application of sludge and wastewater must, therefore, address such public concerns if they are to achieve their goals.

Recommendations

  • States and municipalities that wish to implement a beneficial-use program need to address public concerns and provide assurances that the new uses of sludge and wastewater do not endanger health or the environment in application areas. The public and local officials should be involved in the decision-making process at an early stage.
  • The operators of municipal wastewater treatment facilities and the parties using sludge and wastewater should implement visible, stringent management and self-regulation measures, including monitoring and reliable reporting by farmers, and should support vigilant enforcement of appropriate regulations by local or state agencies. Implementation of these measures will be credible means of preventing nuisance risks and harm to people, property, and highly valued nearby resources.
  • The municipal utility should carry out demonstration programs for public education, and to verify the effectiveness of management and self-regulatory systems. In addition, the utility should be prepared to indemnify farmers against potential liabilities when farmers' financing by banks or other lenders may hinge on this assurance.
Other Regulations and Institutional Controls

From a regulatory perspective, it is important to remember that EPA's Part 503 Sludge Rule augments a wide array of existing institutional programs and controls over the disposition of municipal wastewater and sludge. For example, federal and state regulations govern the handling and treatment of toxic waste and the protection of surface and ground waters. These regulatory mandates appear adequate to manage most of the risks associated with land application, but they must be funded and implemented to be meaningful safeguards.

Sludges that do not meet beneficial use criteria standards as defined by the Part 503 Sludge Rule must be disposed of according to federal and state regulations as applicable. Both the general public and state and local regulators should be aware that the Part 503 Sludge Rule is not the only control over agricultural use of sewage sludge.

Recommendation

  • Management of sludge for beneficial use should be more visibly linked to existing regulations governing its disposal. Program credibility may be improved and public concern reduced if federal, state, and municipal


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