FIWA feedback to the roadmap on the evaluation of the Sewage Sludge Directive

FIWA welcomes the initiative of the EC to evaluate the Sewage Sludge Directive (SSD). Finnish Water Utilities Association (FIWA) is the co-operation and member association of the Finnish water and wastewater utilities. FIWA's membership includes about 300 Finnish water utilities which cover about 90 % of water services in Finland.

We need different opportunities for sewage sludge utilization

Sewage sludge is a valuable source of organic matter and nutrients. The use of organic fertilizers, such as sewage sludge, improves the physical structure of the soil, providing greater porosity, structural stability, water retention capacity and ion exchange.

In Finland sewage sludge is processed and utilized as an organic fertilizer. About 80 % of sewage sludge is digested and 60 % composted. About half of the biosolids is utilized in green areas and approximately 40 % in agriculture. Only a small fraction of sewage sludge is incinerated at the moment. Simultaneously various development projects are ongoing and looking for new options for sewage sludge treatment and nutrient recovery.

FIWA would like to see a clear supportive legislative environment in order to secure the different possibilities we currently have to manage sewage sludge as well as to encourage the use of new solutions.

Coherence with other policies

With respect to sludge, there are indirect ways of protecting the quality of sludge through the EU’s REACH legislation. However, there is no clear line of sight between the protection of sludge quality and source control legislation. This is a major gap which should be closed, given the direction on circular economy and the range of reuses for sludge.

Sewage sludge is legislated both trough waste legislation and SSD. It has been interpreted that even when sludge is processed and becomes an organic fertilizer (or biosolids) waste status still exists. This is not supportive and the situation will become even more imbalanced in the future when other organic fertilizers can reach the product status based on fertilizer regulation. We urge that this situation will be analysed in the evaluation of SSD and subsequently paths for organic sewage sludge fertilizer products will be created taking into account possible modification needs in the REACH regulation.

Co-treatment of different organic materials by digesting or composting is often a locally sustainable solution. Legislation should not hinder but encourage co-treatment. SSD evaluation should recognise that co-treatment is a common practice and legislative coherence should be studied also from this perspective. 

Several new technologies for sewage sludge treatment and nutrient recovery are being developed. As these technologies become mature an appropriate legislative framework and a market is needed for further introduction. 

External study

SSD evaluation will be supported by an external study. FIWA wants to point out that many of the mentioned information sources are made for other purposes and thus answer only partly to the questions that are relevant in the context of SSD evaluation. The roadmap indicates that the issue of pollutants is a key matter. FIWA has analysed the report ”Digestate and compost as fertilisers: Risk assessment and risk management options” and many shortcomings were found. Various information related for harmful substances as well as national risk assessments are available. Since pollutants are considered important, external study should use wider selection of sources related to this matter.

To better control sludge management and its quality, risk assessments and risk management techniques are used, based on national legislation and voluntary quality assurance systems

When comparing different treatment solutions and utilization alternatives, attention should be given to the emissions, costs and soundness. 

VVY:n  lausunto on toimitettu Euroopan komission verkkosivustolle. Sivustolta löytyy muidenkin tahojen antamat kommentit. Voit tutustua lausuntoihin tästä linkistä Feedback received on: Sewage sludge use in farming – evaluation: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12328-Evaluation-of-the-Sewage-Sludge-Directive-86-278-EEC/feedback?p_id=8009680&page=2