Environment

Disposal and Recycling Routes

for Sewage Sludge
Synthesis report
22 February 2002

European Commission
DG Environment – B/2

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Foreword

This report has been produced by Philippe Aubain, Alexis Gazzo, Jan Le Moux and Eric Mugnier from
ANDERSEN (Environment Risk Consulting Department), by Hubert Brunet and Benoît Landrea from
SEDE, on behalf of the European Commission.

We would like to thank the members of the Steering Committee for their guidance:

Sonia Fumagalli (DG ENV/B2), Luca Marmo (DG ENV/A2), Pierre Strosser (DG ENV/B2).

We would also like to thank the persons contacted during the course of this study, for their availability
despite their extensive professional commitments. The full list of contributors is provided in the
appendices of each sub-component report.

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Contents

1. INTRODUCTION ...................................................................................................... 4

2. SCIENTIFIC AND TECHNICAL ANALYSIS ............................................................ 6

3. REGULATORY ANALYSIS.................................................................................... 14

4. SLUDGE USE ACCEPTANCE ANALYSIS............................................................ 16

5. ECONOMIC ANALYSIS ......................................................................................... 21

6. CONCLUSION........................................................................................................ 25

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1. Introduction

1.1 Background
The Commission is thinking of revising the existing Sewage Sludge Directive (Directive
86/278/EEC). The revision will take account of the latest technical developments in waste water
treatment, of the recent research results on the effects of heavy metals on soil and soil micro-
organisms, of the risk of animal and human contamination by pathogens contained in sludge, and
of the concerns expressed by the agro-food industry and large retailers about the safety of using
sludge in agriculture and envisages an extension of the scope to non-agricultural uses.

1.2 Objectives of the study

The aim of the study is to review current scientific knowledge on the biophysical processes and
flows of substances and elements that take place within the "sludge system", and assess the
environmental and economic impact of the main disposal and recycling routes for sewage sludge.
This study aims to:

• review the scientific evidence on the migration and accumulation of substances and elements
in the "sludge system" (scientific and technical report);

• assess the adequacy of existing legislation dealing with such risks (regulatory report);

• perform an economic analysis of the main disposal and recycling routes for sludge (economic
report);

• investigate the main factors that limit the use of sludge in the different disposal and recycling
routes (sludge use acceptance report);

The study covers the fifteen Member States of the European Union and, to a large extent, the
Accession Countries.

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1.3 Intervention methodology
As described below, work consisted in two phases:

Data collection

• Data collection (studies, articles, statistics)

• Contact with key informants (Ministries, research bodies, water
operators, industries, etc.)
• Information review
è Steering Committee review

Analysis

• Technical analysis
è Steering Committee review

• Legal analysis of existing legislation

è Steering Committee review

• Identification of the main factors restricting the use of sludge in the

different disposal and recycling routes
è Steering Committee review

• Economic analysis of the main disposal and recycling routes

è Steering Committee review

• Final synthesis report and sub-component reports

We delivered four separate reports covering the four aspects of sludge recycling and disposal,
which executive summaries are presented in the following pages:

• Scientific and technical report ;

• Regulatory report;

• Sludge use acceptance report;

• Economic report.

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2. Scientific and technical analysis

Sludge composition and treatment

Sludge is composed of by-products collected at different stages of the wastewater treatment process. It
contains both compounds of agricultural value (including organic matter, nitrogen, phosphorus and
potassium, and to a lesser extent, calcium, sulphur and magnesium), and pollutants which usually
consist of heavy metals, organic pollutants and pathogens. The characteristics of sludge depend on the
original pollution load of the treated water and also on the technical characteristics of the wastewater
and sludge treatments carried out.

Sludge is usually treated before disposal or recycling in order to reduce its water content, its
fermentation propensity or the presence of pathogens. Several treatment processes exist, such as
thickening, dewatering, stabilisation and disinfection, and thermal drying. The sludge may undergo one
or several treatments.

Sludge recycling or disposal routes

Once treated, sludge can be recycled or disposed of using three main routes: recycling to agriculture
(landspreading), incineration or landfilling. Other, less developed outlets exist, such as silviculture, land
reclamation, and other developing combustion technologies including wet oxidation, pyrolysis and
gasification. Each recycling or disposal route has specific inputs, outputs and impacts.

Landspreading
Landspreading of sludge or sludge-derived material partially replaces the use of conventional fertilisers,
since it contains compounds of agricultural value. It also contains organic matter, although under a form
and at a level below that which would have a significant positive impact on soil physical properties.
Composted sludge however presents a more stable organic matter due to the addition of a vegetal co-
product during the process.

However, landspreading also involves the application of the pollutants contained in sludge to the soil.
These pollutants undergo different transformations or transfer processes. These processes include
leaching to groundwater, runoff, microbial transformation, plant uptake and volatilisation and enable
transfer of the compounds into the air and water, and their subsequent introduction into the food chain.

Therefore outputs of sludge recycling consist of yield improvement, but also of emissions of pollution
into the soil, and indirect emissions into air and water. Other emissions into the air include exhaust
gases from transportation and application vehicles.

Incineration
Incineration is a combustion reaction. Different techniques are currently performed, classified between
mono-incineration when sludge is incinerated in dedicated incineration plants, incineration with other
wastes, or co-incineration when sludge is used as fuel in energy or material production. Other
technologies are also being developed such as wet oxidation or pyrolysis.

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 Outputs are flue gases, ashes, and wastewater, as well as the production of energy. Therefore
incineration generates emissions into the air (particles, acid gases, greenhouse gases, heavy metals,
volatile organic compounds, etc.), soil (disposal of ashes and flue gas treatment residues to landfill,
atmospheric deposition of air emissions) and water (flue gas treatment wet processes). Emissions into
the air may be reduced thanks to flue gas treatment. Emissions depend on the process, but are also
influenced by the sludge type. Energy production generally counterbalances the energy needs for sludge
drying.

Operation of an incineration plant may also produce noise, dust, odour and visual pollution.

Landfilling
There are two possibilities in terms of sludge landfilling: mono-deposits, where only sludge is disposed
of, and mixed-deposits (most commonly observed), when the landfill is also used for municipal wastes.

The inputs of landfilling are the waste and additional resources required for the operation of the landfill
site, such as fuel for vehicles, electricity, and additional materials when leachate is treated on-site.
Outputs consist of leachate, landfill gas and energy production when the gas is recovered.

Landfill operation therefore generates emissions into the air (mainly greenhouse gases like methane and
carbon dioxide, reduced when biogases are collected and burnt), and into the soil and water at dumpsites
(various compounds such as ions, heavy metals, organic compounds and micro-organisms in leachate).
The operation of a landfill also generates other impacts in terms of noise and dust from the delivery
vehicles, as well as odours, land use, disturbance of vegetation and the landscape.

Other routes
Other sewage sludge recycling routes presently used in Europe include the use of sludge in forestry and
silviculture or in land reclamation.

Forestry and silviculture refer to different kinds of tree plantation and use. The term forestry is mainly
used when considering amenity forests, or mature forest exploitation. On the contrary, silviculture is
more specifically used when referring to intensive production. From the agricultural and environmental
point of view, differences exist in terms of the impact of landspreading as compared to the use of sludge
in forestry, relating to such factors as the plant species grown, the fauna and flora involved, and the soil
types.

Agronomic benefits are increased tree growth and the provision of nutrients to the soil. However,
competition with weeds, especially in young plantations may be observed. Excessive rates of sludge
application may also lead to degradation of the upper layer of the soil and the humus, as well as nitrogen
leaching to groundwater. The use of sludge in a forest environment may cause an alteration in the
characteristics of the ecosystem and, in the case of a mature forest where there is no need to have an
additional input of nutrients, may disturb the natural biotopes. More research is however needed on this
issue.

When considering the risks to humans associated with the presence of heavy metals in sludge, it is
assumed that these are lower than those associated with spreading on agricultural land, as forest
products represent only a very small part of the human diet. However, some risks may still exist due to
the transfer of heavy metals to game or edible mushroom species and in a general manner to wild fauna
and flora.

After identifying gaps in knowledge, some recommendations are given in this report concerning sludge
application in forest or tree plantations.

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 Use of sewage sludge in land reclamation and revegetation aims to restore derelict land or protect soil
from erosion through soil provision and increased vegetal covering. In the case of industrial sites,
topsoil may often be absent or if present, damaged by storage or handling. Soil or soil forming materials
on site may be deficient in nutrients and organic matter. Other problems may exist, such as toxicity, or
adverse pH levels. All these problems create a hostile environment for the development of vegetation.

Possible solutions include the use of inorganic fertilisers or imported topsoil, which can be very
expensive depending on location and availability. An alternative solution is the use of organic wastes
such as sewage sludge, which is already performed in Sweden, Finland, Germany and the United
Kingdom.

Sludge application takes place using the same machinery as in recycling to agriculture. Some specific
machinery for sludge projection may be needed when applying sludge in areas where access is difficult.

It was assumed that risks are lower than in the case of spreading on agricultural land, when its use is not
related to food production. However, no data is available concerning the potential impacts on wild fauna
and flora. Moreover, the amount of sludge applied as well as the application of sludge to sloping land to
reduce erosion go against current regulatory prescriptions for the use of sludge in agriculture, inducing
risks in terms of pollutants application.

Developing technologies
Several technologies presenting an alternative to conventional combustion processes are currently being
developed or introduced onto the market. These technologies mainly include by the wet oxidation
process, pyrolysis, and the gasification process. Other technologies may be found, which are most often
combinations of these three main processes.

These technologies present advantages in terms of flue gas and ash treatment. Moreover, they also seem
to have reduced impacts on the environment compared to conventional combustion processes.

Pollutants transfer
A review of current scientific knowledge concerning pollutants transfer mechanisms in the different
environment media and the food chain has been carried out in order to assess the possible impacts on the
environment and human health.

Each route has specific transfer processes, but transfers relating to landspreading covers most of the
significant transfers relating to the other routes, with the exception of air emissions.

Heavy metals
The presence of numerous metals in soil and sludge has been reported in the literature. Once applied to
the soil they are distributed between the different soil media. Scientific evidence shows that they
accumulate in the upper layers of the soil, due to binding to the different existing organic or mineral
particles. Their mobility and biovailability to plants and micro-organisms may be influenced by several
factors of which the pH level of the soil is the most important. Heavy metals are naturally present in soil
at varying levels, and may originate from several anthropogenic sources such as fertilisers, animal
manure, sludge, or atmospheric deposition. However, variety in the metal levels in European soils may
also be due to the diversity of the extracting methods used rather than differences in the field. In order to
ensure the quality of the comparisons, a harmonisation of the sampling and measurement methods
would be required.

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Micro-organisms species present in the soil are numerous. Some of them are important for soil fertility
and therefore for agricultural production. Concern has been expressed about the consequences of metal
provision to the soil on the micro-organisms population and biodiversity. Available scientific literature
shows contradictory results, depending on the species taken into consideration, the local conditions of
the experiments, and the confusion of short-term laboratory experiments with long-term field trials.
Some authors mentioned the ability of microbial populations to adapt to changing conditions, which
may be considered a result of negative pressure on the population. On the basis of long-term field trials,
some studies concluded that soil micro-organisms’ diversity and population could be negatively affected
by sludge-borne metals in the long-term, and by metal levels in soil which were in some cases below
current regulatory prescriptions. It must also be stressed that microbial activity indicators must not be
used as the only indicators of microbial reaction to metal application, as they do not reflect changes in
population structure.

Leaching to groundwater appears to be a negligible phenomenon. On the contrary, runoff, when it

occurs, may play a significant role in metal transfer. Its importance depends greatly on the local
situation, and the fate of metals needs to be further documented.

Plant uptake occurs for all heavy metals and is described by transfer factors. Some metals (e.g. copper
and zinc) are of biological importance for the plant. It has been observed that heavy metals are
concentrated in the roots and vegetative parts of plants and are less present in the generative parts such
as wheat grain. Uptake will increase with increasing metal levels in soil, but only applies to the
bioavailable part of the metals present in soil. However there may be no direct relation between total
metal concentration and bioavailable metals in soil. pH is the most important factor influencing metal
uptake. In particular, a decrease in the pH value in soil in the range of pH 7 to pH 4 causes an increase
in the uptake of Cd, Ni and Zn. The same effect is observed for Cu, but is less marked. Lastly, when
considering usual acidity levels in agricultural soils, a pH decrease had no observed effect on Pb and Cr
uptake. This information supports the setting of different limit values for Cd, Ni and Zn, and possibly
for Cu, for soil with pH values of between 5 and 7 as well as for soil with pH values of higher than 7.
Sludge spreading should also be avoided on soil with a pH value below 5 and limit values should refer
to the bioavailable part of metals in soil rather than to the total concentration, although it is not possible
at the moment to define for all heavy metals what is the bioavailable fraction.

Uptake of metals by animals occurs through contaminated plant consumption or soil ingestion.
However little information is available concerning metal quantities ingested and absorbed and their
subsequent toxicity levels to animals. Metals do not seem to accumulate in meat. More focus is needed
concerning possible Pb and Cd transfer to offal, as in some cases this could lead to levels nearing
acceptable limits in foodstuffs. Transfer of Pb and Cd across the placenta and into the milk was
observed during indoor feeding trials, but there are likely to be few practical consequences for finished
animals. Concentration of Cu in the milk was not influenced by the ingestion of sludge-amended soil. A
quantitative assessment of this contamination pathway is not available at the present time.

In a general manner, human exposure to heavy metals may be attributed to several sources and
depends on many factors such as diet, actual absorption, and food processing. Consumption of
contaminated crops appears to be the main means of exposure to sludge-borne metals. It is assumed that
the specific contribution of sludge-borne metals to the human diet is very low, when taking into account
the observed level of metals present in soil, and considering the surface area over which sludge
spreading takes place.

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Organic pollutants

Numerous organic compounds are present in sludge. Once applied to the land, they are distributed
throughout all soil media and undergo several retention and transport processes. They are physically,
chemically and biologically transformed in other intermediary compounds during their mineralisation,
for which no data is presently available. The degradation pathway of the organic compounds and thus
the duration before reaching negligible concentration in soils may greatly depend on the aerobic or
anaerobic degradation conditions.

Leaching of organic pollutants to ground water appears to be insignificant but, unlike metals, cannot
be neglected in some cases. The importance of this mechanism depends on the properties of the
compounds and the soil. It appears on the one hand that many compounds present short half-life values,
reducing the risk of leaching to groundwater. On the other hand, persistent compounds such as
PCDD/Fs or PCBs show an affinity with soil particles and will therefore bind to soil rather than leach to
ground water. Runoff, when it occurs, may play an important role in the transfer of organic compounds.

Even if definitive evidence is lacking, it appears that soil micro-organisms are not affected by sludge-
borne organic pollutants in most cases and that they are able to adapt to changing conditions.

Most organic pollutants are not taken up by plants. However, a risk of contamination of the food chain
exists when spreading sludge directly onto crops, especially on plants which are to be consumed raw or
semi-cooked.

Soil and sludge ingestion on land used for grazing is the main route for animal contamination.
Accumulation of bioaccumulative compounds such as PCDD/Fs, PCBs or PAHs may occur in meat and
milk. However, it is presently not possible to assess the quantities and fates of organic compounds
ingested by animals.

It appears that the consumption of animal products is the major source of human exposure to sludge-
borne organic pollutants, due to the ingestion of soil by livestock. As in the case of heavy metals, it is
assumed that the specific contribution of sludge-borne organic pollutants to the human diet is very low,
when considering the reduced proportion of the utilised agricultural area onto which sludge spreading
takes place.

Lastly, it should be noted that at the present time no universally accepted and validated analytical
method exists for analysing most organic compounds. There is also a lack of data concerning levels of
organic pollutants in European sewage sludge as no regular survey has been performed in the past.

Therefore, considering presently available knowledge on organic compounds, it appears at the present
time, that:

• transfer to water is low, micro-organisms adapt to changing conditions in soil, and numerous organic
compounds are rapidly degraded in soil. Attention should therefore mainly be given to compounds
with higher half-life time values,

• from the point of view of crop protection, no limit value seems to be necessary as transfers to plant
do not occur for most organic compounds,

• restrictions should focus on bio-accumulative compounds spread on grazing land such as PCBs and
PCDD/Fs. In this case deep injection of sludge could reduce the risk of livestock contamination by
organic pollutants,

• a survey of organic pollutant levels in sludge should be performed by sludge producers, focusing on
the specific organic pollutants identified within the waste water catchment area of the WWTP.

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Pathogens
There are five main types of pathogens observed in sludge: bacteria, viruses, fungi and yeast, parasitic
worms, and protozoa. Humans and animals are sensitive to some of these organisms, which may cause
numerous pathologies ranging from simple digestion troubles to lethal infections.

Sludge-borne pathogens are mainly present on the soil surface or at shallow depths where sludge has
been ploughed into the soil. Pathogen penetration depends on the effective depth of the soil, its texture
(particularly its clay content), its organic matter content and also on possible cracks, prolonged drought,
faults or absence of vegetation.

Survival of pathogens in soil depends on numerous direct or indirect factors. Indirect factors are climatic
factors such as sunlight, temperature, desiccation or pH, characteristics of the soil (texture, moisture
etc.), quantity of sludge spread, the pathogen content of the sludge, its organic content and the eventual
presence of competing organisms. Direct factors are related to the biological characteristics of the
pathogen, and especially to the form under which it may survive. Parasites’ eggs or cysts are the longest
survivors – one to two years in certain favourable circumstances. Depending on the conditions and the
organisms themselves, survival periods may vary from a few days to several years. The pathogenic
agent population decreases faster when the sludge is spread on the soil surface rather than when it is
ploughed into it.

Transfer to groundwater is only assumed to occur in some particular cases, while surface water
contamination is more likely to occur when runoff water transports pathogens which are bound to soil
particles.

Survival on plants is shorter than in soil, due to the effects of desiccation and sunlight.

Transmission to grazing domestic and farm animals takes place via ingestion of contaminated feed
and soil.

Humans can mainly be affected by consuming raw or semi-cooked contaminated vegetables or meat.

Therefore the risks of sewage sludge application onto the land – that may be addressed by good
practices – have to be taken into account as pathogens are present in sludge and may have significant
impacts on humans and animals. In general, deep injection or ploughing down may be recommended
during or after sludge application. Although those practices reduce the deleterious effect of weather on
micro-organisms, contact with animals, wildlife and humans as well as dissemination into the
environment will be reduced.

Sewage sludge may also contain plant pathogens, as well as weed seeds. They mainly originate from
washing of vegetable and fruit, or from road or roof runoff after aerial deposition. Plant pathogens have
in general low optimum growth temperature, so that disinfection will be achieved at a lower temperature
than for mammalian pathogens.

Pollutants transfer modelling

Based on the description of the transfer mechanisms of different sludge-borne pollutants in the
environment, a model was developed in order to assess:

• the transfer of pollutants in soil (in particular due to runoff and leaching),
• the transfer of pollutants to plants in order to make a comparison with limit values in foodstuffs,
• the accumulation of pollutants in the soil,
• the time before reaching a given limit value of pollutants in soil.

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 Only heavy metals are taken into consideration. Knowledge concerning organic pollutants does not
enable accurate calculations to be made as very little is known about their behaviour and degradation
pathways in soils (moreover, it appears that organic pollutant transfer to plants is negligible and that this
particular route should not involve a significant human health risk). It is not relevant to apply such
calculations to pathogens.

Two scenarios are examined, which represent two extreme situations of low and high
accumulation. Several assumptions were necessary in order to perform the calculation. Therefore the
results are indicative values, and are not supposed to be used neither individually, or without
indicating the hypotheses used.

The main results can be summarised as follows:

• on a one-year basis, it must be observed that pollutants brought to soil by sludge application
represent a very low proportion of the amount of metals present in soil before sludge application;

• plant uptake of sludge-borne metals may vary, but always represents a minor part of the amount of
sludge-borne metals contained in soil; in the long-term, plant uptake will increase with increasing
soil concentration ;

• runoff is the main parameter in the model influencing the heavy metal accumulation in soil ;

• global plant uptake of metals present in soil always remains below the limit values for foodstuffs.
However, in the worst case, it may reach a significant proportion of these limit values;

• on the contrary, uptake of metals originating only from sewage sludge application is very low, and
reaches, in the worse case of our modelling, 1 % of the limit value for foodstuffs ;

• an equilibrium may be reached after several years between plant uptake and sludge application,
indicating that, in some cases, a limit value for metal levels in soil would never be reached ;

• the number of years required before a limit value is reached for metal accumulation in soil would
vary greatly between the two extreme cases considered herein: figures range from around 4,500
years to over 34,000 years in the case of low accumulation, and from 20 years to around 140 years in
the high accumulation scenario.

Gaps in knowledge
Today, many uncertainties remain concerning the transfer of pollutants (especially organic pollutants) to
the environmental media and the food chain. Several issues would need to be more accurately
documented. Amongst these issues, the following may be mentioned:

• The importance of the runoff process in the pollutants’ transfer should be assessed. Mechanisms
need to be understood, as well as quantities of pollutants concerned, and their fate.

• An issue of concern is the degradation pathway of the organic compounds in soil. Compounds may
be degraded into intermediary chemicals before total mineralisation. The toxicity and leaching
potential of these metabolites is not well known. Lysimeter and field studies should be carried out.

• Long-term impacts of heavy metals and organic pollutants, in particular on soil micro-organisms and
fertility, are not well documented.

• More data is needed concerning the ingestion and absorption levels of organic compounds and, to
some extent, heavy metals by animals.

• There is also a lack of knowledge concerning the specific contribution of sewage sludge to
pollutants’ transfers.

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• A survey of the organic pollutants’ levels in sewage sludge should be performed in the Member
States in order to gain an accurate appreciation of their occurrence. This may only be possible if
standard analytical methods are set and broadly accepted.

• Available literature does not always enable a comparison between the different countries, as no
common research protocol and no trans-national study has been carried out.

• More information is also needed concerning other routes for sludge recycling, such as land
reclamation or use in forestry and silviculture. Research should be carried out to precisely identify
the agricultural benefits of sewage sludge spreading and its environmental and sanitary impacts
(especially concerning organic pollutants for which no data is currently available). Moreover,
currently available information does not enable an assessment and comparison of the benefits and
risk as regard the diversity of European forests.

• Lastly, some interesting new technologies such as wet oxidation, pyrolysis or gasification have been
developed. More information concerning their environmental impact and their application is needed.
Tests have not always been carried out on sludge, and this issue requires further documentation.

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3. Regulatory analysis
The analysis of the existing legislation related to sludge treatment, disposal and recycling carried out in
this study shows that specific legal requirements focus principally on the use of sludge in agriculture,
both at national and European level. For the moment, other uses or disposal routes for sludge generally
fall under more general laws on waste and water management.

Similarly, although several Directives have an influence on sludge management (such as Directive
1999/31/EEC on the landfill of waste), the ones which have the strongest impact on sludge production,
disposal and recycling, are Directives 91/271/EEC concerning urban waste water treatment and
86/278/EEC on the use of sludge in agriculture. In particular, requirements set by Directive 86/278/EEC
are a crucial element in the management of sludge currently produced in the Member States. One of the
aims of this study is therefore to compare these requirements with provisions adopted at national level
and to identify the main differences.

The most significant result of this survey is the fact that national regulations, which have been
established on the basis of Directive 86/278/EEC, have often introduced provisions which go beyond
the requirements of the Directive.

In particular, the limit values for concentrations of heavy metals in sludge are lower than the limit
values specified in the Directive in a majority of countries. In five countries (Belgium -Flanders-,
Denmark, Finland, the Netherlands and Sweden), the limit values for heavy metals in sludge are even
much lower. However, six Member States (Greece, Ireland, Italy, Luxembourg, Portugal and Spain)
have implemented limit values, which are identical to those specified in Annex IB of Directive
86/278/EEC.

The perspective of the revision of Directive 86/278/EEC, which could lead to the implementation of
more stringent limit values for heavy metals in sludge, could therefore have an impact in the latter
countries, at least on the provisions to be set by national regulations (average heavy metals content in
sludge is in most cases well below regulatory requirements).

In addition, the regulations on sludge use include limit values for pathogens in France, Italy and
Luxembourg and in a larger number of cases for organic compounds (Austria, Belgium –Flanders-,
Denmark, France, Germany and Sweden), both of which are not included in the Directive.

Concerning Accession countries, regulations in Estonia, Latvia, and Poland are comparable or even
more stringent than the Directive's current requirements on limit values for heavy metals. In the other
Accession countries, sludge use and disposal usually falls under more general laws on waste or on
environmental protection.

For the moment, national legislations have not introduced major changes as regards the other
requirements included in Directive 86/278/EEC on sludge use:

• concerning the type of sludge covered, the sludge regulations in Belgium, Denmark, Italy, and the
Netherlands explicitly apply both to urban sewage sludge and to industrial sludge, while in France, a
specific Order applies to industrial sludge spread on land;

• in terms of obligations for treatment, France, Ireland, Luxembourg, and Sweden permit the use of
untreated sludge under certain conditions, while Denmark, Finland, Germany, Italy, the Netherlands
and Spain have prohibited the use of untreated sludge. In other countries, there is no specific legal
requirement on this aspect;

• concerning information requirements, no major changes have been implemented in national

regulations, although Danish regulation requires analysis of organic compounds content at least once
a year. For the moment, no certification of products or services is mentioned in existing national
regulations.

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It should however be noted that the two voluntary agreements which have been signed on the use of
sludge in agriculture (Sweden in 1994 and the UK in 1998) include requirements for use of sludge in
agriculture which are more stringent than those contained in national regulations, either in terms of limit
values for pollutants in sludge or in terms of treatment requirements.

The analysis of the requirements contained in national regulations enables us to roughly classify groups
of countries by the severity of existing legislation, taking Directive 86/278/EEC as a reference. These
groups of countries are as follows:

National requirements compared to EU requirements

Much more stringent Denmark, Finland, Sweden, Netherlands

More stringent Austria, Belgium, France, Germany

(Poland)

Similar Greece, Ireland, Italy, Luxembourg, Portugal, Spain, United

Kingdom.

(Estonia, Latvia)

The review of relevant legislation reveals that very few elements in the regulations specifically address
the use of sludge in routes other than the recycling in agriculture (use in silviculture, on natural forest,
green areas, and in land reclamation). However, use of sludge on forest soil is mentioned by the
regulation on sludge use in Belgium-Flanders, Denmark, France, and Luxembourg. In addition, some
national regulations have prohibited the use of sludge on silviculture (Germany, the Netherlands) on
natural forest (Walloon region, Germany), and in green areas (Germany, the Netherlands). Significantly,
the regulation in Poland includes limit values for heavy metals concentrations in sludge for use in land
reclamation and on "non-agricultural soil".

Similarly, incineration or disposal to landfill of sludge is usually covered by general waste regulations
on incineration or on landfill and not by specific provisions in national "sludge" regulations.

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4. Sludge use acceptance analysis

The debate on sludge recycling and disposal has recently been the target of growing interest. This is due
to the fact that some concern was expressed about the potential risks of the agricultural use of sludge for
health and the environment as early as the beginning of the 1990s. Therefore, most of the debate on
sludge has focused on this route (past and present debate on disposal routes is not focused on sludge but
relates to waste in general).

The debate on the use of sludge in agriculture originated mainly in Northern Europe at the beginning of
the 1990s, before gaining in intensity from 1995 onwards. Analysing the context of this period is crucial
to understanding the various stakeholders' attitudes, motivations and constraints concerning the use of
sludge. In particular, the recent health "scares" related to GMOs (Genetically Modified Organisms),
dioxins, and BSE (Bovine Spongiform Encephalopathy, that is, "mad cow disease") have cast doubts
on the safety of the food products on the markets and on the ability of existing regulations and
controls to minimise human exposure to potential risks.

The concern expressed about food safety is also related to growing pressure on the agricultural sector,
which in certain countries is considered by consumer associations or nature protection associations as
being too focused on intensive production and not sufficiently concerned about the impact of its
activities on health and on the environment.

The above holds true for most European countries, however, certain countries are under considerable
pressure from both sewage sludge, i.e. a high rate of production per inhabitant, and from other
fertilising materials, in terms of nitrogen and phosphate content. This is one reason why the debate has
not been the same in all countries and has been most heated in the Netherlands, Flanders and
Scandinavian countries.

Analysis by country
Past and current events show that it is possible to divide countries up into the following groups:

In the Netherlands and Flanders, the debate on the use of sludge in agriculture is over, as the regulatory
requirements have prevented almost all use of sewage sludge in agriculture since 1991 in the
Netherlands and 1999 in Flanders.

In countries such as Denmark and the United Kingdom, the debate is now mostly over. In Denmark,
new regulations on the use of sludge in agriculture (Statutory Order no. 49 of January 20, 2000 on the
Application of Waste Products for Agricultural Purposes) have played a large part in ending the debate,
as they are considered sufficiently strict to reduce risks to an acceptable level. In the United Kingdom,
the debate on sludge recycling was heated until an agreement was reached in September 1998 between
Water UK, representing the 14 UK water and sewage operators, and the British Retail Consortium
(BRC), representing the major retailers. In addition, farmers' associations support the agricultural use of
sludge, both for economic and for agronomic reasons.

The cases of Germany and Sweden are special. In Sweden, a voluntary agreement was signed in 1994
between the Swedish Environmental Protection Agency (SEPA), the Swedish Federation of Farmers
(LRF) and the Swedish Water and Waste Water Association (VAV) concerning quality assurances
relating to the use of sludge in agriculture. However, in October 1999 the LRF recommended that their
members stop using sludge because of concerns about the quality of sludge. In Germany, opinion has
recently swung in favour of agricultural land spreading, mainly because this practice is considered
economically viable and it is considered that the potential risks are sufficiently reduced by the existing
legislation. However, political developments in 2001 have considerably heated the debate, which is
quite high at present as some Länder support an increase of regulatory constraints on sludge
landspreading.
16
 In Austria, France and Walloon, a national (or regional) agreement is currently under negotiation
between the different parties, and hence the debate is heated. The situation is particularly tense in France
where the farmers' unions supported, until recently, the development of the agricultural recycling of
sewage sludge, on the condition that additional quality controls and an insurance fund system were set
up. The situation has now changed, as farmers' unions (the FNSEA and CDJA) have asked for a ban on
the use of sewage sludge, officially because the current methods used are not considered to be sufficient
to address the risks related to the agricultural recycling of sludge.

In Finland and Luxembourg, the farming community is generally hostile towards the use of sludge for
land spreading, mainly because of the pressure to use animal manure for land spreading. For example,
the Finnish Union of Agricultural Producers asked for a ban on the use of sewage sludge for land
spreading in 1990, and have renewed their stand against the use of sludge in agriculture in 2001.

In Ireland and Portugal, farmers support, in some cases, the agricultural use of sludge, both for
economic and for agronomic reasons (mainly in terms of organic matter and phosphorus content),
although it is difficult to obtain information on this matter. In both countries, the use of sludge seems to
be too recent an issue to generate much public debate.

In Spain, Italy and Greece, the debate remains limited, as far as can be judged from the available
information.

This summary of the debate mostly shows that the debate is more "advanced" in Northern Europe,
but remains limited in Southern Europe. In addition, it is important to mention that the debate is
currently heated in certain countries (Austria, Walloon, France, Germany and Sweden).

A comparison with the national legal requirements also demonstrates that "tight" legal constraints
(such as very low limit values for pollutants in sludge) do not necessarily imply a greater acceptance
of the use of sludge in agriculture. The Swedish example demonstrates this best.

Finally, a major trend in the current debate on the use of sludge is clearly the increasing number of
agreements regulating the use of sludge. However, whereas voluntary agreements have proven to be
successful in the UK, they did not prevent the current crisis in Sweden. In the City of Toulouse
(France), our enquiry shows that the national agreement will possibly not allay opponents' fears related
to sanitary risks or appease all of the local opposition: the debate largely rests on political and
sociological grounds.

Analysis by stakeholder
Identifying the main positions, attitudes and constraints on the use of sludge by type of stakeholder is
difficult mainly because of the various possible attitudes within one category (see case studies in
chapter 5.9), and because of the possible differences from one country to another. However, on the basis
of the information collected in the course of this study, it is possible to give the following summary of
the main stakeholders' positions (more details on the various possible attitudes within one category of
stakeholder are set out in the body of the report):

For farmers, the main motivation for the use of sludge in agriculture is the supply of organic fertiliser
at a low cost. Their main constraints come from their customers, either food industries or retailers, who
have specific quality requirements. In a growing number of cases, these quality requirements include
restrictions on, and sometimes the prohibition of, the use of sludge in agriculture. In this context, the
main consequences for farmers associated with the use of sludge in agriculture could be a reduction in
their market share and a drop in profits, as well as additional liability costs in the event of an accident.
In this context, farmers require (in countries where the debate is heated) that a guarantee system be set
up, which would cover them against both possible risks, in order to continue using sludge.

17
Landowners are generally hostile to the agricultural use of sludge. Their attitude is based on two major
concerns: liability and land value. Landowners do not want to be held liable in the event of an accident
(harm to humans, animals and ecosystems) caused by the use of sludge and wish to prevent any loss in
the value of their land. The European Landowners' Organisation (ELO) adopted an official position
concerning sludge recycling in agriculture in January 1999, which provides safeguards for the use of
sludge. In particular, the findings of the ELO focus especially on the need to strengthen legislation, the
need to "ensure that suppliers accept liability for any economic loss or damage associated with
spreading sludge on their land", for instance by drawing up a pan-European model contract similar to
the model contract developed by the Country Landowner’s Association (CLA) in the UK.

The main influences on the agrifood industry are marketing and public health concerns. The
industry's brand image is one of its most valuable assets and its primary concern is therefore to protect
its image from being tarnished. In this sense, the industry's attitude is mainly influenced by the way in
which the general public perceives the potential risks of using sludge in agriculture. As most of the
members of this industry are sludge producers as well, professional associations of food industries are,
in most cases, officially in favour of maintaining the use of sludge in agriculture if the quality of sludge
can be guaranteed. As sludge producers, these companies are obviously seeking low-cost sludge
disposal routes.

The main motivation for food retailers is to be able to purchase agricultural products at a low cost and
to secure their market share by maintaining or improving the image of the quality and safety of their
products. In this context, as there is still a great deal of scientific debate on the potential risks of the use
of sludge in agriculture, land spreading could be perceived as a potential threat to their image. The main
concern for food retailers involves the marketing stakes regarding product quality and, therefore, the
extent to which the use of sludge may have an impact, whether real or perceived, on the quality of
agricultural products.

The main motivation for waste-water treatment companies is to maintain long-term disposal and
recycling routes for the sludge produced at the lowest possible cost. These companies are therefore
aware of the need to maintain agricultural land spreading as a major recycling route for sewage
sludge, mainly for economic reasons. In this context, these companies are willing to improve their
performance beyond that required by the regulations in order to protect the existing routes for sewage
sludge. They are also aware of the need to improve practices, and also insist on the need to introduce
national policies aimed at improving and controlling the quality of waste water entering the sewers.

The main waste management companies do not exclusively focus their business on sludge recycling.
However, the main economic driver behind their subsidiaries specialised in organic waste management
has led them to increase awareness of the importance of sludge quality control and of improving land
spreading processes. In this respect, service quality assurance could become standard practice in
Europe. In addition, waste management companies are increasingly developing the use of composted
sludge, as compost has the advantage of reducing odours and of being a commercially viable product.

Communities are in most cases seeking to maintain the existing disposal and recycling routes for
sewage sludge that are both economically viable and safe in terms of health. In addition, communities
are subject to strong pressure from their voters and are therefore concerned about limiting the "water
bill". The "NIMBY" factor is also an important element which makes a difference between acceptance
in rural and in urban communities.

In most cases, national authorities have implemented policies supporting the use of sludge in
agriculture, as it is considered to be the best economic and environmental option to deal with the
increasing quantities of sludge produced. In this context, national authorities are seeking to increase
confidence in the quality and safety of products cultivated on sludge fertilised soils.

Consumer associations and nature protection associations have both played only a minor role in
national debates on sludge recycling. Most consumer organisations involved in the debate on the use of
sludge in agriculture have been largely preoccupied with food safety. In this respect, some consumer
associations are concerned that the use of sludge in agriculture does not offer sufficient guarantees. The
limited participation of consumer associations and the general public in the debate on sludge recycling
can be explained by the lack of information made available to the public on these issues.
18
 The analysis of the stakeholders' positions shows that the main areas of consensus on sludge disposal
and recycling routes are that the growing quantities of sludge must be treated in the aims of keeping
both environmental and economic costs as low as possible. Similarly, improving practices, both
with regard to the treatment and the use of sludge, is now considered as essential. In the context of
uncertainties concerning the potential impacts on human health and the environment of the various
disposal and recycling routes, all stakeholders are calling for additional research, in order to increase
confidence in the use of sludge in agriculture.

Reducing constraints and encouraging the recycling of sludge

In order to encourage the recycling of sludge, the following should be taken into account:

The development of agricultural recycling depends largely on the possibilities to improve the quality
of the sludge itself and increase confidence in sludge quality. This implies the prevention of pollution
of the waste water at source by reducing the possibilities for heavy metals and organic compounds to
enter the waste water sewage system and improving sludge treatment as well as ensuring the
monitoring of sludge quality. These technical solutions however require major investment from the
water companies or local authorities in charge of treating the waste water. The possibility to certify the
treatment processes involved and the quality of sludge, either through independent "sewage sludge
audits" or by the certification of sludge production and treatment processes, could help to increase
confidence in sludge quality. Similarly, the quality standards of sludge recycling practices also need to
be guaranteed, especially for agricultural recycling.

One of the main issues with regard to sludge recycling in agriculture is the setting up of guarantee
funds or insurance systems in order to cover any loss of profits, damages or other costs related to the
use of sludge in agriculture. This would partially address the issue of liability, which is a vital concern
for farmers and landowners in the debate over the use of sludge. In addition to economic instruments,
legal provisions could be introduced to regulate producer liability. However, according to the City of
Düsseldorf officials, the guarantee fund was not considered as a decisive argument leading the City to
privilege the use of sludge in agriculture, and has even had negative consequences on the economic
conditions of this route.

National regulatory requirements vary greatly from one country to another. In this area, national
regulations, based on the same scientific grounds, should be considerably improved by the next
Directive on sludge use, in order to provide long-term perspectives for the use of sludge. With regard to
increasing confidence in the use of sludge, standardisation initiatives (continuation and completion of
CEN TC 308 work on the production and disposal of sewage sludge) have a major role to play.

The evolution of the debate on sludge disposal and recycling in Europe shows that the relationship
between farmers and their customers (food industry and retailers) is crucial for the acceptance of the
use of sludge in agriculture. Examples at national level show that an agreement at European level
between representatives of food industries, retailers, farmers and sludge producers could enhance
mutual confidence and information transfer. In this respect, efforts could be made to improve
communication between the major stakeholders, for example by creating "contact points" similar to the
national committees on sludge set up in several Member States.

The current state of the debate on sludge recycling and disposal routes clearly shows that the current
uncertainties over possible risks for human health and for the environment play a major part in the
resistance against expanding various sludge recycling routes. The areas where scientific results are the
most expected by the stakeholders contacted in the course of this study are possible effects of organic
pollutants and pathogens in sludge. Progress in the social and political acceptance of sludge recycling
could therefore be made by promoting research on these specific aspects, publishing the research
results and making them widely available. In particular, there should be better dissemination of the
results of current national research programmes on the effects of the agricultural recycling of sludge on
health.

19
In addition to the dissemination of research results, an important effort of communication on sludge
use should be carried out. In particular, tools such as codes of practice for the recycling of sludge
implemented on a voluntary basis should be considered. Communication should especially aim to
promote high-quality sludge (with low levels of contaminants), which could be recognised as
fertilisers (or as a component of fertiliser products) at European level. The development of labels at
European level would enable users to identify high-quality sludge and to distinguish it from other types
of sludge or waste, thus improving the image of sewage sludge itself. Therefore, labels on products
could be a useful additional tool to labels on quality assurance, for encouraging the use of sludge in
agriculture. The possibilities for providing more training opportunities to specific categories of
stakeholders (farmers, for example) should also be examined.

20
5. Economic analysis

Evaluating and comparing different disposal and recycling options for sewage sludge

Landspreading routes rank best overall, landfilling and incineration routes worst

Landspreading of solid and landspreading of semi-solid sludge entail on average the lowest cost (110-
160 €/ton of dry matter) from an overall economic point of view, i.e. accounting for both internal and
external costs and benefits.

Landfilling, mono-incineration and co-incineration of sludge with other wastes entail the highest costs
(260-350 € /on of dry matter) from an overall economic point of view.

Landspreading of composted sludge, use of sludge in land reclamation, and use of sludge in silviculture
record intermediate total costs (210-250 € /ton of dry matter).

Total costs are mainly composed of investments and operating costs of sludge treatment. However,
the quantifiable environmental impacts (external costs) can make a difference as regards routes
whose internal costs are similar.

Whatever the sludge route investigated, total costs are mainly composed of investment and operating
costs (internal costs and benefits) of infrastructure and of operations required for sludge treatment. The
internal costs of landspreading of composted sludge, use of sludge in land reclamation and use of sludge
for silviculture are among the highest.

Quantifiable environmental impacts, however, can be a factor in differentiating routes with similar
internal costs. For example, the environmental benefits associated with landspreading of composted
sludge make this route more attractive than the co-incineration of sludge with other waste, whereas their
net internal costs are similar.

Quantifiable environmental impacts (external costs and benefits) represent less than 15% of total costs.
However, many environmental impacts such as impacts on soil biology, ecosystems and some long-term
effects on human health could not be quantified. Thus, the importance of environmental costs and
benefits is in fact larger than estimated in this study.

The agronomic or farm value of sludge, assessed in terms of savings resulting from reduction in
fertiliser use, can represent between 10% and 30% of the cost of landspreading.

Farmers' interest in sludge can be increased due to treatments which enhance the fertiliser and enriching
agent content of the treated sludge, e.g. tertiary treatment of nitrogen or phosphorus, liming, or mixing
with a carbonated substance. However, such treatments lead to additional costs for sludge producers,
which therefore means they may be of less general economic interest.

21
Evaluating and comparing scenarios
Costs of compliance with new requirements in terms of:

- more stringent limit values on heavy metals in sludge

- new limit values on heavy metals in soils
- new limit values on organic compounds in sludge
- more stringent obligation of treatment
- new requirements on sludge quality assurance system
range from 0.8 billion €/year in the short term to 1.0 billion €/year in the long term for the 15
Member States of the European Union.

The best estimates of costs necessary to meet new regulatory requirements of more stringent limit
values on heavy metals in sludge, new limit values on heavy metals in soils and new limit values on
organic compounds in sludge, more stringent obligation of treatment and new requirements on sludge
quality insurance systems amount to 0.8 billion €/year in the short term, 0.9 billion €/year in the
medium term (after 2015) and 1,0 billion €/year in the long term (after 2025) for the 15 Member States
of the European Union.

The analysis shows that the “worst-case scenario”, where no sludge is able to meet new regulatory
requirements without an efficient pollution prevention policy, leads to costs as high as 1.2 billion €/year
for the 15 Member States of the European Union.

The share of the costs between Member States is approximately proportional to the relative quantities of
sludge produced in each Member State.

Estimated percentages of sludge failing to comply with new requirements on heavy metals and
organic compounds are high if no pollution prevention policy is implemented.

According to our estimates, 67% of sludge in the short term, and 83% in the long term, fails to comply
with limit values on heavy metals or organic compounds in sludge or in soil, if no pollution prevention
policy is implemented.

If an efficient pollution prevention policy is implemented, then this percentage could drop down to 25%
(minimum due to proposed limit values on heavy metals in soil).

The integration of a Pollution Prevention Policy into the policy package leads to similar overall costs.

The integration of the necessary pollution prevention measures to minimise the diverting of sludge from
recycling, the so-called called the Pollution Prevention Policy scenario, leads to a very limited increase
(less than 15%) in the overall costs of the policy.

However, the evaluation of the costs of the measures required for the Pollution Prevention Policy
scenario is difficult. As the costs used in the present study have been obtained from a single study
(carried out in a United Kingdom context), cost estimates of such measures remain to be confirmed and
further analysed.

However, the Pollution Prevention Policy changes the allocation of the costs among stakeholders: the
Pollution Prevention Policy scenario shifts majority of the cost-burden from the local authorities,
farmers and citizens to the industry.

While the cost of an efficient pollution prevention policy is mostly borne by industries (around 60% for
the medium term estimates), the local authorities (20%) and water companies (8%), the cost without
such a policy is borne mainly by local authorities (up to 60%, for the cost of switching from
landspreading to incineration), farmers (up to 20%, for the loss of compounds of agricultural value) and
citizens (up to 16%, for environmental and health impacts).

22
 This change in the cost-burden, however, should not mask the fact that costs allocated to local
authorities and water operators (costs of switching from landspreading to incineration and up to 70% of
the costs of a quality insurance scheme) are ultimately borne by water consumers.

Sludge management costs remain low compared to the overall water management costs but must be
kept to a minimum

Sludge management costs remain relatively marginal when compared to the overall costs of managing
water and urban wastewater: internal costs of managing sewage sludge represent, on average for the 15
Member States, less than 6% of the total costs of water service (production, delivering and treatment).

However, consumer sensitivity to increases in water prices resulting from the significant increase in
prices during the past decade may impose constraints on ensuring sludge treatment costs are kept to a
minimum.

Compliance costs for industrial sludge should be lower than those for urban sludge.

Whatever the scenario, costs of compliance with regulatory requirements that would also apply to
industrial sludge should be lower than those for urban sludge. This is mainly due to the lower estimated
production and better sludge quality.

Costs are estimated to range from 0,1 billion €/year in the short term to 0.2 billion €/year in the long
term.

Compliance costs in Accession Countries should be much lower than those borne by Member States.

Costs of compliance with new regulatory requirements in ten European Union Accession Countries, i.e.
Bulgaria, Czech Republic, Estonia, Hungary, Latvia, Lithuania, Poland, Romania, Slovakia, Slovenia,
should be significantly lower than those borne by the Member States. This is mainly due to the lower
quantities of sewage sludge currently produced and recycled in these countries, forecast to be much
lower than the quantities recycled in the Member States.

Sensitivity, uncertainties and limitations of the study results

The estimation of costs associated with the various scenarios are very sensitive to forecasts of
quantities of sludge recycled, quantities of sludge not meeting new regulatory requirements and
pollution prevention costs.

The most sensitive factors for the analysis of scenarios are the forecasts of the quantities of sludge
recycled, the quantities of sludge not meeting new regulatory requirements and, for the Pollution
Prevention Policy scenario, the costs of pollution prevention measures. Any variation in one of these
factors leads to an almost proportional variation in the total costs of any scenario.

Sensitivity is relatively lower for other factors such as unit costs of switching from landspreading to
incineration, quality assurance costs, sludge treatment obligations, nutrient concentration in sludge, and
external cost coefficients.

Impacts of uncertainties on cost estimates for the scenarios are very high.

Uncertainties regarding basic factors are very high overall. Thus, overall uncertainties for estimates of
costs associated with scenarios are high. Clearly, the results obtained in the present study are to be used
very cautiously and remain indicative only.

Uncertainties that have the strongest impacts on the study results are the quantities of sludge not
meeting new regulatory requirements and pollution prevention management and costs. Other
uncertainties that were identified should have a more limited impact on the total costs estimated for the
different scenarios.

23
 Evaluation of environmental and social costs is limited to airborne emissions and may underestimate
the external costs and benefits.

Quantifiable environmental and social costs were limited to airborne emissions. Thus, the impacts on
other natural environments (water and soil) have not been quantified.

As described in the scientific and technical report and in the social acceptance report, other
environmental effects or social issues may have significant impacts on the comparison of routes and
scenarios. In particular, the lack of knowledge on how to economically quantify the impacts on soil
biology or the ecosystems, exposure to pollutants and their long-term effects on public health leads to a
limitation of the evaluation of external costs.

Moreover, the social costs and benefits such as unpleasant odours, the fears associated with the
perception of environmental or health risks, the acceptance of sludge by the farming world or by the
food industry etc, are key factors to be considered in assessing the overall impact and costs of disposal
and recycling options and scenario. These factors have however, not been quantified.

Improving the economic analysis of sludge disposal and recycling: ideas for the way
forward
Improving the information base is necessary to increase the certainty of cost estimates

To reduce uncertainties and improve the reliability of results, information is required on:

• Sludge composition : a more precise evaluation of the percentage breakdown of sludge not meeting
requirements would require a precise and updated percentage breakdown of pollutants (heavy metals
and organic compounds) in the quantities of sludge produced for all 15 Member States.

• From general categories of sludge disposal and recycling routes to detailed databases with
sludge quality, routes and treatments : more reliable results can be obtained if the database
containing the details of sludge quality (percentage breakdown) were to include the type of treatment
(conventional, advanced etc) and a detailed allocation of sludge to different disposal and recycling
routes. The description of detailed categories of disposal and recycling routes should be standardised
among Member States.

• Defining Pollution Prevention Policy measures and cost : to obtain more reliable results on the
impact of Pollution Prevention Policy measures on the costs for scenarios, more analysis is required
to better define the types of measures required for such Policy Prevention Policy in the various
Member States. Also, better estimates of the costs associated with these measures are required.

• Quantifying unknown external costs: human health, ecosystem degradation etc. : to make a
better evaluation of external costs, it would be necessary to improve knowledge on the economical
quantification of impacts on soil biology, ecosystems, the exposure to pollutants and long-term
effects on health (see chapter on "gaps in knowledge" in the scientific and technical report).

Information databases should also be developed for industrial sludge and for Accession
Countries to the European Union

At the present time, even less information is available on industrial sludge and the situation in
Accession Countries than on urban sludge in Member States: for instance, basic information such as
sludge quantities and routes are not known. Therefore, more precise and reliable information should be
gathered on industrial sludge in Accession Countries in order to allow a comprehensive cost and
benefits analysis.

24
6. Conclusion

Agricultural recycling makes both economic and environmental sense, provided the migration and
accumulation of substances and elements contained in sludge into the environment and the food chain,
and the associated risks are reduced and addressed by adequate regulatory measures and good practices.

The development of agricultural recycling depends largely on the possibilities to improve the quality
of the sludge itself and increase confidence in sludge quality.

This implies the prevention of pollution of the waste water at source by reducing the possibilities for
heavy metals and organic compounds to enter the waste water sewage system and improving sludge
treatment as well as ensuring the monitoring of sludge quality. These technical solutions will require
major investment both from the water companies and local authorities in charge of treating the waste
water, although these costs will remain low when compared to the overall costs of managing water and
urban wastewater

The current uncertainties over possible risks for human health and for the environment plays a major
part in the resistance against expanding various sludge recycling routes: many uncertainties remain
concerning the transfer of pollutants (especially organic pollutants) to the environmental media and the
food chain, and the possible effects of organic pollutants and pathogens in sludge. These issues would
need to be more accurately documented.

Progress in the social and political acceptance of sludge recycling could therefore be made by
promoting research on these specific aspects, publishing the research results and making them widely
available. In particular, there should be better dissemination of the results of current national research
programmes on the effects of the agricultural recycling of sludge on health.

In parallel, information is required on sludge composition, sludge production, treatments and routes,
pollution prevention policy measures and cost, external costs (such as human health, ecosystem
degradation etc.) to reduce uncertainties and improve the reliability of cost estimates.

25