The Australian Government has released the draft PFAS National Environmental Management Plan Version 3.0 for comment. Have your say here This consultation has now closed. See combined submission here
Be warned, the documents are very technical but if you are reading this website you are becoming informed on PFAS toxicity, movement through the environment and how PFAS exposures occur via the food chain.
To assist with an understanding of biosolids in relation to the NEMP 3 would benefit by viewing an excellent blog by Anthony Amis - PFAS Pollution of Food Growing Areas to Continue Under National Environment Management Plan

Biosolids and what is claimed

For centuries farmers have used animal manures with great success to improve soil fertility on their land.
But using sewerage sludge from municipal wastewater treatment plants as a fertilizer is a whole other issue. Certainly has valuable nutrients and organic matter in a similar way but that is where the similarity ends. Biosolids are an exceptional source of phosphorous much needed for food growth. While recycling is part of Victoria's circular economy policy on organic waste eco-cycle, dangerous substances are not and that is the problem.
Biosolids are not raw sewage but organic solids that are produced during treatment in the wastewater treatment process. They have been treated to stabilise organic matter and reduce disease-causing organisms or pathogens. 
What the majority of treatment plants are not using though is advance treatments to remove the nasties (emerging contaminants) from the sewers ranging from pharmaceuticals (antidepressants, endocrine disrupters), microplastics, heavy metals and PFAS to name a few. These enter the sewer system along with industrial wastes.
The biosolids can be applied to the land direct from waste treatment plants or used as branded compost and fertilisers. Either way, the land owner is importing a contamination problem.
Transforming modern sewage sludge into fertilisers without proper and effective guidelines to portray the biosolid as a beneficial use is beneficial to who?
This draft NEMP 3 appears to be a wastewater industry-led government review to provide an update that achieves little to prevent a cocktail of pollutants entering the environment rather than be captured at point of treatment.
Managing and treating biosolids and recycled wastewater is expensive, that is the reality but it is also government and industry's job to find a solution. If sewage sludge continues to be offloaded onto farmland under the proposed NEMP 3, the future effect to land and water and potential cost burdens, now and in the future, should be considered as a counter to investing in better, more costly treatment technologies that currently exists but little used.

how biosolid is branded

Beneficial reuse -
  • is just transferring a problem from the industry to the farmer and environment because the pollutants are not destroyed. Pharmaceuticals, PFAS and heavy metals go somewhere - taken up by pasture and crops, then fed to livestock and runoff into creeks and rivers or seep into groundwater.
  • is propagating a lie with marketing material from brands embracing healthy soils confusing the public giving no indication it is made from sewage sludge with the term 'compost' used instead with no mention of PFAS and heavy metals because compliance on package labels relates to outdated Australian standards.
  • is not disclosing the possible risks due to diseases, heavy metals and bioaccumulation of PFAS or other components of the biosolids.
  • feedstock has potential for vast differences in contaminants

​Why is there no ecological information on the Safety Data Sheet for a local Gippsland compost using biosolids?
An example of waste collected for composting in Gippsland can be found on the following webpage Gippsland Regional Organics
 

state of knowledge - who knows what?

State of Knowledge covers three areas - 
  1. What the world's experts and businesses are learning about PFAS toxicity and emerging contaminants.
  2. The people/farmers who are unknowingly applying biosolids & recycled wastewater to their lands without disclosures of potential pollutants that may bioaccumulate on their land.
  3. Increase in litigation in America due to biosolids contamination.
Healthy soils are essential to provide safe food production, clean water and habitats for biodiversity so it is not surprising that industry branding need to instill a trust for consumer confidence. Unfortunately, product disclosure is not declaring WHAT CONTAMINANTS ARE KNOWN or HAS THE POTENTIAL TO CONTAIN. This is on the back of major food retailers trust in Australian standards to ensure branded compost/fertilisers are compliant with legislation. The outdated Australian Standard AS4454 allows producers to be compliant as it does not even mention PFAS. Wastewater Treatment Plant's state of knowledge has it in all sewerage sludge as noted in Anthony Amis submission at top of page. The compost is on-sold to be branded under the compliance of Australian Standards with the unsuspecting consumer and their land is the 'beneficiary' of toxic dosing over and over again. 
HARPS - Harmonised Australian Retailer Produce Scheme A supposed 'world-first scheme designed to harmonise all retailer-specific food safety, trade, and legal requirements of each of Australia’s major grocery retailers (ALDI, Coles, Costco, Hello Fresh, Metcash (IGA) and Woolworths).
The HARPS scheme is a lazy system for the major food retailers to disclaim product safety to consumers safety when it is the complete opposite. CoM will be challenging this.

what to do with the branding network for sewage sludge

Compost brands that sell products with biosolids are now at risk but the public is dependent on the NEMP 3 to ensure a commitment to healthy soils and plants. On the current draft it is business as usual and a huge coverup.
Wastewater Treatment Plants need composters to offload their huge stockpiles of biosolids which they probably see as needing to be protected, nurtured and invested in.
The biosolids campaigning for improved treatment of sewage sludge to ensure land stewardship into the future is growing so governments (taxpayers) also need to invest in our future.

The following excerpt comes from a study of Sweden's attempt to address land application of biosolids - 
What sewage sludge is and conflicts in Swedish circular economy policymaking
Sewage sludge as risk
  • 'The composition of sewage sludge is sometimes referred to as a mirror of the society, and thus the composition of it changes depending on consumption habits, connected businesses, and treatment processes. Many of the substances which are released into the wastewater might have unknown effects on the environment, could have combination effects, and might not be measurable. This leads to uncertainty regarding potential risks. Some interviewees argue that this uncertainty demands society to take a precautionary stance, ‘it is a sludge which we do not know anything about, how many substances it contains.'
The following is a translated excerpt from a submission by the Swedish Chemicals Agency - Kemikalieinspektionen which is equivalent to our Australian Industrial Chemicals Introduction Scheme
  • “The arable land is a finite resource, the conditions of which must be able to be used by future generations. If the productive agricultural land is exposed to long-term exposure to hazardous substances and substances that are difficult for nature to break down, this means that the land is polluted during long time, which in the long run can lead to the soil's productivity incapacity is threatened. Furthermore, there is uncertainty about what is happening in the surrounding natural environment as a result of the spreading of sludge containing dangerous substances on arable land…” KEMI Submission (Sweden)
​Industry and government don't need to report the extent of biosolid contamination as monitoring and testing is insufficient. Therefore, unless the voice grows government do not need to do right by the people and the environment. We need to challenge what is going on in our own backyard and market system economics to save capitalism from itself. If we do not protect the land and environment now there is no healthy economy.
The completed submission will be uploaded on this page in March 2023