How Environmental Regulations Are Diminishing Public Health Concerns.
By : Peter Maier, PhD, PE and edited by John M. Ackerman, MD.
To understand present environmental regulations, one should first know some of the historical background.
Prior to the nineteenth century, drinking water was obtained primarily from wells, it looked clear and hence was thought clean enough to drink. Since most communities were settled along open waters, liquid waste was simple discharged via storm drains into open waters. Prior to the 19th century, human waste was separately collected and used by local farmers. The streets were utilized to dispose waste from markets and houses. To keep the streets clean, cities built sewers to deal with storm water. When in house plumbing was introduced, it was also connected to the storm sewers (presently called “combined sewer systems”) taking care of both sanitary sewage and stormwater.
When wells could not provide enough, surface water was also utilized for drinking vis-a-vis sand filtration to remove visible solids. Later, chlorine was thought to eliminate most bacteria. Communities not conveniently located along open waters (where the sewage nuisance problems could not be solved with cesspools or septic tanks) had to be solved via sewage treatment plants to prevent nuisances (such as odors). By the turn of the nineteenth century, separate treatment processes for both drinking water treatment and sewage were established.
Concerns about water pollution caused by the discharge of sewage into open waters began around 1910 in England (when Londoners noticed that salmon no longer ran the Thames River). This led to an investigation. Already aware of the fact that sewage was a food source for bacteria, the classical Streeter and Phelps formula was utilized to predict the “oxygen sag” in the river in order to calculate how long it would take the river to “self purify” (when the dissolved oxygen concentration was equal to what it was previously).
The formula, however, required the value of the then developed BOD (Biochemical Oxygen Demand) test basically determining (in a laboratory) how much oxygen the bacteria would use to consume the waste in sewage. Acknowledging the fact that heterotrophic bacteria were simultaneously using carbonaceous (fecal) waste and autotrophic bacteria using the nitrogenous (urine and part of protein) waste acknowledged two different biochemical oxygen demands.
The above documentation was entered into the technical literature. However, the two World Wars and the depression probably halted any further interest and investigation regarding the impact of sewage in open water. Although there were some analytical test procedures developed during that period, most accomplishments by sewage treatment plants were solely evaluated how well they controlled odors. After WWII, while local communities began operating treatment plants for both drinking water and sewage, their separate designs relied on the services of consulting engineers in order to build the facilities. However, at that time, the knowledge how to treat sewage was limited. Ten States (in 1947) established standards for both sewers and sewage treatment based on empirical design parameters developed around the turn of the century. The so called “Ten State Standards” introduced a few analytical test procedures including the BOD5 test (now commonly used internationally). Unfortunately, it became common place to only use the 5-day value instead of the entire test (which took 30 days). It was assumed that the 5-day value reflected all of the oxygen required to break down 100 percent of the organic matter. In so doing, it not only ignored 60% of the total oxygen exertion of a receiving river, but also ignored all of the nitrogenous waste (urine and protein) in sewage.
The latter, in addition to ignoring its oxygen exertion, was also a fertilizer for algae (presently labelled a nutrient). Around 1960, finally considering the impact to Public Health, all of the State Health Departments began to initiate both drinking water and sewage Regulations. The Regulations for drinking water did not differ much between States. However, water pollution Regulations varied creating “clean” and “dirty”designations. Subsequently this encouraged “industries” to migrate from clean to dirty states in order to avoid stricter, more expensive wastewater treatment requirements. However, when States started to lose their employment (tax base), politicians became involved and pressure was then exerted on the Federal government to assume more responsibility for the environment. In that same period, the general public became more aware of pollution because air and water pollution was not restrained by state boundaries. There began a push for more Federal involvement.
The Federal EPA was created in 1970 to consolidate services supplied by different Federal agencies. Congress passed The Clean Air Act in 1970 and subsequently The Clean Water Act in 1972 (controlled and directed by EPA in Washington to be implemented by State Health Departments). This was probably the first step towards an increased focus on the environment instead of Public Health. In the eighties, States formed their own Environmental Quality Departments and the active influence by State Health Departments was increasingly diminished.
As the culture in the US focussed more on money, instant gratification, short term gains plus dependency on specialized services and technology, it is not surprising that a similar attitude also prevailed within State governments (slowly resuming emphasis on environment instead of Public Health priorities). Air pollution is now focussed on global warming while its simultaneous damaging impact on the Public Health of individuals is hardly considered. Many physicians (especially living with weather inversions) are expressing their frustrations with the lack of Air Pollution Regulations protecting their Public Health.
Since sewage is not yet medically associated as a potential threat to Public Health, State and Municipal Health Departmental Regulations lack any such Standards (except once when the Federal EPA initially implemented the CWA of 1972 setting limits for E-Coli never previously existing). To meet such new challenges, most sewage treatment plants installed chlorination equipment without realizing that chlorine reacts with organic matter forming halogens which can be carcinogenic as well as endocrine disrupters. However, EPA (in 1978) dropped the Federal requirement on the advice of both GAO (General Accounting Office) and the CDC because such practice did not prevent waterborne diseases, was expensive, and did harm to the environment. Having dropped this federal requirement, EPA left it up to the individual states to either drop or maintain the requirement. Proving how difficult it is to make changes (even after bad regulations were acknowledged), most States maintained the requirements. Now, 30 years later, the harmful results of chlorination are finally acknowledged. However, instead of simply admitting having made this mistake, chlorination equipment now is replaced (at high cost to the public) with UV disinfection while its effectiveness (especially in killing bacteria in effluents of sewage treatment plants) is doubtful because it depends on the clarity of the effluent (not always the case).
Other problematic areas dealt with the disposal of excess sewage sludge (also called biosolids). In the seventies, EPA subsidized 75 percent of the cost of new or modified sewage treatment plants. Many cities designed facilities for much larger capacities and offered this excess capacity to treat industrial wastewater. The question remains, [if this industrial wastewater is indeed treated (or very diluted)] is it released with effluents into open waters or is it removed and ends up in the biosolids. Approximately, 60 percent of biosolids (which are also contaminated with multi-antibiotic resistant bacteria and their multi-antibiotic resistant genes) are still disposed onto open agricultural lands?
The fact that EPA (in 1983) officially acknowledged the problems regarding the utilization of the 5-day BOD test value (without correcting the test) is another example of resistance to correcting errors even when we still cannot properly evaluate: 1.) how sewage is treated and 2.) what the effluent waste load creates. It is also a strong possibility that multi-million dollar sewage treatment facilities are designed to treat the wrong aspects of the sewage waste by assuming that raw sewage is carbonaceous (whereas, in fact, it is mostly nitrogenous). Nobody seems to care that our open waters are still being utilized as urinals.
The lack of openness and reluctance to discuss what is described above is amazing regarding the many engineering scientific errors and problems in the area of sewage treatment. More recently, because of a lack of fresh water (especially in California), a solution is being considered to utilize treated sewage for both irrigation and recharge of groundwater for drinking. Such additional uses of treated sewage are contemplated without scientifically knowing if such will continue to facilitate our excellent Public Health. Multiple professional published references regarding the PPCP’s (Pharmaceutical and Personal Care Products) as well as antibiotic resistant bacteria and their antibiotic resistant genes in all our waterways are raising serious scientific concerns. Hopefully, science and the public will educate and persuade authorities to continue the importance of the Public Health aspects of the Environmental Regulations.