Product Stewardship - The Next Big Thing

There is a growing concern today in the biosolids management field about the increasing presence of microconstituents in wastewater treatment plants and, consequently, in biosolids.  Microconstituents are defined as “miniscule particles of natural and manmade substances, such as pharmaceutical and personal care products, pesticides, and industrial chemicals, which have been detected within water and the environment.”[1]   There is little research to date that would definitively ascertain any potential risks to human health or the environment from microconstituents.  And, although their detection in our water systems is not a new phenomenon, the increased presence raises concerns about the implications for public health.  More research needs to be done to assess the risks of various microconstituents and to improve our understanding of their effects, both short term and cumulatively, on humans and the environment.

In the summary document from “Charting the Future of Biosolids Management,” [2]it was noted that participants identified two major biosolids constituent concerns: phosphorus (P) concentrations and microconstituents.  The discussion centered on the uncertainly felt by managers about the feasibility of biosolids management options due to future regulation of microconstituents.  Most studies addressing the fate of emerging contaminants in wastewater focus on what is left in the effluent rather than in the biosolids.  The participants agreed that much further examination and research needed to be done with the evaluation of microconstituents being addressed in a multi-disciplinary manner.  There is a need for an understanding of these compounds presence and effects in biosolids, in soil/plant interactions, and in thermal processes.

Since, there is no denying that microconstituents do exist in wastewater and biosolids, the prudent course of action on the part of wastewater management officials would be to consider how these particles could be treated and/or reduced in the wastewater and biosolids stream.  Treatment methods could be costly or complicated since there is no one course of treatment for the hundreds of chemicals and compounds that are passing through wastewater treatment plants.  A much more effective solution would be to reduce or prevent them from ever entering the waste stream by controlling them at the source. 

To do this, we must address several issues:

-         public awareness of the problem

-         how unused pharmaceuticals are disposed

-         how personal care products are produced and disposed

-         conduct research to determine which microconstituents are of concern to the biosolids sector

-         determine the pathways by which they reach wastewater and biosolids

-         the fact that current federal regulations require pathogen reduction and monitoring for some metals, but no regulations govern the presence of organic pollutants[3]

This approach speaks to the idea of developing product stewardship solutions.  Product stewardship is an environmental management strategy in which all parties involved in the design, production, sale and use of a product take responsibility for minimizing the product’s environmental impact throughout all stages of the product’s life.[4] The greatest responsibility lies with whoever has the most ability to affect the lifecycle environmental impacts of the product.  The companies that produce the products should be held responsible, at least in part, for reducing the toxicity and/or persistence to begin with and for their safe disposal. 

In August, 2010, the EPA released a literature review database called, “Treating Contaminants of Emerging Concern”[5] which summarized recent articles on wastewater treatment technologies and their current ability to remove a number of chemical contaminants of emerging concern (CECs).  Wastewater treatment plant operators may find some of the information useful in studying how to remove CECs from wastewater.  The EPA did not promote any particular technology or assign priority to contaminants.  This body of work was presented as a source of historical information and current CEC treatments for use by operators, managers and designers of wastewater treatment plants.  It explained how many CECs “enter the municipal wastewater through bathing, cleaning, laundry, and the disposal of human waste and unused pharmaceuticals.” (EPA document)  Wastewater treatment plants and drinking water plants were not designed to specifically remove CECs from wastewater, but removals often occur through secondary treatment.  However, the report goes on to say that “the use of the term ‘removals’ simply means less of the target chemical was observed after treatment than before treatment.”  (EPA document)  This may have been due as much to biological and chemical transformation of contaminants into benign molecules such as carbon and water or into a totally different chemical that is of no concern as a known pollutant.

The American Academy of Pediatrics (AAP), along with the American Medical Association, the American Public Health Association, and the American Nurses Association, have issued statements calling for an overhaul of the Toxic Substances Control Act (TSCA) of 1976, which is widely felt to be ineffective at protecting the public from exposure to today’s toxic chemical stew . The American Chemistry Council (ACC) strenuously objected to the Academy's recommendations for chemical policy reform while offering no alternative suggestions. [6]

Al Ruben, retired EPA official, lead developer of the 503 Rule, strongly recommends that water quality professionals (that’s us) push to have appropriate revisions made to TSCA which would put the responsibility of product stewardship in the manufacturers court.