Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Biosolids Use Regulations See Virginia Pollution Abatement (VPA) Permit Regulation at 9 VAC 25 - 32 [12 VAC 5 ‑ 585]
Action Enforcement and Site Management
Stage Proposed
Comment Period Ended on 12/15/2006
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12/7/06  12:00 am
Commenter: Karen Martin, citizen Bedford Co.

Comments regarding proposed regulatory actions part2
 

I will now comment on the more general area of biosolids as regulated by VDH. In my opinion, VDH has failed to “step up”.

In the Agency Statement, VDH acknowledges that one of the options available was to revise the entire set of biosolids use regulations. However, it chose the easier path, stating “Although additional requests for revisions to the Biosolids Use Regulations have been submitted by local governments and private individuals, the process of revising the entire set of the Biosolids Use Regulations will likely become a long drawn out process, as the land application of biosolids is a highly controversial subject. Thus, the Virginia Department of Health is electing to recommend that only the previously listed sections of the Biosolids Use Regulations be revised at this time.”

Yes, it’s a very tough subject, but that doesn’t mean any stakeholder should play “ostrich”, and particularly not the state agency whose stated mission is “to achieve and maintain optimum personal and community health by emphasizing health promotion, disease prevention and environmental protection”.

Why did VDH duck its responsibilities? Apparently because the agency is more concerned about the financial health of biosolids corporations than the physical health and well-being of Virginia citizens. The Agency Statement actually says doing anything other than what they chose to do “…will likely result in local adoption of ordinances with varying non-uniform requirements, that could have significant financial impacts on the regulated entities.”

The biosolids issue is an extremely important long-term health issue. The results of dumping sewage sludge into the ocean took time to rear their ugly heads. Now, we all accept as “good science” that dumping sludge in the ocean is a very environmentally unsound practice. Applying deductive logic to good science tells us that the same material is likely to eventually cause equivalent problems when dumped on land. Sludge is not like manure from your own barn that you throw in the manure spreader. It has pathogens and heavy metals and is entering our food chain right where it all begins. 

As citizens, we expect our state health department to protect us, not protect the companies doing the dumping.  

CommentID: 337