Aligning policy and priority on biosolids

Guest blog

Where there’s muck, there’s brass – but after fifty years of value, is it time for a rethink? Dr Peter Matthews, Past President of CIWEM and former Chair of Natural Resources Wales, reflects on half a century of generating value from waste and asks if policy and priority are really aligned in the biosolids debate.

There was a time when sewage – urban waste water – was simply a problem to be got rid of as fast as practicably possible. But it wasn’t long before some bright spark discovered what had been thought of as waste was anything but. Ever since, we’ve been in a race to extract value from it – for energy, for fertiliser, even for the water it contains. But as the Environment Agency looks again at biosolids policy, are we learning all the lessons of the past that we can?

Fundamentally, sewage is a sustainable resource. For a long time, it and the products of engineered treatment – what we’ve come to call sludge – have been treated and used beneficially on land. There are still memories of the ‘honey cart’ of ‘septage’ in many places in the countryside. And in recent times, almost all the sludge produced by sewage treatment in England and Wales has been used safely and beneficially on agricultural land.

Thus was created the concept of ‘biosolids’: in simple terms, treated sewage sludge used in agriculture in accordance with national regulations and agricultural best practice. Biosolids to land is an excellent example of how a happy alliance of economics and sustainability can work. Biosolids that go to land avert the need for the natural alternatives of carbon intensive incineration, and a reliance on artificial fertilisers.

That said, our senses combined with society’s (quite legitimate) focus on public health occasionally replenish our angst about anything to do with sewage. Concerns such as microplastics, anti-microbial resistance and ‘forever chemicals’ bubble up. And while management practices have evolved to reflect community concerns, fifty years have passed since our current control systems started to form back in 1971. The Biosolids Assurance Scheme, led by the water industry, is one of the most recent moves taken to demonstrate that careful practice can provides the assurance that farmers, regulators and food manufacturers crave.

The birth – and death? – of a national strategy

Our first National Strategy considering all aspects of sludge management was established in 1981 after the formation of a national approach to the delivery of water services in 1974. The next big step in agricultural use was the Sludge (Use in Agriculture) Regulations, and associated Code of Practice in 1989 (supplemented in 1992 by the Safe Sludge Matrix). But since then, there has been a gradual disintegration of the National Strategy, as other sludge management routes became subject to different regulatory regimes.

The Environment Agency has now proposed a fundamental change in sludge regulation. And whilst it is called a Sludge Strategy, it focuses just on biosolids to land. It proposes to bring this into the Environmental Permitting Regulations (EPR) regime, but leaves other aspects of sludge management already within the EPR separate and fragmented. There is not, per se, a National Strategy or regulatory framework.

The EA is right that it is time for a review and refresh – inevitably, incremental change over decades has resulted in inconsistencies which need resolving. But what is proposed departs from what we know works, building on the last fifty years of sludge management. What’s more, it falls short of ‘better regulation’ principles, and abandons the principles of integration. I don’t believe it has to be that way, and there’s no better time than now to rethink the approach.

Recreating the collaboration

When the many and various challenges we currently face – for instance, the need to reverse losses in ecological diversity, better conservation of resources as part of a circular economy, and the new Environmental Land Management scheme – are stacked against the diversification of sludge treatment and utilisation opportunities, it’s clear we need to recreate the collaboration and consensus that worked so well in 1981 to underpin the original national strategy and regulations.

That starts with looking beyond just the use of sludge in agriculture in favour of a broader regulatory framework that embraces all potential uses. For sure, changes are necessary even within the current context. Not least there remains confusion over the miscellany of terms used incorrectly and interchangeably! My view is we should rally around the overarching term ‘bioresources’, and protect the purity of the term ‘biosolids’ to refer to treated sludge meeting strict standards.

Beyond that, there’s an urgent need for informed debate. For instance, does the concept of a sludge marketplace, including co-treated products from blended waste streams, help or amplify public concerns? Without a national framework for managing sewage sludge, questions like this (that were well tested in the 1980s and 90s) become very difficult to answer.

Creating space to find the right answers

I think the way through this is not as murky as it might seem.

To begin, we need a return to the benefits of a national focus of all interested parties creating the background to future agreement on the best way forward. Such a national consensus served us well in 1981 and could serve us equally well in 2021.

Second, and reflecting Ofwat’s terminology, we should develop an integrated national strategy for managing sewage sludge and describe it as the ’National Strategic Framework for Managing Bioresources’. The objective would be to ensure the safe management of all bioresources and, in particular, to ensure the safe, sustainable, assured, desirable use of biosolids in agriculture as the favoured option. I would propose it contains modules setting out the requirements for each option of management, with existing regulatory and control modules slotted in as now, but kept under review.

And thirdly, we need a coherent process for developing the evidence base and evaluation of emerging risks. With this in mind we have begun work on a national archive for sludge management practice, which will help collate knowledge before paper records and memories fade.

For the full five decades since government and industry started thinking about a better way to manage urban waste water I’ve been – metaphorically – up to my neck in it! Both within industry and as a regulator. I know this is a complex area, but I also know there is tremendous benefit to be secured for water companies, for agriculture, and for the environment more generally if we get this right. A narrow view that ignores the potential at stake would be a real missed opportunity. And the unintended consequences could easily set us back more than the fifty years of progress we’ve made since I first got involved in the hunt for brass from muck.

Continue the conversation: why not consider joining CIWEM's Wastewater and Biosolids Network?