The role of consultation in sludge management issues
Emmanuel ADLER
ACONSULT- Club ATOUT BOUES
Centre d'Affaires des Monts d'Or - 69290 St Genis les Ollières - France
tel 33 - 4 78 57 3939
fax 33 - 4 78 44 8074
http://www.atoutboues.fr.st/
Philosophy is the whole of the questions where the one asking the question is himself concerned by
the question, Merleau-Ponty
Summary
Through various angles (history, sociology, case studies and international
comparisons), we should demonstrate that consultation in sludge management
issues is an issue by itself that requires special attentions.
For environmental utilities of public concern (waste facilities, industries, roads,
airports..), people in developed countries tend to be more concerned by the "image"
than by the technology itself. It seems that anthropological issues are becoming more
important than technological data. Therefore, it is necessary to elaborate new ways
to process projects related to environmental public services. Because of public health
concern, such decisions are strongly dependant on scientific knowledge and then
challenged by the precautionary principle. Therefore, addressing expectations of the
population becomes necessary (information, training and consultation…). Besides,
because of the nature of biosolids, projects often involve other organic residues and
stakeholders, making it compulsory to communicate properly. Other aspects
(regulatory framework, pressure from the media…) also contribute to underline the
strong need for more consultation.
1- Improving management practices in environmental public services
Convinced that environmental public services can no longer achieve sustainable
development without strong changes in current management practices, we do believe
consultation is the key word to solve most of present conflicts related to water or
waste management. By consultation (see box n°1) , we shall comprise all actions
targeted towards communication, concertation and negotiation.
Based upon industrial experience in drinking water & wastewater engineering, a
simple methodology is being developed to facilitate biosolids projects using both
technical and anthropological approaches1.
This collective work involves various stakeholders2 and several projects at different
levels, from a community reed beds project3 to an information website4 for French
1
We have to thank Pr JP GOUBERT from EHESS for his strong support on the human science side.
Public and private partnership have been developed with a strong focus on communication issues.
3 Several projects have been followed in the Rhône area for rural villages
4 www.atoutboues.fr.st
2
Emmanuel ADLER
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speaking stakeholders and a national group5 dedicated to promoting biological
solutions for biowaste management (compost, methanisation, landspreading).
The present paper presents our analysis concerning ways projects are or not
implemented and attached procedures for taking key decisions. First, we should
consider statutory and regulatory changes related to environmental decisions,
underlying the strong need for more public participation.
box n°1 - what consultation is about
2- About environmental decisions
Communication and consultation for environmental projects are becoming more and
more important because, on one side, people are demanding more confidence and
participation, and, on the other side, because science itself, revised by the
precautionary principle, requires transparency and holistic approach. We should
consider two selected examples as follow :
At the community level, the Aarhus convention from 25.6.98 and the Directive
2001/42/EC on the assessment of the effects of certain plans and programmes on
the environment have been adopted. Recently, the European Commission services
sent out in April 2002 a first Working Document outlining the basic ideas on a
proposal for a Directive on Access to Justice in Environmental Matters with the
objective to contribute to the enforcement of legislation relating to the environment
and to reduce existing enforcement deficiencies, in order to ensure a high level of
environmental protection.
In the United Kingdom, the Interdepartmental Liaison Group on Risk Assessment
(UK-ILGRA) defining the Precautionary Principle, wrote that “Precaution is
controversial because the 'why', 'when' and 'how' of precautionary intervention goes
to the heart of the regulation of hazardous activities and their place in society…
Properly applied it is a positive, proportionate policy tool to encourage technological
innovation and sustainable development by helping to engender stakeholder
confidence that appropriate risk control measures are in place”.
5
This large group is attached to the French professional association AGHTM and puts together over
60 different professional stakeholders concerned by biowaste management. To develop appropriate
tools, four working groups have been set up (health, technology and R & D, town-industry-farm
cooperation & communication, regulatory issues).
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3- Setting up the framework – considering the confusion
Assessing the present of sludge6 management and trying to forecast its future is
obviously not very easy as everyone here, in this international specialised
conference, can experience it, looking for up-to date information in order to improve
the efficiency. Obviously our problem, though human excreta do have to be
considered special, does not exclusively apply to biosolids management and can be
transposed to other environmental issues of public concern, especially those related
to waste management but not only (i.e water and air quality).
Thus, today, the management of residues is becoming more and more difficult for
various types of reasons (regulatory, social, technical, financial, political…). This is
why it is necessary to consider the biosolids problem as part of a larger one, with
other residues and stakeholders.
3.1 Biosolids among other residues
It can then be pointed out, especially for professionals coming from the water sector,
that biosolids management issues can no longer be considered alone and require to
take into account the hole set of organic residues (from municipalities, farms or
industries). In order to better understand the situation of biosolids, data related to
domestic animals7 and organic fluxes can be provided.
For instance and for France, table 1 presents recent estimates for animal
populations, and graph 1 shows major organic residues fluxes applied to land,
underlying the fact that 96% of the total amount is coming from the countryside and
only 4% from municipalities and industries (food processing, paper, chemical…).
Tab 1 –estimates of animal populations in France (1999)
species
population
% of total N
millions
%
content
released
beef cattle
20
4,7
74
pigs
16
3,8
10
sheep
9,5
2,3
6
goats
1,2
0,3
1
horses
0,4
0,1
2
poultry
313
74,2
7
Human
62
14,7
?
6
The question of terminology is very important as it reflects the way the residues are considered. We
shall then latter use the commonly accepted name “biosolids” which, by the way, has no equivalent in
French, though some professionals tried to adopt "biosolides"...
7 It could be interesting to consider also animals living in houses, France being n°1 in the UE for pets
(9 millions cats, 8 millions dogs, 27 millions fish, 7 millions birds, 2 millions mice and assimilated !)
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Graph 1 – major organic residues fluxes applied to land in France (2000)
biosolids 2% poultry 2%
sheep & goats 6%
agroindustries 2%
pigs 8%
beef cattle
80%
To get an overview of the hole set of organic residues produced in France, graph 2
presents current available data :
Graph 2 - estimates of organic residues in France (millions tons Wet Matter 2000)
catering oils
Street & market waste
Meat Industry waste
Green waste
Sugar Industry waste
Municipal waste
0,08
0,3
0,5
0,7
0,73
1,34
3
9
9
10
20
44
55
Crops waste
94
275
Cattle waste
0
50
100
150
200
250
3.2 Diversity of technological solutions
As it can be demonstrated with the conference program with over 100 presentations,
the nature and number of management solutions for biosolids are becoming more
and more numerous involving as many new stakeholders coming from various
horizons.
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300
Compiling all possible technological solution for human excreta management, starting
from activated sludge reactor (but why not event start from scratch with "just after"
the restrooms ?) to sonic device (before digestion) would be unachievable. Projects
involving organic residue management (biosolids, municipal waste or cattle
dejections) require various technologies described as follow :
-
destruction processes (incineration, gasification, pyrolysis…),
storage process (land filing of either sludges or its solid mineral content other
destruction),
land recycling processes (direct spreading of liquid residues or biological
treatments, i.e. mainly composting and methanisation)
4- Major obstacles for projects implementation
Though History does remind us human excreta management has always been an
inextricable problem for society8, things are endlessly evolving (from "what we eat" to
"how we process residues") and require new assessments.
In fact, we shall all agree managing biosolids is becoming more and more complex,
both at :
-
local level (community),
and at higher levels (national legislation9, European directives, WHO or EPA
recommendations…).
4.1 Setting up limits
To that extent, we shall consider the issue of standardization for organic residues
based upon a recent WARP report10. We therefore Extracted limit values for mercury
content for product quality in different international standards are presented in graph
3, pointing out the necessity for improved consultation at that type of stage11.
Please refer to our paper presented in Wakefield in 2001 called “human excreta management : in
need for new paradigm”.
9 See annex 1 for French regulation on organic residue (or product) management for land spreading.
10 Comparison of compost standards within the EU, North America and Australasia, June 2002.
11 It is interesting to recall the EU Memorandum in Doha, 11/11/2001, whish stated “We believe that
standards of transparency and consultation for the definition of voluntary and mandatory labelling
standards would help to reduce the costs of compliance with such standards”.
8
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Graph 3
limit values in different standards for mercury for composts and sludges (mg/kg DM)
USA Recommend. USDA (Min.f.agric.)
USA EPA/High Quality
UK UKROFS fertil.org.farming
Sweden
Spain Decr.1310/1990 pH>7
The Netherlands Compost (very clean)
Luxembourg Recommended
Italy DPR 915/82
Hungary(x)
Germany Bio waste ordinance (I)º
Germany M 10 K.II2
France Legisl.sew.sludge/industr.waste
Finland Target values 1998
Denmark Comp.before 01 06 2000
Belgium Min.f.Agric
Austria ON S 2200 Class III2)
EUsew.sludge Lower limit
Eco-label' 488/98 EEC
0
10
20
30
40
50
60
4.2 Main issues
To summarize, we can consider the following obstacles for implementing biosolids
projects (excluding technological & financial aspects) :
-
absence of scientific consensus12 given precautionary principle policies,
diversity of stakeholders concerned (public authorities, citizens, firms,
scientists...),
complexity of decision making processes.
Crisis may occur according to different scenarios, depending on local situations and
on general socio-cultural conditions.
5- Examples of crisis
Recent examples can illustrate how difficult it is to implement new projects. We shall
focus on NGO activism and consider various actions.
12
This word is an absolute necessity for PCRD projects financing by the European Community DG
Research.
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5.1 Actions against incineration
The Greenpeace association released a report on health and incinerators13 followed
by a very aggressive campaign in various countries. The pictures in box 2 have been
considered representative :
box n°2 - Greenpeace actions against incineration
It is also interesting to mention local associations which focus on a specific projects :
box n°3 - exemple of a US association against incineration
13
INCINERATION AND HUMAN HEALTH, State of Knowledge of the Impacts of Waste Incinerators
on Human Health. Greenpeace Research Laboratories, University of Exeter, UK. (March 2001)
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5.2 Actions against land filling
Spreading liquid or treated wastewater sludge can create serious oppositions. The
pictures in box 4 have been considered representative :
box n°4 - selected actions against land application of sludge
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6- Developing consultation tools to prevent crisis
6.2 Definitions
Concert : to plan together; to settle or adjust by conference, agreement, or
consultation; to devise; to arrange; to act in harmony or conjunction; to form
combined plans.
Negotiation : the deliberation which takes place between the parties touching a
proposed agreement. That which transpires in the negotiation makes no part of the
agreement, unless introduced into it. It is a general rule that no evidence can be
given to add, diminish, contradict or alter a written instrument.
merc. law. The act by which a bill of exchange or promissory note is put into
circulation by being passed by one of the original parties to another person. Until an
accommodation bill or note has been negotiated, there is no contract which can be
enforced on the note: the contract, either express or implied, that the party
accommodated will indemnify the other, is, till then, conditional.
6.2 Examples to feed the debate
Recent examples can illustrate how communication is becoming crucial for selecting
solutions. Pictures in box 5 have been considered representative :
box n°5 - selected actions of communication
Debate over the sludge issue in a US
county
Debate over public perception and drinking water
(AWWA, 2002)
Debate over the sludge issue in a
scientific journal
Biosolids, odors and poetry (NBP, 2000)
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As presented in 2001 in this conference, we do consider History as a major input for
developing consciousness and consultation related to biosolids projects. We provide
here after two examples of the past that could help communicating…
recent book on the history of lavatories
human excreta management in Paris,
16th century
6.3 Perspectives
What the future of biosolids will be ? Most likely, it will depend more and more on
consensus and therefore will be a mix of local and general opinions. For project
promoters, appraising necessities and possible tensions is imperative. If no one can
talk for all the numerous stakeholders, consultation shall improve project
management.
Our team is in the process of developing those new consultation tools.
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