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Union Leader Op-ed: Sludge Applications (and PFAS Residues) Will Reduce the Safety of Our Food System 

On May 9, 2022, the Union Leader published an article reporting that in the wake of rising fertilizer prices, some farmers across NH are turning to sludge from wastewater treatment plants as a replacement.


Sludge poses significant environmental dangers, including the potential to contaminate soil with per- and polyfluoroalkyl substances (PFAS). These forever chemicals are toxic to human health and the environment


Recently in Maine, groundwater and well water at some farms exceeded state PFAS standards by factors in the hundreds.


Maine Legislature passed a bill in April 2022 banning the application of sludge that contains any amount of PFAS on farmland.


While NH has required tests for PFAS in sludge since 2017, the Department of Environmental Safety won’t establish standards until late 2023. Currently, sludge in NH cannot be rejected because of PFAS levels.


We at NOFA-NH stand against the spreading of PFAS containing sludge from municipal and industrial operations on farmland. In response to the article, members of our board drafted an op-ed, which was published on June 17, 2022. You can read the op-ed here or below with the original resources linked in the text, which were excluded from the published version.

Sludge Applications (and PFAS Residues) Will Reduce the Safety of Our Food System 

June 17, 2022

By Edith Pucci Couchman, Hollis, Member of the NOFA-NH Board of Directors; Joan O'Connor, Henniker, Member of the NOFA-NH Board of Directors; Kate Dobrowski, Warner, Member of the NOFA-NH Board of Directors



Healthy food and clean water are essential for human life. That’s why we at the Northeast Organic Farming Association of New Hampshire (NOFA-NH) were alarmed and concerned to read your recent headline: “With fertilizer costs skyrocketing, farmers find a friend in New Hampshire sludge.” 

Sludge applications will reduce the safety of our food systems. Municipal and Industrial sludge (biosolids, biosludge—choose your euphemism) are known to contain concentrations of PFAS: synthetic chemicals that have been linked to disorders such as infertility, endocrine disruption (including thyroid damage), testicular and kidney cancer, and weakened immune function. These toxic and persistent chemicals are commonly found in municipal and industrial sludge. Because such chemicals have been shown to cause harm even at very low levels, we are convinced that it’s not a good idea to apply them to the precious soils, pastures, and orchards that produce our meat, dairy, vegetables, and fruit. 

NOFA-NH exists to support and extend ecologically-sound and socially just ways of growing and eating. We strive to be well-informed farmers and consumers who actively care about the well-being of our communities, soil, biodiversity, and future generations. We believe good food is raised by using organic, organic-regenerative, and biodynamic methods. We think that our fellow farmers and gardeners who use sludge are not being served well when government officials suggest that sludge is safe. Sludge applications could result in farms and pastures being transformed into mini toxic waste dumps—for the convenience and profit of various industrial and municipal entities.  

We are painfully aware of the situation in Maine (and other parts of the country) where farmers are losing their farms because soil and animals have been contaminated from PFAS containing sludge. We see the citizens of Maine taking this threat so seriously that they enacted legislation in May to keep sludge out of their food web.  

We also empathize with our neighbors in the vicinity of the Saint-Gobain Performance Plastics factory and the Pease Airforce Base who have suffered directly from PFAS contamination of their water. (‘Biosolids’ applied to fields can also wash off into adjacent waterways and aquifers). 

It’s clear that if PFAS contamination levels continue to grow, everyone will suffer from the consequences. The impact could include not only life-threatening or disabling diseases but also costly, yet necessary taxpayer funded programs to clean up the mess and responsibly treat those who are ill.   

This sludge situation is an example of how industrially made synthetic chemicals are damaging the essential air, water, and land that support all life. While some countries protect their citizens somewhat better than others, in the long run, it’s a global predicament. With regard to PFAS, companies such as 3M and Dupont (who recently spun-off this class of chemicals—and potential liability—to a new entity: Chemours), have made a significant sum of money selling PFAS to unsuspecting ‘consumers’ for over 60 years. Meanwhile, years have also been required for evidence to accumulate and research to be conducted documenting the harmfulness of these novel materials. These dangerous ‘forever chemicals’ continue to enter the environment (and our bodies) from sources such as carpet dust, factory air stacks, grease-resistant takeout packaging, and paper mills. Some specific chemicals in the PFAS class (featured in products such as “Scotch Guard,” “Teflon,” and fire-fighting foams) have been banned in Europe and the US, but, often, as in the case of synthetic pesticides, new ones are hurried into the market as quickly as the earlier ones are regulated or proscribed. These new PFAS chemicals are even more difficult to remove from water supplies and are also likely to be harmful. In an effort to close such regulatory dodges, in July, six countries in the European Union will propose a ban on this entire class of synthetic chemicals.   

Going forward, the United States as well as Europe, needs legislation that will require companies to prove that new products are harmless before such products are commercially licensed and sold. This approach is known as the Precautionary Principle. People should not have to wait for tragic outbreaks of illness before public health is protected. The absence of precise results from expensive, complex, and time-consuming research is not an excuse for regulatory agencies to shirk their missions. As we all wait for the science to become even clearer, let’s take action and treat our soils, food, and bodies with respect. Let’s adamantly oppose the disposal of sludge on gardens and farmlands, and let’s buy local foods that are produced without such toxic additions. 

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