[USCC] Composted biosolids vs biosolids under 503

[dmhill@aol.com]

 Rufus and all,

I wonder if some of the confusion may stem from the difference between federal and state regulations coupled with the state's responsibility for oversight and enforcement of both sets of regulations?? A state may be more restrictive than the federal regulations (CFR 40, Part 503) but the state may not be less restrictive than federal regulations. 

As an example, the Maryland Department of Environment (MDE) states emphatically that any product derived form sludge (MDE does not acknowledge the word "biosolids" nor allow it in documentation) "is sludge and will always be sludge". Furthermore. any product (i.e., topsoil) containing "so much as one molecule of sludge will be regulated by the laws governing the use and management of sludge".

Again, the above are Maryland's regulations based on interpretation and further restriction of the 503 regs. Additionally, these laws (statutes) change from state to state and biosolids and/or Class A compost derived from EQ biosolids must also meet the requirements for the state in which it is or will be permitted for distribution.

David Hill
Bethesda, MD


-----Original Message-----
From: Chaney, Rufus <Rufus.Chaney at ARS.USDA.GOV>
To: Compost Discussion List <compost at mailman.cloudnet.com>
Sent: Wed, 28 May 2008 9:48 am
Subject: [USCC] Composted biosolids vs biosolids under 503










Dear Composters:

At the request of several participants, I contacted EPA officials (Rick
Stevens, Bob Bastian, Jim Smith) who manage the biosolids regulatory
program to obtain a clear statement on the questions raised about
whether a proper biosolids compost was still biosolids.

The bottom line: If a biosolids meets the APL requirements, has
undergone a Class A pathogen reduction treatment and a vector reduction
treatment complying with the rule, it no longer has any of the
management or other requirements of the 503 Rule. It is no longer
biosolids, but a commercial product derived from biosolids. There are no
Federal label requirements for these so called EQ biosolids products.
And surely a properly made compost which included APL biosolids as a
feedstock would comply with the EQ designation in all regards.

Some states have additional requirements that are not part of the
Federal 503 Rule, so check with your state rule to be sure what is
required at your location.

States also provide guidance for use of such products, and enough
information should be provided users that they can use fertilizer or
soil conditioner rates that are appropriate for use of the product.

Rufus Chaney
Beltsville, MD
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