  It’s important to make students realize the critical nature of sewage treatment.  Human waste is a resource that is never-ending.  We will need engineers in the future to develop new ways of treatment and disposal.  The aging infrastructure in our cities is going to need constant upgrading and, with the average age of workers in the wastewater treatment sector at 55, new jobs will be coming available.  It would be a benefit to show students that careers in the waste management field are not only essential to the welfare and health of all communities, they will pretty much guarantee job security.

Judging from the comments, the reaction to these videos was favorable overall, but often with reservations.  Waste treatment tends to be a hidden process, not one that is obvious to most people or even talked about.  We flush and forget about it.  Some commenters expressed a need for the general public to be aware of the consequences of our actions and take responsibility for recycling our waste products, whatever they may be.  The fact that someone actually told this story and showed the steps of the processing of human waste was praised by many teachers as an important educational step.  While some comments wholeheartedly endorsed the treatment process and beneficial use of biosolids as illustrated in the videos, others were conditionally supportive, expressing concerns about the presence of hormones and pharmaceutical products in a material that is being used as a fertilizer.  The public awareness of these types of emerging contaminants (EC’s) may need to be addressed by the biosolids sector.  Viewers asked questions about the presence of heavy metals, hormones, contraceptives, bacteria, and viruses, among other things.  With a rise in public awareness comes a sector need to explore and explain what is being done to evaluate the impacts of and, if necessary, eliminate these EC’s.  What was once out of sight is becoming more transparent so those in the sector must be prepared to answer questions that arise as a result of this growing awareness.

Other areas of concern expressed in viewers’ comments were: that Europe is more stringent in its regulations than the US; where biosolids that can’t be reused end up; whether or not biosolids can be used as fuel; what happens to waste in countries (or states) who can’t afford wastewater treatment plants; whether we can capture methane during the treatment process; and where the waste from airplanes and ships goes.

In the end, how biosolids are ultimately used will depend on the treatment process.  There are very strict regulations regarding what is allowed to be present in biosolids before land application.

If nothing else, the video will help raise awareness about the crucial yet complicated nature of waste management.

Here are the links to view the three parts of the video:

Part 1: is the basics of the liquid treatment at NYC DEP’s Newtown Creek

Part 2: is the haul of liquid digestate by barge to Ward’s Island for dewatering

Part 3: is the composting of biosolids at WeCare’s composting facility in Burlington County.


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Top Soil Blending with EQ Biosolids

Recent enforcement action by PADEP against a biosolids processor and topsoil blender using Exceptional Quality (EQ) biosolids warrants review of State and Federal regulations, as well as interpretation of the regulations and permit conditions. One little known regulatory interpretation in particular affects processors who are involved with top soil blending.

An EPA publication, “Control of Pathogens and Vector Attraction in Sewage Sludge,” is incorporated by reference into the EPA regulation covering biosolids: 40 CFR Part 503. This document states that EQ standards must be maintained as long as the processor maintains control of the material. Therefore, if the biosolids processor is responsible for top soil blending, “…the new product must undergo pathogen and vector attraction reduction processes and be analyzed for Part 503 parameters including pathogens, vector attraction reduction and heavy metals.”

If, however, the EQ product has left the control of the processor (for example, the WWTP or privately owned composting facility sells the EQ biosolids), then the material falls out of the jurisdiction of federal regulations and any subsequent blending of the material with other products is not covered by the Part 503 regulations.

For biosolids processors in Pennsylvania, there are additional specific requirements in the PADEP General Permit for Beneficial Use of Exceptional Quality Biosolids (PAG-07) that should also be reviewed. These permit conditions are summarized below:

  1. The permittee (preparer of EQ biosolids) must provide the following information in writing to the person(s) responsible for the blending operations.
  2. Storage of the EQ biosolids intended for blending and the final product cannot be stored for longer than 1 year.
  3. The amount of EQ biosolids at the blending site cannot exceed 1000 cubic yards and the final product (blended topsoil) stored by the blending operation cannot exceed 7500 cubic yards. Otherwise, a processing permit is required.
  4. Blending and storage activities cannot be conducted in a manner that will create conditions that are conducive to the harboring, breeding, or attraction of vectors. This means no standing water.
  5. Storage must be designed to prevent discharges into surface or groundwater.
  6. Measures must be taken to minimize and control odors and dust emissions.
  7. Best management practices must be implemented to minimize run-on and runoff.
  8. Trucks must be tarped to prevent the potential for dust or spillage.
  9. Trucks/trailers used to transport EQ biosolids or topsoil cannot be used to transport food or feed without proper cleaning.
  10. The blending and storage activities cannot be conducted within 100 feet of a perennial stream, within 33 feet of an intermittent stream, within 11 inches of a seasonal high water table, or within 50 feet of a property boundary.
  11. The person responsible for the blending operations must keep daily records of the weight or volume of exceptional quality biosolids received and final products sold, given away, or otherwise distributed.

Biosolids processors and topsoil blenders need to be aware of these regulations and permit conditions and their interpretations.

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