STOP WASTE FARMS IN PENNSYLVANIA.   UPDATED: 12/8/2023

The Pennsylvania Department of Environmental Protection (DEP) allows food processing wastes to be spread on land as beneficial use “fertilizers” and “soil conditioners”.  The activity is managed with regulations dating from the 80s and 90s; which doesn’t reflect decades of science.  The most recent science around “forever chemicals” (PFAS/PFOS) from the Environmental Protection Agency (EPA) shows that land application of food waste products and biosolids is introducing forever chemicals into our precious farmland at unsafe levels.  

Science also suggests these materials are absorbed into the “edible portion” of our crops. A recent 2022 case in Michigan found that beef products sold to schools in that state contained dangerous levels of PFAS/PFOS forever chemicals, and that those cattle had been fed crops grown in fields where food waste and/or biosolids were applied.  Other states are catching on and now regulating this activity.  What is most incredible about this is that only a small fraction of forever chemicals are even detectable.  An advanced test may be able to detect 50 or so and there are more than 5000+ known variations.  Beyond forever chemicals, there are pharmaceuticals and microplastics that are still immature fields of study and pose unknown contamination risks.  Even if we ignore forever chemicals, and emerging fields; there are multiple other health, welfare, and other environmental concerns.  

Pennsylvania refers to Food Processing Waste as a “Food Processing Residuals” or FPRs.  The DEP’s FPR Manual describes FPRs as including “process wastewater from cleaning slaughter areas, rinsing carcasses, or conveying food materials; process wastewater treatment sludges; blood; bone; fruit and vegetable peels; seeds; shells; pits; cheese whey; off-specification food products; hides; hair; and feathers.” 

The sum of these various products, detergents, and processing byproducts varies significantly from one to the next, but they often contain more hazardous substances than beneficial substances.  As noted in the FPR Manual, they can contain Arsenic, Lead, Cadmium, Chromium, Mercury, Molybdenum, Selenium and even PCBs. FPRs can also affect the quality of the soil; with the FPR Manual noting; “Certain FPRs, particularly meat and poultry processing sludges, contain significant quantities of fats and oils. Overapplying such FPRs can decrease the permeability of some soils.”  What is missing from the FPR manual is everything that happened in the last 20+ years in science, specifically in the proliferation of Forever Chemicals and Plastic Contamination, and our infantile understanding of pharmaceutical compounds in these waste streams from human and animal sources.  Forever chemicals specifically are all around food processing, packaging, and production.  These products are used in non-stick coatings, cleaning products, and all sorts of materials around food processing.  More on that in a second. 

The DEP already recognizes the near non-existent value of Land Application of this material in the FPR Management Manual.  These facts are referenced in multiple places within that manual.  The primary benefit of land application of FPRs is skirting environmental regulations associated to Landfills, Impoundment and Incinerators, and reducing costs to the processor. These facts are written in plain sight in the PA DEP FPR Management Manual.  

Environmental protection standards are becoming more stringent, and disposal costs continue to escalate. Therefore,we need to take a new look at alternatives – FPRs must be minimized and recycled.

-Pa FPR Management Manual, Page 1

Forever Chemicals represent the biggest emerging issue with waste streams. Forever Chemicals refers to a family of compounds built around carbon-fluorine bonds. These bonds are stable, and resistant to water, oil, heat, and other compounds.  These properties make them ideal for use in firefighting foam, stain resistant products, non-stick applications, heat resistant applications, various processing, and manufacturing efforts where its properties are desirable.  There are more than 5000 related chemicals known to the EPA as of 2021.   

EPA studies show that there is a significant concern to waste product streams as forever chemicals are present in food processing waste and biosolids in detectable and unsafe quantities.  The chemicals then enter the food supply;

“PFAS have been reported in food, food packaging, food waste streams and compost made from food waste streams.”

“Composts made from a variety of materials, such as food waste, leaves and grass, and manure, show a range of contamination levels and suggest that biosolids have the highest concentration of PFAS, followed by food waste, then yard waste and other organic wastes.”

-EPA, Emerging Issues in Food Waste Management.

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Data suggest that edible crops grown in soil conventionally amended with municipal biosolids may contain PFAS, and further studies are needed to characterize mechanisms of uptake from various soils and crops

-EPA, Regional Applied Research Effort (RARE) 

Across the country farms are being tested for forever chemicals and being shutdown for these activities', yet the activities continue in many states, including PA.  The EPA sets a safe drinking water level at 1 part per trillion.  A farm in Maine was recently found to be contaminated due to this activity.  The crops were absorbing the forever chemicals, which were being consumed by dairy cows.  The cows milk was tested and returned what might be the highest level of PFAS ever detected;  32,200 parts per trillion.

“The amount of PFOS in milk from the dairy herd at the Tozier farm in Somerset County was worse than “startling” — it may be the highest milk contamination levels ever recorded in North America. Measurements in late June and early July ranged from 12,700 to 32,200 parts per trillion (ppt). The highest reading is 153 times Maine’s standard for determining that milk is “adulterated” and unfit for sale (210 ng/l). As a result, the farm has been forced to stop selling its milk and beef.”

“With a second farm shuttered due to massive PFAS contamination, Maine legislators weigh easing access to the courts”  - IATP.org

This is a petition to all parties to consider a moratorium on land application of waste products and to specifically separate Food Processing Waste and Biosolids disposal from the Right to Farm Act.  This would allow local municipalities to better manage waste disposal within their borders.  Waste should be treated as Waste, not a farming byproduct.  A small adjustment to these laws/rules will protect our farmers and our environment from forever chemicals, reduce nutrient pollution to the Chesapeake Bay, improve resident health and welfare, ensure the proper handling of waste materials, and in the appropriate places and quantities.