2016: The Sludge Review:

In 2016, the Scottish Government published the review of the storage and spreading of sewage sludge on land in Scotland – known as the Sludge Review. This acknowledged that ‘stakeholder feedback indicates that there is a need for greater consistency, and greater public confidence, in the way sewage sludge is handled and used’. 21 key recommendations were made, none of which have been fully implemented.

In 2018, in response to continued complaints, the Scottish Government commissioned The James Hutton Institute, to produce an updated health risk assessment of sewage sludge. This included a consultation in which the ASCC agreed to participate, hopeful it would lead to improved regulation. The final report was in 5 parts. This report was not made public.

After more than a decade of pursuing every avenue for change, in June 2021, a freedom of information (FOI) request on 1 July 2021 to the Scottish Government to gain access to the final report. This was refused on the basis that they intended to publish the report within 12 weeks. That period passed and the report was not published. An appeal was lodged and the report was eventually disclosed on 17 October 2021. The James Hutton Institute stated that, if it wasn’t for the fact that the FOI letter had been submitted to the Scottish Government, it would have been shelved.

We are still having issues with sewage sludge spreading to this day but the Environmental Rights Centre for Scotland (ERCS) involvement has kept the issue of sewage sludge on the agenda

Once the report was made public online, the ASCC felt that it didn’t fully address public concerns regarding regulatory and enforcement failures. The report made a number of recommendations to mitigate risks to human health including odours, but none of these had been implemented.

With this information, ERCS contacted MSPs to ask parliamentary questions on both reports, including when the recommended actions would be implemented.

Following a letter to the Minister for the Environment and Land Reform, ERCS was informed that a consultation paper on the recommendations from the 2016 Sludge Review would be published by October 2022.

his was subsequently delayed to January 2023. Given this delay, in November 2022, ERCS submitted a representation to Environmental Standards Scotland regarding the failure to implement the recommendations of the Sludge Review in the hope that they would use their powers to intervene to ensure that the Scottish Government finally got the message and the necessary steps implemented addressing the significant and long-standing problems with the spreading of sewage sludge. Scotsare still waiting for action.

Sewage Sludge Spreading

07 Oct 2021: The James Hutton Institute report on the impact on human health and the environment arising from the spreading of sewage sludge on land has been completed when will it be published?

MSP question?: The smell and inconvenience generates multiple complaints, but it is the potential risk to human health that is most concerning. Can the minister confirm whether the Scottish Government has considered the risk to human and animal health of sewage sludge when it is used as a soil conditioner and advise what recent assessment it has made of the viral, heavy metal and bacterial loads in sewage sludge?

Màiri McAllan: I am aware of the concerns of constituents and of the member. The Government takes matters of human health and environmental policy very seriously. A full review of the legislation and guidance that are relevant to the storage and spreading of sludge was undertaken in 2016, and the more recent piece of work that I referred to, which will be published this month, will help us to carefully consider the situation in 2021.

The spreading of sewage sludge on land is a long-established practice and an effective way of recovering value and avoiding waste. The practice is tightly regulated by the Scottish Environment Protection Agency, but issues of odour, which I know the member’s constituents are concerned about, are the responsibility of local authorities. I assure the member that SEPA will never hesitate to take enforcement action against anyone who is not complying with the current regulations for storage and spreading. https://www.gov.scot/publications/foi-202100243526/

15 Dec 2021: Highlighting archaic arrangements for residents of West Dumbartonshire, it was revealed that until 31 December 1998, for many years, sludge boats collected residue from treated sewage at Shieldhall and the Dalmuir works, and carried it out to a deep sea dumping area between the Isles of Bute and Arran a practice banned by a European Union directive which prevented the dumping of sewage at sea because of its adverse affect on the environment.

Now it is transported in articulated lorries, nicknamed “mobile shit ships” and dumped on farmland in the Auchencarroch Hills, near Haldane in Balloch and residents are fed up to the back teeth with shit overspills and the stink from fields at times of heavy rain.

22 Dec 2021: Environment Minister, Mairi McAllan said: “Since 2010 Scottish Water has worked with Sepa to upgrade 104 wastewater treatment works and 279 storm overflows, by investing £686 million. And now they plan to go even further, investing a further half a billion pounds to improve and protect Scotland’s waste water network.

In regard to resolving litter issues pertaining to the protection of the seas marine litter is a global challenge and we are determined to play our full part in addressing it. A recently issued Government draft strategy paper included proposals for improvements and these form part of a consultation process on an updated Marine Litter Strategy, which aims to prevent litter reaching our seas and shores, remove rubbish from the marine environment, and strengthen monitoring. Abandoned fishing and aquaculture nets and gear are difficult to recycle as these are usually made of multiple materials. Adopting a circular design, with standardised materials, would make dismantling and recycling easier. This would enable re-use of valuable materials and reduce the amount of waste that could potentially end up in the water.

The draft strategy also includes measures to prevent items like wet wipes and sanitary products from entering our seas through the sewage system. Actions include improvements to sewage system infrastructure and an awareness campaign to promote behaviour change and highlight inappropriate flushing of sanitary items. To help curb plastic pellet pollution, the strategy includes the development of a certification scheme for businesses handling plastic pellets, with this work to be undertaken in collaboration with the plastics industry.

Comment from a long suffering resident:

9 Jan 2022: Once again the Scottish Government is being exposed for failing to deliver. This is a government that lives on spin delivered by a veritable army of spin doctors and press consultants. But dig, even just a little, and no matter where you look, this is a government falling down on the job. Sewage sludge used to be disposed of at sea at Garrioch Head in the Firth of Clyde. But this was stopped because surprise, surprise the sludge was polluting the marine environment. So where to now does it go. Well where better than the rural hills of Auchencarroch above Loch Lomond and the National Park. With no attempt to deliver modern environmentally sound solutions like incineration to heat disposal facilities, it is once again a case of the Scottish Government saying one thing and doing another.

And that of course is absolutely true to of dealing with plastic and recycling. For years now we’ve heard all the spin about recycling. All the millions of words, buzz words, policies et al. But look locally just at West Dunbartonshire where recycling has dropped from 44% to 36%. It may be that our SNP Council is particularly badly run, but going backwards is the utter antithesis of what is being spun at Scottish Government level.

But aside of the environment which we are clearly quite happy to trash, the thousands of tonnes of material not being recycled but instead landfilled comes at a huge cost. Between landfill tax, tip fees, and other such charges, every tonne of land-filled waste costs the Council around £160.00. Multiplying that average cost times let us say 5,000 tonnes and one gets the scale of the money being shelled out on land-filling.

Looking at things like that and WDC’s huge drop in recycling, one gets an idea of the scandal of how we deal with waste. Maybe our local representatives would like to comment but I suspect not. But yes, an interesting article. Brings to the surface, exposes the reality of how poor Scotland’s environmental protection performance really is. COPD 26 – a load of poppycock as far as Scotland is concerned.

14 Nov 2022: Sewage sludge spreading – the harm and fight for improved regulation.

Doreen Goldie and Jo Hirst, previously Chair and Treasurer of the Avonbridge and Standburn Community Council (ASCC), have been at the forefront of public action against sewage sludge for more than a decade. This is their report.

Rural communities affected by sewage sludge spreading on agricultural land continue to wait at 2023, for the Scottish Government to act on human and environmental health risks.

Sewage sludge or biosolids is a by-product of sewage and wastewater treatment. It is a source of nutrients for soil structure and its recycled use on agricultural land as fertiliser is often the preferred option over incineration or landfill in the UK and EU. However, it needs to be regulated and managed appropriately as it contains a cocktail of potentially hazardous contaminants including heavy metals, pharmaceuticals, inorganic and organic contaminants, microplastics and human and animal pathogens. Its use was banned in the Netherlands in 1995 and in Switzerland in 2005. In April 2022, Maine become the first U.S State to ban the practice of using sewage sludge because it contains the hazardous ‘forever chemical’ PFAS and contaminated farms and groundwater beyond use. In Scotland, there has been growing concern over the use of sewage sludge, the lack of regulation and enforcement, and the need for an updated review of potential environmental and human health hazards.

Communities around Scotland are facing the same issues.

Community action: Sewage sludge first became an issue in Scotland in 2009 when residents complained of excessive odours from nearby spreading. Investigation uncovered issues affecting residents since 2004, across neighbouring areas and further afield in Aberdeen, Perthshire, Stirling, Renfrewshire, East Lothian, Dumfries and Galloway and Fife. Main issues and concerns:

This is a summary of the main issues and concerns uncovered:

Breaching recommended volumes and frequency of spreading leading to potential soil contamination.

Strong odours in residential areas affecting everyday life and worsening health for people with long-term health conditions (e.g. cancer and chronic obstructive pulmonary disease).

Spreading in fields near the primary school resulting in cases of children being physically sick in the playground and their sports day being cancelled.

Spreading and stockpiling near water bodies with the potential for water pollution.

Spreading on livestock land potentially affecting animal health and development.

Poor regulation of sewage sludge transportation operators resulting in odours, spillages and hostile confrontations, intimidation, aggression and physical harm against citizens from operators spreading sewage sludge. Hence a reluctance to report issues to the relevant authorities.

An outdated 2008 assessment of potential impacts on human health from sewage sludge not considering new research and emerging hazardous contaminants.

These ongoing issues seemed to be a combination of both the Scottish Environment Protection Agency (SEPA) and the local authority not taking responsibility, not having adequate guidance or not having the capacity to take action.

Guidelines and standards need to be updated because the present reliance is on guidance from 2001. And it seems unreasonable to make SEPA the single regulatory body that’s going to be responsible for this because they don’t have the personnel and resources to regulate & enforce it.

Public bodies should be made accountable for regulating sewage sludge. This includes raising any concerns with MSPs, local authorities, SEPA and Scottish Water.