Massachusetts is Facing a
Wastewater Biosolids Reuse and Disposal Crisis

Biosolids are a necessary by-product of the wastewater treatment process. When recycled, they are a valuable soil fertilizer used for agriculture and land restoration. However, due to concerns about PFAS contamination, Massachusetts is expected to further regulate biosolids management. MassDEP is under pressure from advocacy groups and legislators to ban land application of biosolids altogether. Such a move would severely limit options for reuse and disposal, with landfill space and incineration facilities already near capacity. Based on the MassDEP PFAS and Residuals Technology Management Study, Part 1, an estimated 55% of biosolids produced in Massachusetts were already managed out of state in 2023.  

A ban on land application in Massachusetts would:

  • Raise wastewater treatment costs 

  • Impose higher costs for ratepayers to fund the transportation of biosolids to locations further away in the Midwest and Canada 

  • Increase greenhouse gases transporting biosolids to other states or countries 

  • Eliminate a reliable and valuable soil amendment and fertilizer 

The Coalition recently published a Biosolids position paper outlining seven recommended strategies the State may take to avert this potential crisis and build upon the work already being undertaken by MassDEP through its PFAS and Residuals Technology Management Study. The position paper was presented to MassDEP during a site visit at Greater Lawrence Sanitary District’s Organics to Energy project in December 2024. 

Our recommendations include:

  1. Focus legislative and regulatory efforts on PFAS source control that would A) reduce or eliminate the use of PFAS in the manufacture of products; B) eliminate the importation of PFAS-containing products; C) create take-back programs for older products containing PFAS.

  2. Adopt a PFAS concentration-based approach with consideration of exposure risk for determining the best option(s) for reuse or disposal of wastewater biosolids.

  3. Maintain current reuse or disposal options until a master plan is developed and viable alternatives identified.

  4. Adopt a state policy to sustainably manage and dispose of biosolids produced in Massachusetts within the Commonwealth.

  5. Support research on biosolids treatment for PFAS, alternative biosolids disposal technologies, and fate and transport of PFAS in biosolids.

  6. Incentivize the construction of regional biosolids management facilities within the Commonwealth including digestors, incinerators and suitable land application locations.

  7. Provide financial assistance to publicly owned wastewater treatment facilities to help offset the operational and capital costs of biosolids management.

MCWRS Advocacy

During the last Massachusetts Legislative session, which ended December 31, 2024…

Senate Bill 2053 was filed. That legislation would have placed a moratorium on new biosolids incinerators, further limiting the ways in which utilities can dispose of biosolids. While Senate Bill 2053 did not pass, similar legislation could be introduced during the new legislative session in 2025. The PFAS Omnibus Bill was also filed last session but did not pass. That bill included useful language to control the use of PFAS in manufacturing and products but also contained troubling requirements to have MassDEP phase out the land application of biosolids in the Commonwealth. The PFAS Omnibus bill was supported by many legislators and will certainly be re-filed in some form in 2025. MCWRS provided testimony on the 2024 bill and will be offering its insights on any new biosolids-related bill filed in 2025. 

The future of biosolids management in Massachusetts, and across the nation, will have major implications for wastewater treatment systems and costs passed on to sewer ratepayers. MCWRS will continue to advocate for sound science and a balanced, reasonable regulatory approach to dealing with PFAS in biosolids and wastewater.   

Such advocacy was just made more challenging by EPA’s January 2025 release of a draft risk assessment report for PFAS in biosolids.  While under review at this time, that risk assessment suggests that any amount of PFOS or PFOA in land-applied biosolids carries a health risk. It also suggests health risks associated with incineration and landfilling of these particular PFAS compounds. The risk assessment was geared toward health risks for those handling biosolids and those living near land-application sites (i.e., farms) and not the general public. Unfortunately, the media generally ignored this limiting aspect of the study and the fact that the “findings” were all model based and not the result of actual field testing or data collection.  EPA is accepting comments on the risk assessment until March 17, 2025. MCWRS will be closely scrutinizing the report and offering its thoughts through comments. 

In September 2020, MCWRS hosted a webinar discussing PFAS in biosolids in more depth. Members can access a recording of this webinar free of charge by contacting us at info@mcwrs.org.  

Our 2024 Symposium featured a panel on the future of biosolids disposal, and a presentation on the joint efforts of the Springfield Water & Sewer Commission, Upper Blackstone Clean Water, and Narragansett Bay Commission to investigate the potential for a multi-state, regional solution for wastewater biosolids disposal.

Frequently Asked Questions

  • Wastewater biosolids (sewage sludge) are an inevitable by-product of modern wastewater treatment. Flushing the toilet and washing the dishes or laundry are everyday activities that contribute to biosolids being collected at a wastewater treatment facility. Commercial and industrial sewer discharges can also add to biosolids. If your home is not connected to a sewer, when you have your septic tank pumped, the collected septage is hauled to a wastewater treatment facility for processing and also brings in more biosolids.  

    Wastewater treatment plants clean the water they receive and collect the residual solids that are left behind. These solids are rich in organic matter and nutrients.  

    Biosolids must be disposed of in some way. One of the most environmentally friendly options is to reuse biosolids as fertilizers. Typically, farmers use biosolid fertilizers for hay and other crops, replacing man-made fertilizers that require a massive environmental impact to create. Biosolids are strictly regulated by federal and state rules and only those meeting established standards can be land applied.  

    Alternatively, biosolids can be disposed of through landfills or incineration. 

  • Recent advances in laboratory analysis have revealed that Per- and Polyfluoroalkyl Substances (PFAS) are present at trace levels in biosolids. There is concern PFAS in biosolids could make its way into crops, livestock feed and groundwater and then into people via food or drinking water.  Some PFAS compounds have been associated with possible health effects. 

    PFAS, also known as Forever Chemicals, are manmade chemicals produced by companies like 3M and DuPont. These chemicals have many uses and most notably are water, grease and heat resistant. Some common uses include firefighting foam, fabric waterproofing, stain resistant carpets and upholstery, non-stick cooking pans, cleaning materials, fast-food wrappers, makeup and even toilet paper.  

    The prevalence of PFAS in everyday items has resulted in wastewater treatment plants receiving most of their PFAS contamination from households. Some industrial uses may also contribute higher levels of PFAS but the baseline contamination in wastewater appears to be from domestic use. 

  • Wastewater treatment processes do not destroy PFAS, so some of these chemicals can end up in biosolids or may be discharged to receiving waters.  The first and most effective way to eliminate PFAS is source control to keep these chemicals out of everyday products. PFAS are specifically made and used by manufacturing companies. The intentional addition of PFAS to products can be curtailed through voluntary, regulatory and legislative efforts. Until source control is achieved, there will continue to be PFAS in wastewater.   

    Additionally, more research on which products contain PFAS and the health risks posed by these products is critical. While there is evidence that high concentrations of some PFAS compounds pose a health risk if ingested over many years, there remain many questions about the risk posed by very low levels and the health concerns associated with most of the thousands of different PFAS chemicals. The mere presence of PFAS in products or the environment (air, water and soil) does not mean there is a risk of harm to health or wildlife. The ability to detect PFAS at single digit part per trillion levels assures that PFAS will be found in many types of media but does little to inform the public of the risk posed.    

    In the fall of 2024 the MCWRS Board of Directors, in conjunction with Coalition members, developed a position paper to address biosolids reuse and disposal with a recommended path forward that is responsible, sustainable, and effective. 

MCWRS Board Members meet with MassDEP at Greater Lawrence Sanitary District in December 2024

Resources