Letter To: the Department of the Environment
103 33 Stockholm, [Sweden]
Re: the use of sewage sludge on farm land
The Association of Food Producing Industries is in favor of thinking in terms of recycling in all areas of the industry occupation, meaning that plant nutrients shall be captured and re-introduced in a sustainable cycle between city and countryside. The primary condition for using sewage sludge, however, is that the quality and the consumers' confidence in the food can be maintained.
The Association of Food Producing Industries (LI) started in cooperation with the industries concerned during 1996 a cooperative project led by the Royal Academy for Forestry and Agriculture. The purpose of this work was to formulate common requirements for the Food Industry regarding the use of sewage treatment sludge on farmland producing foodstuff.
The work resulted in a policy declaration adopted by the board of the Association on March 10, 1998 and states the industries' view on the spreading of sludge on farmland (see appendix).
Vi have since summer of 1998 until now, held discussions regarding this policy with all the parties involved in the Sludge Agreement which is in effect since 1994, those parties being the National Farmers Association, the Swedish National Environment Protection Agency and the Water and Waste Water Association. The Swedish Association of Food Producing Industries finds this process heading in the right direction concerning many of our demands, while other issues lack resolve and lacking drive amongst the parties involved.
Against this background, we now turn to the final authority for these issues in Sweden.
The issues regarding sludge dispersion are very complex and contain several aspects such as the risks related to health and the environment and an added component of economical risk, which is related to the consumers' confidence in our food products.
LI's principal stand is that any possible spreading of sludge on farmland shall take into consideration the quality of the land and the food products and not primarily operate from a social objective to incorporate organic waste in cycles.
One of the most important demands, and probably the most difficult to resolve, is our demand regarding a long-term balance between additions and removal of metals and other undesirable compounds. Much has been done to reduce the discharge of metals and many point sources have been eliminated. Regarding Cadmium, where serious problems remain, the total addition from airborne sources, chemical fertilizers and sewage sludge been cut in half during the last ten years but the accumulation in the farmland continues. To accomplish a sustainable cycle between town and country in the foreseeable future, measure have to taken both nationally and internationally. Internationally, Sweden must act to reduce the emissions of metals since the precipitation from airborne contaminants counts for a large portion.
LI's view is that it is the role of government to design a long-term plan that shows the path towards balance between addition and removal of undesired compounds in farmland. Without such a plan we find it difficult to get behind the objective of a sustainable cycle between town and country.
The Association does not view it as their primary task to be a driving force behind a goal of a sustainable town and country cycle. LI will participate in discussion and to formulate our demands but we are not "the owners" of the problem.
We are impacted by it since, when all is said and done, we carry the ultimate responsibility for the quality of the food which is made from raw materials derived from the farm land and we are the parties suffering if the consumers confidence in the food products decline.
To get a broad acceptance amongst the consumers and the citizens for recycling of nutrients in sludge we find that the research and field tests must be expanded. The objective must be to clarify the long-term effect on soils and harvested crops as well as long term health effects both from heavy metals and other undesirable compounds.
Today sufficient funds are not available to implement the planned field experiments and relevant analyses. Furthermore there is a need for information to the public about why recycling of organic waste from societies food consumption to agriculture is an important part of the cycle.
We intend with this letter to clearly state our point that the Department of the Environment and the other parties involved, must take a comprehensive responsibility for the measures necessary to accomplish the goals and objectives that have been set regarding sludge distribution on agricultural land. This goal must be attained with restored consumer confidence and sufficient quality of the raw materials produced on those soils and are used in food production. A long-term sustainable situation means a balance between heavy metals added to farmland and sludge is only one of the problems in this process. The alternative is that the Department of the Environment issues a revision concerning the present goal concerning sludge use in agriculture. If no credible long term strategy to achieve a balance between metal addition and removal (that is effective on each individual farm) is presented, we can not see any possibility to accept sludge spreading on farm land.
Kind Regards
Swedish Association of Food Producing Industries (LI)
Jan Rosenström Tomas Lööv
CEO Executive Secr