First and Last Name: Dr. Karen Knutsen
Organization or Affiliation: Chehalis River Council
These comments were filed with the Washington Department of Ecology (DOE) on December 18, 1997
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First and Last Name: Dr. Karen Knutsen
Organization or Affiliation: Chehalis River Council
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Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
If a delegated authority has failed to carry out adequately any portion of the delegated responsibility regarding sewage sludge management, the department must revoke all or part of the delegation, pursuant to its stated purpose of protecting human health and the environment (WAC 173-308-010 (2) (a)), otherwise that purpose is not served. The rule must have the force of law, so that inadequate management of sewage sludge cannot be allowed to continue. Only when consequences are defined and mandated will there be any recourse for citizens when local government fails in its responsibilities.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-050 (2) (b) to read: "The department must revoke part or all of a delegation of authority under this section if it finds that a local health department has failed to carry out adequately any portion of a delegated responsibility."
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
There should be no question but that the department will impose requirements in addition to, or more stringent than, the requirements of this chapter if it is necessary to protect public health and the environment. This should be mandatory, and the wording of the rule should give it the force of law. Such action is the least the public should be able to expect from the department, whose primary purpose is protection of the public health and the environment.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-130 to read: "On a case-by-case basis, the department must impose requirements for the beneficial use of biosolids that are in addition to or more stringent than the requirements in this chapter if the department believes that the additional or more stringent requirements are necessary to protect public health and the environment from any adverse effect of a pollutant in the biosolids."
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
There should be no option to reduce monitoring of sewage sludge by preparers of biosolids after two years. The amount of toxic metals, toxic organic chemicals, and pathogens in sewage sludge depend upon the day-to-day composition of the material entering the waste treatment plant, and the efficacy of the pathogen reduction protocols. The composition of sludge can vary enormously from day to day, thus to monitor only once a month, or once a year, is totally inadequate for the purpose of assessing the contaminant content of the sludge. So-called "hot loads" can occur due to intermittent high loadings in the waste stream. These are not necessarily predictable, but can lead to contaminant concentrations that can be orders of magnitude higher than the average value monthly or yearly plant monitoring might indicate. Monitoring too infrequently would miss these contributions to the pollutant concentrations. Also, the contaminant levels can change due to changes in amounts of storm water runoff or changes in the industrial waste stream entering the treatment plant, either from new plants coming on line, going out of business, or altering their industrial processes. Monitoring even once a month is questionable in its efficacy for characterizing sludge. To reduce this further after two years is to assume a stability in the incoming waste stream that is totally unrealistic. In fact, we recommend that weekly monitoring be the minimum allowed any preparer of biosolids for land application. The inaccurate characterization of sewage sludge represents a threat to public health and the environment. The proposed change would lessen that risk, and keep the department in line with its primary purpose: the protection of public health and the environment.
Please provide specific language for your recommended change or addition.
Delete WAC 173-308-150 (2).
Change the table in WAC 173-308-150 (3) to read "a minimum of weekly" for monitoring frequency in all categories.
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
The cumulative pollutant loading rates for biosolids listed in Table 2 of WAC 173-308-160 are based upon the USEPA 503 regulations. They are much higher than their European counterparts, and their ability to protect human and environmental health is unproved. In fact, the maximum permitted metal loadings in soil established by the USEPA 503 regulations are as much as 1-2 orders of magnitude higher than current international standards. In addition, the USEPA allowances for copper, cadmium, and chromium exceed levels that the Netherlands considers a serious threat to humans or the environment (1). Why is this EPA regulation, and therefore the proposed state rule, so lax? Why have cobalt, chromium, and molybdenum been removed from the list of regulated metals, especially when chromium is a byproduct of so many industries and hexa-valent chromium is so very toxic? Why are our government regulators, including the department, so ready to convert our national farmland, forest land, and "public contact sites" into toxic waste dumps? Why are we working so hard to contaminate our food supply, and most probably our water supply as well? These are not rhetorical questions. We recommend that the proposed rule adopt standards equivalent to those currently applied in western Europe regarding the maximum metal loading allowed in soils, and that adherence to these loading levels be maintained regardless of the metal concentrations found in the applied sewage sludge.
Airborne pollutants can be major contributors to metal and toxic organic contamination of soils, especially in industrialized areas. For example, the US stopped putting lead in gasoline because airborne lead particulates were contaminating its soil and water. Therefore, we also recommend that the maximum permitted metal loadings in soil include background levels in the soil prior to the proposed sludge application, and that loading not simply be calculated from the amount of sludge applied.
(1) M. B. McBride, "Toxic metal accumulation from agricultural use of sludge: are USEPA regulations protective?," Journal of Environmental Quality, vol. 24, p. 5, 1994.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-160 (2) to read: "Table 2 of this section sets the maximum quantities of pollutants that may be added to an area of land, also referred to as the cumulative pollutant loading rate. The cumulative pollutant loading rates in Table 2 apply whenever biosolids are applied to the land."
Change WAC 173-308-160 Table 2 to reflect the more stringent European standards.
Change WAC 173-308-160 (2) (b) to read: "Before bulk biosolids are applied to the land, the person who proposes to apply the bulk biosolids must have the background levels of regulated metals in Table 2 of this section determined prior to application. Cumulative pollutant loading rates due to subsequent application of biosolids to the site may not then exceed the cumulative pollutant loading rates in Table 2 of this section, including background concentrations."
Delete WAC 173-308-160 (2) (b) (i), (ii), (iii), and (iv).
Delete WAC 173-308-160 (3).
Change WAC 173-308-160 (4) to read: "Table 4 of this section sets annual pollutant loading rates used to derive an annual whole biosolids application rate. Table 4 is applicable to all biosolids that are sold or given away in a bag or container for application to the land. The person who prepares the biosolids must provide information on compliance with this requirement on a label or information sheet as required under WAC 173-308-260 (1) (b) (ii) and (4) (b)."
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
Applying sewage sludge to a land reclamation site at greater than the agronomic rate is a hazard to ground- and surface waters and to any plant or crop grown on the site. Excess application of soluble nitrogen can result in ground- and surface water contamination which is already well-known to be a human and environmental health hazard. Any over-application of fertilizer can imperil water quality, and in the name of protecting the waters of the state, should not be allowed. In addition, if the potential for ground water contamination due to biosolids application is found to exist, it is the duty of the department to require ground water monitoring or other conditions, and subsection 5 should state this with the force of law.
Please provide specific language for your recommended change or addition.
Delete WAC 173-308-190 (1).
Change WAC 173-308-190 (5) to read: "When the potential for ground water contamination due to biosolids application exists, the department shall require ground water monitoring or other conditions in accordance with WAC 173-200-080. If it is determined that an enforcement criterion may be violated, an evaluation must be conducted to demonstrate compliance with the provisions of WAC 173-200-050 (3) (b) (vi)."
Draft #: Proposed Rule OTS-175 - Draft date: -
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
All exemptions to regulation based upon the so-called "exceptional quality" of biosolids should be eliminated. The standards used for the "exceptional quality" classification with respect to toxic metals are derived from the USEPA 503 regulations, which are far less stringent than their European counterparts, and the effectiveness of which for protection of public health has been questioned in a recent scientific study (1). Arbitrarily defining "safe" levels of toxic metals in sludge, below which all regulation, public notice, and monitoring are eliminated, is scientifically indefensible. What is important is the final metal loading of the soil at the application site, as well as the degree to which metals are lost to ground- and surface waters. Despite protestations that the metals do not move off of the site, there is significant scientific evidence to the contrary (2). The degree to which metals move depends upon a large number of factors, such as soil pH, particle size, soil chemical composition, slope, amounts of rainfall, and soil organic content, to name just a few. The combination of these factors will be unique to a given application site, and if that site is not properly evaluated and mitigated, there may be significant risk of ground- and surface water and crop contamination. Under the "exceptional quality" exemptions, there would be no preliminary determination of metal loadings, and no monitoring to determine if metal loading limits are ever met or if the metals are contaminating ground- and surface waters. While 300 mg/kg of lead in sludge may allow it to be considered "exceptional quality" and therefore free of any regulation, according to the Clean Water Act, the acceptable level of lead in drinking water for children is 0. The "exceptional quality" limit for e. coli bacteria is 1000 MPN per gram (dry weight), despite the fact that the average number of bacteria that can cause illness in humans is 10. Other dangerous bacteria and viruses are not even monitored. Under the "exceptional quality" exemptions, the public, and even the landowner, would not have to be notified of the significant risk associated with the land application of sewage sludge. There are no "exceptional quality" standards for organic chemicals. These are, in fact, not to be regulated or monitored under any section of the proposed rules, despite the fact that dioxin, PCB's, pesticide residues, and other persistant, toxic organic chemicals are known to be present in sludge (3), and may become concentrated in the food chain starting from crops raised on sewage sludge application sites (4).
By eliminating exemptions from regulation for so-called "exceptional quality" sewage sludges, and by rigorously enforcing proper site selection, mitigation, and monitoring of sewage sludge application to land, we can minimize the possibility of adverse environmental and health effects from sewage sludge. I recognize the need to "do something with it." The problem of what to do with human and industrial waste is complex and can seem overwhelming, as it continues to pile up while we spend time trying to work out a solution. However, arbitrarily declaring hazardous waste "safe" and then dumping it totally unregulated and unmonitored onto an unsuspecting public is the kind of behavior that has already led us to the tragedy of poisoned farms and citizens in Quincy, Washington. The state has the power to regulate more stringently than the federal guidelines, and in the interest of protecting public and environmental health, which is the primary responsibility of the Department of Ecology, it should do so.
(1) M. B. McBride, "Toxic metal accumulation from agricultural use of sludge: are USEPA regulations protective?", Journal of Environmental Quality, vol. 24, p. 5, 1994.
(2) M. B. McBride, et al. "Mobility and solubility of toxic metals and nutrients in soil fifteen years after sludge application," Soil Science, vol. 162, p. 487, 1997.
(3) Cornell Cooperative Extension Publication, excerpt from: "1997 Cornell Recommends for Integrated Field Crop Management: Land Application of Sewage Sludges", p. 4.
(4) M. S. McLachlan, et al., "A study of the influence of sewage sludge fertilization on the concentrations of PCDD/F and PCB in soil and milk," Environmental. Pollution, vol. 85, p. 337, 1994.
Please provide specific language for your recommended change or addition.
Delete WAC 173-308-200 "Exemptions based on the exceptional quality of biosolids" in its entirety.
The deletions and changes below reflect the deletion of exemptions from regulation for "exceptional quality" biosolids, as specified in WAC 173-308-200:
Change WAC 173-308-210 (4) (b) to read: "The site management restrictions in (b) (i) through (iii) of this subsection are applicable to all biosolids when they are applied to agricultural land."
Change WAC 173-308-210 (5) (b) to read: "The person who applies biosolids to agricultural land must keep the records required in WAC 173-308-290 (4).
Change WAC 173-308-220 (4) (b) to read: "The site management restrictions in (b) (i) through (iii) of this subsection are applicable to all biosolids when they are applied to forest land."
Change WAC 173-308-220 (5) (b) to read: "The person who applies biosolids to forest land must keep the records required in WAC 173-308-290 (4).
Change WAC 173-308-230 (4) (b) to read: "The site management restrictions in (b) (i) through (iii) of this subsection are applicable to all biosolids when they are applied to a public contact site."
Change WAC 173-308-230 (5) (b) to read: "The person who applies biosolids to a public contact site must keep the records required in WAC 173-308-290 (4).
Change WAC 173-308-240 (4) (b) to read: "The site management restrictions in (b) (i) through (iii) of this subsection are applicable to all biosolids when they are applied to a land reclamation site."
Change WAC 173-308-240 (6) (b) to read: "The person who applies biosolids to a land reclamation site must keep the records required in WAC 173-308-290 (4).
Change WAC 173-308-120 (6) to read: "The person who applies bulk biosolids to the land must obtain written approval of the landowner prior to applying biosolids to the land. In addition, written notices must be sent to all adjacent landowners. The landowner must add a legal description of the area(s) to which biosolids have been applied to his/her deed(s)."
Delete WAC 173-308-310 (6) (a) (i) through (iv).
Change WAC 173-308-310 (6) (b) to read: "Land application plans are required when bulk biosolids are applied to the land. Treatment works treating domestic sewage that propose to apply biosolids to the land must either:"
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
The concentration of contaminants in the sewage sludge should have no bearing on the mitigation, monitoring, or regulation of sludge application sites. Just because a piece of ground becomes a hazardous waste site in 20 years instead of 2 does not mean that it has become any less of a hazardous waste site. Cumulative loading rates must always be adhered to in order to safeguard human and environmental health.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-210 (1) (b) to read: "The total cumulative loading rate for each pollutant may not exceed the limit in Table 2 of WAC 173-308-160."
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
It is the responsibility of the department to safeguard human and environmental health. As stated in WAC 173-308-190, it is the responsibility of the proposed rules for "biosolids" management to enforce water quality standards as defined in WAC 173-200, and the federal Clean Water Act. Protecting water quality is of vital importance. Allowing sewage sludge (or "biosolids") to be dumped indiscriminately is not. There is no compelling reason to allow sewage sludge (or "biosolids") to be applied in floodplains, within 100 feet of wells, or applied so that they enter wetlands or waters of the state. It is well known that sewage sludge (or "biosolids") contains toxic metals, toxic organic chemicals, and pathogens, regardless of any so-called "exceptional quality" designation. It is also well established that the toxic metals in sewage sludge (or "biosolids") are water soluble and bioavailable for many years after sludge application has ceased (1). Therefore, application of sewage sludge to areas such as those defined above presents an unacceptable risk of toxic contamination entering ground and surface waters. Our recommendation, then, is to bar such practices entirely with the force of law and with no exceptions.
(1) M. B. McBride, et al. "Mobility and solubility of toxic metals and nutrients in soil fifteen years after sludge application," Soil Science, vol. 162, p. 487, 1997.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-210 (4) (a) (x) to read: "Biosolids must not be applied to the land within one hundred feet of a well."
Change WAC 173-308-210 (4) (b) (i) to read: "Biosolids must not be applied to land that is 100 feet or less from surface waters of the state."
Change WAC 173-308-210 (4) (b) (ii) to read: "Biosolids must not be applied to land so that they enter a wetland or waters of the state."
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
It is the responsibility of the department to safeguard human and environmental health. As stated in WAC 173-308-190, it is the responsibility of the proposed rules for "biosolids" management to enforce water quality standards as defined in WAC 173-200, and the federal Clean Water Act. Protecting water quality is of vital importance. Allowing sewage sludge (or "biosolids") to be dumped indiscriminately is not. There is no compelling reason to allow sewage sludge (or "biosolids") to be applied in floodplains, within 100 feet of wells, or applied so that they enter wetlands or waters of the state. It is well known that sewage sludge (or "biosolids") contains toxic metals, toxic organic chemicals, and pathogens, regardless of any so-called "exceptional quality" designation. It is also well established that the toxic metals in sewage sludge (or "biosolids") are water soluble and bioavailable for many years after sludge application has ceased (1). Therefore, application of sewage sludge to areas such as those defined above presents an unacceptable risk of toxic contamination entering ground and surface waters. Our recommendation, then, is to bar such practices entirely with the force of law and with no exceptions.
(1) M. B. McBride, et al. "Mobility and solubility of toxic metals and nutrients in soil fifteen years after sludge application," Soil Science, vol. 162, p. 487, 1997.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-220 (4) (a) (ix) to read: "Biosolids must not be applied to the land within one hundred feet of a well."
Change WAC 173-308-220 (4) (b) (i) to read: "Biosolids must not be applied to land that is 100 feet or less from surface waters of the state."
Change WAC 173-308-220 (4) (b) (ii) to read: "Biosolids must not be applied to land so that they enter a wetland or waters of the state."
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
It is the responsibility of the department to safeguard human and environmental health. As stated in WAC 173-308-190, it is the responsibility of the proposed rules for "biosolids" management to enforce water quality standards as defined in WAC 173-200, and the federal Clean Water Act. Protecting water quality is of vital importance. Allowing sewage sludge (or "biosolids") to be dumped indiscriminately is not. There is no compelling reason to allow sewage sludge (or "biosolids") to be applied in floodplains, within 100 feet of wells, or applied so that they enter wetlands or waters of the state. It is well known that sewage sludge (or "biosolids") contains toxic metals, toxic organic chemicals, and pathogens, regardless of any so-called "exceptional quality" designation. It is also well established that the toxic metals in sewage sludge (or "biosolids") are water soluble and bioavailable for many years after sludge application has ceased (1). Therefore, application of sewage sludge to areas such as those defined above presents an unacceptable risk of toxic contamination entering ground and surface waters. Our recommendation, then, is to bar such practices entirely with the force of law and with no exceptions.
(1) M. B. McBride, et al. "Mobility and solubility of toxic metals and nutrients in soil fifteen years after sludge application," Soil Science, vol. 162, p. 487, 1997.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-230 (4) (a) (ix) to read: "Biosolids must not be applied to the land within one hundred feet of a well."
Change WAC 173-308-230 (4) (b) (i) to read: "Biosolids must not be applied to land that is 100 feet or less from surface waters of the state."
Change WAC 173-308-230 (4) (b) (ii) to read: "Biosolids must not be applied to land so that they enter a wetland or waters of the state."
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
It is the responsibility of the department to safeguard human and environmental health. As stated in WAC 173-308-190, it is the responsibility of the proposed rules for "biosolids" management to enforce water quality standards as defined in WAC 173-200, and the federal Clean Water Act. Protecting water quality is of vital importance. Allowing sewage sludge (or "biosolids") to be dumped indiscriminately is not. There is no compelling reason to allow sewage sludge (or "biosolids") to be applied in floodplains, within 100 feet of wells, or applied so that they enter wetlands or waters of the state. It is well known that sewage sludge (or "biosolids") contains toxic metals, toxic organic chemicals, and pathogens, regardless of any so-called "exceptional quality" designation. It is also well established that the toxic metals in sewage sludge (or "biosolids") are water soluble and bioavailable for many years after sludge application has ceased (1). Therefore, application of sewage sludge to areas such as those defined above presents an unacceptable risk of toxic contamination entering ground and surface waters. Our recommendation, then, is to bar such practices entirely with the force of law and with no exceptions.
(1) M. B. McBride, et al. "Mobility and solubility of toxic metals and nutrients in soil fifteen years after sludge application," Soil Science, vol. 162, p. 487, 1997.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-240 (4) (a) (x) to read: "Biosolids must not be applied to the land within one hundred feet of a well."
Change WAC 173-308-240 (4) (b) (i) to read: "Biosolids must not be applied to land that is 100 feet or less from surface waters of the state."
Change WAC 173-308-240 (4) (b) (ii) to read: "Biosolids must not be applied to land so that they enter a wetland or waters of the state."
Draft #: Proposed Rule OTS-175 - Draft date: -
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
Bulk biosolids should not be applied to lawns and home gardens, regardless of a so-called "exceptional quality" classification. The standards used for the "exceptional quality" classification with respect to toxic metals are derived from the USEPA 503 regulations, which are far less stringent than their European counterparts, and the effectiveness of which for protection of public health has been questioned in a recent scientific study (1). Arbitrarily defining "safe" levels of toxic metals in sludge, below which all regulation, public notice, and monitoring are eliminated, is scientifically indefensible. Under the "exceptional quality" exemptions, there would be monitoring to determine if metal loading limits are ever met or if the metals are contaminating ground- and surface waters, or the extent to which metals are contaminating the food crops grown in home gardens. Indeed, the public would not even be warned about the hazards to which they would be exposed when using sewage sludge on lawns and home gardens. They would not be warned that they may want to keep children away from the sludge material, which can contain toxic metals and organic chemicals, and dangerous pathogens, or that they should be sure to work it into the soil. They will have no warning about toxic contaminants that may be picked up by food crops in their home gardens. While 300 mg/kg of lead in sludge may allow it to be considered "exceptional quality" and therefore free of any regulation, the acceptable level of lead exposure for children is 0. The "exceptional quality" limit for e. coli bacteria is 1000 MPN per gram (dry weight), despite the fact that the average number of bacteria that can cause illness in humans is 10. Other dangerous bacteria and viruses are not even monitored. There are no "exceptional quality" standards for organic chemicals. These are, in fact, not to be regulated or monitored under any section of the proposed rules, despite the fact that dioxin, PCB's, pesticide residues, and other persistant, toxic organic chemicals are known to be present in sludge (2) and may become concentrated in the food chain starting from crops raised on sewage sludge application sites (3).
By rigorously enforcing proper site selection, mitigation, and monitoring of sewage sludge application to land, we can minimize the possibility of adverse environmental and health effects from sewage sludge. Lawns and home gardens are sites where the public, and especially children, are likely to have intimate contact with the sewage sludge material. In the case of lawns, especially, it is unlikely that the sewage sludge will be worked into the soil, and quite likely that children will be playing directly in the sludge. The state has the power to regulate more stringently than the federal guidelines, and in the interest of protecting public and environmental health, which is the primary responsibility of the Department of Ecology, it should do so.
(1) M. B. McBride, "Toxic metal accumulation from agricultural use of sludge: are USEPA regulations protective?", Journal of Environmental Quality, vol. 24, p. 5, 1994.
(2) Cornell Cooperative Extension Publication, excerpt from: "1997 Cornell Recommends for Integrated Field Crop Management: Land Application of Sewage Sludges", p. 4.
(3) M. S. McLachlan, et al., "A study of the influence of sewage sludge fertilization on the concentrations of PCDD/F and PCB in soil and milk," Environmental Pollution, vol. 85, p. 337, 1994.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-250 (1) to read: "Biosolids shall not be applied to a lawn or home garden."
Delete WAC 173-308-250 (2) and WAC 173-308-250 (3).
Draft #: Proposed Rule OTS-175 - Draft date: -
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
The public has a right to know what they are buying (or are given, or are paid to take). They have a right to full disclosure of contents and risks associated with any so-called "commodity" they may be offered. Failure to provide proper labeling of sewage sludge offered to the public as "fertilizer" or "soil conditioner" deprives them of the right to know, and of the right to choose. The state may claim a mandate to dispose of it, but it is the right of every citizen to choose NOT to use it on their own lawns, gardens, farms, or in other ways in which they, the citizens, not the state, deem the risk to their own, their family's, or the environment's health is too great to be acceptable. People can make informed choices only when they are informed. Our recommendation is to mandate full disclosure of sludge trace contaminants, pathogen levels, health risks of use, and instructions for "safe" handling via labels applied to sewage sludge which is sold or given away in bags or containers. In addition, the labeling suggestions of subsection (a) (iii) should be mandated (label shall contain, not may contain, information on agronomic rates, product storage, hygiene, and the protection of the environment) for all biosolids sold or given away in bags or other containers. The arbitrary classification of "exceptional quality", which thereby removes the labeling requirements entirely, is unacceptable, for the reasons addressed above, and because the "safety" of the USEPA standards on which the designation is based is not proved.
Please provide specific language for your recommended change or addition.
Change WAC 173-308-260 (4) "Label or information sheet required" to read: "Any person who prepares biosolids that are sold or given away in a bag or other container in the state of Washington, must comply with the requirements of (a) (i) through (vi) of this subsection."
Change WAC 173-308-260 (4) (a) (iii) to read: "A statement or information that encourages proper use of the product and protection of public health and the environment. This must include information on agronomic rates, product storage, hygiene, and protection of surface or ground water resources."
Please state your comment, question, or recommendation. Explain your concern. How will your recommendation improve the rule?
The public has the right to be fully warned and informed with respect to the health hazards of coming in contact with a sewage sludge (or "biosolids") application site. The substitution of "no trespassing" signs for the informational signs required under subsection (1) of this section warns and informs no one, and is therefore unacceptable under any circumstances.
Please provide specific language for your recommended change or addition.
Delete WAC 173-308-275 (2).
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