Addressing Microconstituents by Product Stewardship
By Ned Beecher
As noted in related articles, microconstituents in biosolids continues to be a hot topic of research. That research is critical. But....
But, as with concerns about other trace contaminants in biosolids, the question is, “What else can be done to address the concern?” When it came to addressing metals in biosolids, once research had begun to identify those that showed up in biosolids at concentrations that had potential significant impacts, industrial pretreatment and pollution prevention programs were strengthened. For microconstituents, which are largely derived from households, a similar solution is “product stewardship.”
According to the Product Stewardship Institute (PSI), “"product stewardship" is a principle that directs all participants involved in the life cycle of a product to take shared responsibility for the impacts to human health and the natural environment that result from the production, use, and end-of-life management of the product. The greater the ability of a party to influence the life cycle impacts of a product, the greater the degree of that party’s responsibility. The stakeholders typically include manufacturers, retailers, consumers, and government officials.
“The product stewardship approach provides incentives to manufacturers to consider the entire life-cycle impacts of a product and its packaging - energy and materials consumption, air and water emissions, the amount of toxics in the product, worker safety, and waste disposal - in product design, and to take increasing responsibility for the end-of-life management of the products they produce.”
Wastewater and biosolids managers are key stakeholders in the life cycle of numerous pharmaceuticals and personal care products (PPCPs) and other microconstituents that are found in effluent and biosolids. Like all managers of waste, our local, publicly-funded infrastructure is burdened with materials that, because of their potential toxicity, may require costly end-of-pipe treatment. In many cases, it may be more cost-efficient for society as a whole to reduce the need for the end-of-pipe solution by working upstream to reduce the use of chemicals that have been shown to be persistent and cause environmental or public health impacts. This is why produce stewardship is of interest.
In mid-July, I attended the 6th PSI forum at the urging of the NEBRA Board of Directors. PSI is a national non-profit environmental institute with membership from 46 states and over 170 local governments, and partnerships with more than 55 businesses, organizations, universities, and non-US governments. PSI creates opportunities for all those involved in the product lifecycle to share information, discuss areas of agreement and disagreement, identify collaborative research needs, and develop product stewardship solutions together.
PSI has been instrumental in supporting the passage of product stewardship laws in several states, such as mercury thermostat collection programs in several New England states. Maine has a used pharmaceutical collection program and just passed a framework product stewardship law that provides a formal annual process for the state to propose and adopt additional programs for managing – and requiring manufacturers to fund – product collection and recycling programs.
For the recycling to soils of organic residuals to become ever more sustainable, microconstituents that are found to have impacts may need to be reduced or redesigned. Research is showing that most microconstituents break down either in the wastewater or biosolids treatment processes or in the soil after land application. But some are persistent. However, the significance of their presence is generally not yet known. Since there are several routes by which trace chemicals can enter the environment, the most effective way to reduce potential impacts may be to reduce use or reformulate the substances to ensure rapid decomposition.
As a result of attending the PSI forum, I am hoping that NEBRA and other wastewater and biosolids organizations will be involved in discussions in Maine and possibly other states regarding PPCPs and other microconstituents. Already, the NEBRA Board has recommended that the widespread use of the anti-microbials triclosan and triclocarban in consumer soaps and other products be re-evaluated. NEBRA’s interest is to protect the quality of biosolids products, to ensure the sustainability of their use as soil amendments and fertilizers. We have an important message that no one else will bring to the product stewardship discussions: some (but not all) microconstituents in wastewater may affect our ability to recycle reclaimed water and biosolids. The producers of those chemicals and other stakeholders need to be aware of their impacts on our programs and help take responsibility for their life cycle costs.