What are bio-solids, and are they safe for school vegetable gardens?

With the increased interest in growing your own, some school districts are implementing programs to teach children

Kellogg Garden Products

about how to grow their food. The Los Angeles school district is one such place, which because of it’s location utilizes “star power” to promote their program. The EMA or Environmental Media Association is the organization who’s mission is to, “mobilize the entertainment industry in a global effort to educate people about environmental issues and inspire them into action”.  They have also utilized the generosity of a local soil amendment company, Kellogg Garden Products.

Recently a controversy surrounding the program, and the type of amendments they are using in those gardens arose. According to a SFGate article titled Sewage Sludge, Celebrities, and School Gardens, “It appears that Kellogg is using sewage sludge, purchased from the city of Los Angeles, in 70% of its fertilizers, while all the while branding them as ‘natural & organic.’ The promotional language on their website says: ‘The cornerstone to our success, stability, and integrity is our commitment to providing organic gardeners with products you can trust.’ Sewage sludge is not just treated human waste (which is gross enough, but apparently safe); it also contains hazardous contaminants drawn from sewer water by sewage treatments plants, including industrial solvents and chemicals, heavy metals, medical wastes, flame retardants and PCBs.”

I wrote to Kellogg’s, and received an e-mail from Kathy Kellogg Johnson, Chief Sustainability Officer. Here is her response to the above mentioned SF Gate Article.  “Thank you very much for contacting us and giving us the opportunity to respond to the blog post on SFGate.com. Essentially it is a reprint of an article that has been circulating the internet for the past few months.  The author is a self proclaimed activist who cites his own misquoted sources.  He has never contacted us to initiate a dialog.  His tactics include slamming Michele Obama’s White House garden, Alice Waters foundation for teaching children to garden, and many more.  There several factual errors in the article that I would like to point out:

1.      “It appears that Kellogg is using sewage sludge, purchased from the city of Los Angeles, in 70% of its fertilizers.”

This is FALSE. All of our fertilizers are OMRI listed, and OMRI does not allow products to be OMRI listed if they contain sewage sludge. Moreover, four products we produce (Amend, Topper, GroMulch, and Nitrohumus) contain what the EPA calls “Class ‘A’ Exceptional Quality Biosolid Compost.” To acheive Class A Exceptional Quality status, biosolids go through heavily regulated processes to remove contaminants and to kill pathogens. The resulting biosolids form a rich soil amendment that looks and smells like any other composted material. While we think that biosolids are a great soil amendment, we realize that some people find the concept unappealing. We offer our customers a choice by listing which products contain biosolids on our website, and offering several OMRI listed soil amendments as an alternative for those customers who would prefer not to use biosolids in their gardens.

I also want to note that biosolids have a benefit beyond any one individual garden. Composting them is a huge benefit to the environment, as the alternative is to dump sewage into the ocean, fill up our landfills with it, or to burn it. None of those options are as environmentally friendly as composting sewage and turning it into a soil amendment.

And just to point out how sloppy or deliberately misleading this article is with the facts, we get all of our biosolids from Inland Empire Utility Agency, not Los Angeles, which is clearly stated on our website. The 70% is a gross, inexcusable, exaggeration, and gives further evidence of the activist’s ill intent and zero effort to fact check.  In fact, just 4 of 276 products that Kellogg markets contain biosolids. No matter how I tweak the math, I can’t get to 70%.

2.      “Sewage sludge is not just treated human waste (which is gross enough, but apparently safe); it also contains hazardous contaminants.”

This is FALSE. As I mentioned above, the EPA heavily regulates the use of biosolids and all of Kellogg’s products that contain biosolids are 90% BELOW the allowable maximum for any contaminant. The original perpetrator of this article is taking advantage of the public’s lack of knowledge about soil science to scare them with data that sounds worrisome but actually is actually completely benign. Yes, testing equipment is now so good that we can detect minute amounts of all sorts of things. But just as a certain amount of arsenic is naturally occurring in some soils and is nothing to worry about, the amount of heavy metals in our products is extremely small and we make every effort to see that it matches the naturally occurring levels found in native soils.   The peer reviewed scientific data shows that there is nothing to be concerned about. To make this point even plainer, there are more heavy metals in your toothpaste than there are in our products.

3.      “sewage sludge is toxic and should not be branded as organic fertilizer, nor should it be used to grow food with, and very obviously, school children should not be digging around in it to grow zucchini and cilantro.”

This is FALSE. The statement that sewage sludge is toxic is factually incorrect.   The activist is entitled to his own opinion, but not entitled to his own facts.  Toxic is a defined term and the micro constituents sometimes found in biosolids are NEVER approaching toxic (harmful) levels.  All of the fertilizers donated to the EMA gardens were certified as organic and do not contain biosolids. The accusation that Kellogg lies about its fertilizer content and covers it up is an outright lie.

The “evidence” that Kellogg has donated products containing biosolids to EMA schools appears to be rooted in two publicity photos that show Amend in the background of the photo.    This was an inadvertent mistake on our part. We were asked to bring bags of soil to the photo shoot to be used as a prop.  I grabbed Amend and Gromulch, what was easily accessible, and these 2 photos are now what the activist points to in order to embarrass, discredit and dismember a very excellent garden program in Los Angeles.

As we increase our line of OMRI listed products, we have decided to only donate OMRI certified products to the schools we support through Environmental Media Association. But to reiterate the original points, there is nothing toxic in our products.  Kellogg complies with all state and federal regulations, and to take it a step further, we offer a large selection of OMRI listed products for the gardening public.  We are proud of our legacy of recycling organic materials from local sources and enriching soils and gardens that are virtually starving for organic matter.  We believe that there is excellence in our processes and in the return of biosolids to soils to enrich and nourish plant growth.

I hope my response to the blog post answers your questions, but if I can clarify anything or provide more information, I would be happy to do so. And again, I really appreciate that you gave us the opportunity to respond and share our side of the story.  i would love to talk further, and share the source documents, and get the word out there, that we need to all be cognizant of returning organic matter to our soils!”

I was contacted by a concerned parent who had bought some soil amendments from Trader Joe’s. On the bag it mentioned “no bio-solids” in the ingredients list. Wondering what bio-solids we’re, and why they made a point of saying none we’re contained in the bag, she did some research. She sent me the link to an article, that I followed to the SFGate.com article. As Kathy Kellogg says, no one asked for their side to the story so  I am happy to give Kellogg’s a chance to respond to the rumors.  This issue is new to me and I would like to learn more. We would love to hear from others who might be more knowledgeable on the subject.


About Trey Pitsenberger

Trey is a nurseryman, author, and speaker.

23. June 2011 by Trey Pitsenberger
Categories: | Tags: , , , , | 18 comments

Comments (18)

  1. My latest blog post, "What are bio-solids, and are they safe for school vegetable gardens?" http://t.co/J76sfdB via @pitsenberger

  2. Interesting post!  My initial take is that strictly processing sewage sludge is better than the alternative, though I’d like to see independent data.  Thanks for a reasonable, calm approach!

  3. I want to be clear in stating that I work for Kellogg Garden Products and believe wholeheartedly in the value of biosolids both in the garden, and in keeping sewage out of the ocean, landfills, and from being incinerated.

    I really appreciate that you posted Kathy’s response in its entirety so that people have a chance to see exactly what we think about this topic. Kellogg is still family-owned and run, and many of the employees who work for Kellogg have been with the company for so long, they’re practically family. I’m pointing this out so that people know that we will do our absolute best to answer any questions, and that the people who answer your questions deeply care about our products, the garden centers who sell them, and our customers.

    Elizabeth mentioned wanting to see independent data. The EPA conducts a study on biosolids every two years, as required by the Clean Water Act. You can read about their findings here: http://water.epa.gov/scitech/wastetech/biosolids/biosolids_index.cfm. You may also find their biosolids FAQ informative: http://water.epa.gov/polwaste/wastewater/treatment/biosolids/genqa.cfm.

    • I came upon this site because the quality of the kellogs garden soil I purchased is simply not of the quality I expected. Bits of plastic, plywood, and painted wood do not inspire confidence in soil purity of a veggie garden. Plastics leach chemicals, plywood uses formaldehyde based glues, and paint could be lead. I am supposed to be confident about feeding food grown in this to my three year old?

      • Gchasen–That’s very strange to find those items in a bag of our soil. I would love to get to the bottom of what happened with your soil, and we will of course, refund your money. Could you please email me so I can help resolve your problem? My email is fernrichardson@kellogggarden.com.

    • I also just posted an article on the data based on San Fran’s testing … http://biosolidsgrow.posterous.com/afraid-of-whats-in-sewage-sludge-biosolids-co

  4. All sewage sludge biosolids contains large quantities of toxic industrial wastes.
    (see EPA report on drugs, pharma, toxic metals, hazardous chemicals and other pollutants
    in sludge biosolids:
    http://water.epa.gov/scitech/wastetech/biosolids/tnsss-overview.cfm  )

    Scientists have documented the uptake of sludge pathogens and contaminants into plants and vegetables which are eaten by humans and animals:
    http://sludgevictims.com/plants/uptake.html   

       Many food processors and retail grocers  in the United States, Canada and UK  (including Campbells, Comstock, Dean Foods (Birdseye), DelMonte, Heintz, Nestle, Progresso, Libbys) will not sell food grown in sewage sludge biosolids:  http://www.sludgevictims.com/FOODCOMPANIES.pdf 

    Brainwashing school children with falsehoods about the safety of growing vegetable gardens in sludge biosolids is reprehensible.

    Helane Shields, Alton, NH   hshields@tds.net    http://www.sludgevictims.com 

    • Hi Helane–The EPA study you linked to does not show that large quantities of toxic materials are found in biosolids. If that were the case, the EPA would not continue to allow the use of biosolids. The EPA has found very small quantities of the things people consume, like pharmaceuticals, and is researching whether those items must regulated.

      And again, the only thing we’re interested in encourage children to believe is that gardening is a fun way to grow healthy food. We only donate organic products to school gardens.

  5. There is no doubt that Kellogg thinks it is doing the right thing. However, this belief is based on a thirty EPA, FDA, USDA policy to used sludge on fruits and vegetable. WEF has been running a PR program for EPA since 1994.

    Folks fail to understand that EPA doesn’t have any regulations for Biosolids. Part 503 is a sludge regulation. Nor does it regulate Class A sludge which is an arbitary designation based on low levels of a few toxic metals and a a low level of a few heat resistant Enterobacteriacea such as E. coli, Kelbsiella, Citrobacter, Enterobacter, and Salmonella colonies at the end of the fecal coliform test. It is possible to have EPA approved Class A sludge so contaminated that it can not be disposed of in a Part 503.23 Surface Disposal SIte.

    According to EPA’s sludge rule, these can be very dangerous. 503.9(t) Pollutant is an organic substance, an inorganic substance, a combination of organic and inorganic substances, or a pathogenic organism that, after discharge and upon exposure, ingestion, inhalation, or assimilation into an organism either directly from the environment or indirectly by ingestion through the food chain, could, on the basis of information available to the Administrator of EPA, cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunction in reproduction), or physical deformations in either organisms (humans) or offspring (children) of the organisms.
    http://deadlydeceit.com/503-9.html

    This is an excerpt from Myth #2, Composted Sewage Sludge (biosolids) is a Safe and Sustainable Organic Soil Amendment! A Short History LessonGenotoxic Contaminated Compost from EPA to Your Lawn and Garden
    In the case of sewage sludge/biosolids/compost use, the idea to sell or give it away is based on the myths that: 1) municipalities are running out of landfill space; 2) sludge/compost is an organic waste; 3) biosolids is different from sludge; 4) composting heat kills all pathogens; 5) antibiotic producing soil bacteria and fungi will kill those pathogens the heat of composting didn’t kill; 6) Escherichia coli, coli-like-forms (coliform), heat resistant coli-like-forms (fecal coliform) i.e., family Enterobacteriacea, and fecal Streptococcus are not disease causing organisms; 7) the coliform Salmonella is the only pathogen of concern; 8) chemicals in compost do not cause cancer, or other serious illness, or death; 9) crops do not take up chemicals or pathogens; 10) strict laws and regulations protect public health from toxic mismanaged sludge/biosolids/compost; 11) farmers and consumers have no legal right to know they are being exposed to cancer causing chemicals and deadly pathogens in sludge/biosolids/compost products; 12) less than 10% of exposed people would become health effects victims; and 13) victims could not make the connection between illness, or death, and exposure to sludge/biosolids/compost.
    http://thewatchers.us/myths/number-2-compost.html

  6. I am a soil scientist who has worked in the field of organic residual recycling for many years. In addition, I am a home gardener, who preferentially uses biosolids products to amend my vegetable and flower beds. Biosolids are consistent, safe, sustainable, and extremely effective.
    The notion that biosolids are unsafe to use as a soil amendment is as absurd as saying that manures are unsafe, or compost made from yard debris and food scraps are unsafe. Is there potential risk? Of course there is. It is a dirty world out there. Extensive (and multiple) risk assessments performed by EPA conclude that it’s an incredibly small and negligible risk, and I’m willing to take it. Biosolids are far more tightly regulated than manures, synthetic fertilizers, and yard debris composts, thus giving me further piece of mind regarding their safety. In addition, I realize that I am contributing to the biosolids waste stream (usually 1 to 2 times per day), and I would like to see recycling programs continue. The way to support recycling systems is to purchase and use the final product. Alternatives to recycling include landfilling and burning. What a waste of a resource that would be!
    To put some of these contamination claims into context, concentrations of flame retardants and dioxins are usually higher in household dust than they are in biosolids. Pharmaceuticals, metals, pathogens, and numerous other potential contaminants are tested for, and found at minute levels. Manures, yardwastes, and synthetic fertilizers often contain higher metals concentrations than biosolids. Pathogens are destoyed by composting, just like they are in manure and yardwaste composts. Pharmaceuticals, dioxins, flame retardants can sometimes be detected at extremely low levels in biosolids, but no where near high enough concentrations to warrant concern. The EPA has studied biosolids to death. the first round of regulations was developed between 1984 & 1993, the 2nd round  between 1999 & 2003, the 3rd round was recently completed.
    There is a scientific consensus regarding the safety of the land application of biosolids. It may be controversial, in the same way the theory of evolution is controversial. I think it’s important that we acknowledge, however, that it is not controversial for scientists.

    • There is a problem, you are implying that you fully understand that the 1,000 fecal coliform per gram of solids allowed in compost was based on counted colonies of heat resistant Enterobacteria at the end of the test and reported as one bacteria per colony. If the test shows you have a 1,000 colonies of a combination of E. coli, Salmonella, Enterobacter, Klebsiella, Yersinia (and 25 more) per gram, then it is difficult to explain how they are destroyed. EPA has never claimed pathogens were destroyed in compost. It leaves that to the scientists.

      According to EPA’s 1995 “A Guide to the Biosolids Risk Assessments” (page 110) for the EPA Part 503 Rule, the sludge health risk assessment was only based on looking at 13 organic chemicals which were either already banned, no longer manufactured or restricted for use. These were dropped from consideration in the rule. Not only that but EPA did not consider any cancer causing chemicals in the risk assessment, nor did it consider any heavy metals would cause cancer.
      http://www.epa.gov/owm/mtb/biosolids/503rule/503g_ch6.pdf

      Yet, in the 1989 proposed regulation EPA has admitted (1989) that five of the admitted twenty-one carcinogens in sludge are carcinogenic when inhaled in dust — Arsenic, Beryllium, Cadmium, Chromium IV and Nickel. (FR 54, p. 5777)http://deadlydeceit.com/1989_503_cancer_list.html

      EPA also listed 25 pathogen which it claimed only caused gastroenteritis, but forgot to included some very deadly bacteria and viruses.http://thewatchers.us/1-2-1-PATHOGENS.htmlhttp://deadlydeceit.com/1989_503_pathogens.html

      Pathogens are not destroyed by composting. EPA only requires that they be temporarily inactivated.

      According to EPA’s original Mar. 1988 study,”Occurrence of Pathogens in Distribution and Marketing Municipal Sludges”
      “Although the use of sludge as a soil amendment is attractive, it is not without potential health risks. Toxic chemicals, including heavy metals and industrial organics, may enter the food chain and present long-term health risks.” The plague causing bacteria Yersinia was consistently found in static pile compost. CDC authorities state, “Outbreaks in people still occur in rural communities or in cities.”significant increases in bacterial populations, including salmonellae, occurred during subsequent production of commercial soil amendment products.

      Then we have the 1981 study, “Factors Affecting Salmonellae Repopulation in Composted Sludges” states, The repopulation potential and recovery of Salmonella sp. and their close relatives Arizona spp. and Citrobacter spp. in sewage sludge which had been composted was examined. Salmonellae growth in previously composted sludge was found to occur in the mesophilic temperature range (20 to 400C), require a moisture content of -20%, and require
      a carbon/nitrogen ratio in excess of 15:1.These results also indicated that some enteric bacteria, upon desiccation, became dormant and in this state were highly resistant to both heat and radiation. Optimal recoveries in the low bacteria sample occurred at the 21% moisture level at 28 to 360C after a 5-day incubation. The population increased more than four orders of magnitude under these conditions. The indigenous salmonellae initiating this growth had survived in a desiccated state for over 1 year prior to providing the proper moisture-temperature combination for the repopulation to occur. — as long as a demonstrated potential exists for repopulation of salmonellae in a commercial soil amendment product produced from composted sludge, a potential health hazard exists for the user.APPLIED AND ENVIRONMENTAL MICROBIOLOGY, Mar. 1981, p. 597-602http://thewatchers.us/EPA/2/1981-salmonella-regrowth-compost.pdf

      EPA’s 2006, Biosolids Technology Fact Sheet, Use of Composting for Biosolids Management, based on Yanko’s 1988 study, states,
      “Under some conditions, explosive regrowth of pathogenic microorganisms is possible.” “Composting is not a sterilization process and a properly composted product maintains an active population of beneficialmicroorganisms that compete against the pathogenic members.”

      [Note: EPA and partners have assured the public that composting destroys pathogenic disease causing organisms]

      Limitations
      Odor production at the composting site.

      Survival and presence of primary pathogens in the product.

      Dispersion of secondary pathogens such as Aspergillus fumigatus, particulate matter, other airborne allergens.

      Lack of consistency in product quality with reference to metals, stability, and maturity.

      In addition to odors, other bioaerosols, such as pathogens, endotoxins, and various volatile organic compounds, must also be controlled.

      Biofilters are often used to control odors, but the biofilters themselves can give off bioaerosols. (28)http://www.epa.gov/owm/mtb/combioman.pdf

  7. Kate, there is no scientific consensus on whether sludge is ‘safe’.
    Working as you do with Sally Brown, who makes her endorsement of sludge use widely known, you may have a collegue who shares your enthusiasm for sludged food.  Outside of your office, there are many scientists who urge caution  due to the inconsistancy in sludge biosolids, the pathogens, the chemicals, the toxic metals in sludge, the inbalance in nutrients, the endocrine disruptors, the pharmaceuticals.  Spreading sludge on farmland is not sustainable, since through repeated applications the metals will continue to increase in the receiving soil until the soil will not support plant growth.

    In Europe and North America  more and more people buy certified organic food. They  pay premium prices to be assured that there is no sewage sludge used on their food.
    No, they do not share your enthusiasm for sludged food.

    It is deceitful to mislead the public into thinking that ‘organic residuals’ means certified organic quality…when in fact it means sewage sludge – a material banned in certified organic farming.

    Very solid, very sound reasons exist to avoid the use of industrially contaminated materials -including sludge – in agriculture.  Many would argue that a person- like you - who knowingly puts sewage sludge on her home vegetable garden thus exposing herself to toxic metals and industrial chemicals, deliberately increasing her body burden of contaminants - has the more absurd position.

  8. Hello, I work for the Center for Media & Democracy, the group that went after Kellogg. The article made a mistake. Kellogg’s “fertilizers” are sludge-free. But many of their COMPOSTS do contain sludge.

    Second, the sludge comes from the Inland Empire Regional Composting Authority… but that sludge comes from BOTH the Inland Empire Utilities Agency AND from the Los Angeles County Sanitation District. So in this case, Kathy Kellogg was telling a pretty big lie. I’ve personally called LA to confirm that YES their sludge goes to IERCA.

    Third, the sludge DOES conform to EPA’s standards. But those standards are pathetically lax. A 2002 National Research Council study found that the standards were based on outdated science, and a study published last week found that the standards were outdated and were not effective in killing noroviruses. Most importantly, a San Francisco 2010 test found high levels of dioxins in Kellogg Amend, which is made with – you guessed it – sludge.

    As for the 70% number, that came from a stat we found – and I’d have to look up the source to find it again – that said 70% of their business was sludge. They have a huge line of products and 70% of them do NOT contain sludge. Only 4 or 5 do. But based on what I’ve seen available in stores as well as based on the size of the bags, I’d bet that 70% of their sales are sludge-based products measured either in volume or dollars. Usually you see people buying their sludge products and in my area, most Home Depots do not carry their full line of products. They tend to carry 3 brands of sludge and 1 of non-sludge. I had to call all over town to find a Home Depot that had the organic stuff.

  9. One last point for you… I wrote the article about Michelle Obama and we did NOT slam her for gardening. I congratulate and applaud her for gardening. Unfortunately for her, previous occupants of the White House applied sewage sludge to the White House grounds. When she decided to plant a garden, she was the victim of that sludge use, as her soil was potentially toxic. For most gardeners, accessing the tests needed to find out which toxins, if any, are in your soil is expensive and near impossible. I tested my own soil for lead and a few other things fairly easily and cheaply, but when I wanted to test for arsenic or other potential contaminants, I could not find a lab that accepted samples from the public and had reasonable prices and did a sensitive enough test. Thank goodness that Michelle Obama is the First Lady and can have any tests and soil remediation she needs done for her. The point of the article was to say that most people aren’t that lucky.

  10. I would like thank Trey for actually attempting to hear Kellogg’s side in this matter.  I wholeheartly agree with Kate and the thousands of scientists who have researched biosolids for decades and concluded that returning it to the soil is the best environmental use.  Most of the loudest voices in this debate are not scientists, but rather activists with an agenda. 

    I am a scientist who has researched biosolids and choose to use it on my own food crops.  As Kate said, it is more highly researched and regulated than any other soil amendment out there.  As an urban dweller is it more responsible for me to use recycled urban products to enrich my soil than import them from somewhere else.  It is fundamentally unsustainable to send the vast amounts of organic matter present in biosolids to landfills when a huge body of research says they can be safely recycled by returning them to the soil. 

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