ISDS 



SYSTEM ADDirrVES 



Findings and Concerns 



As outlined in previous sections, much documented research indicates that the long term 

 damage produced through use of ISDS treatments (including chemicals, yeasts, bacteria, 

 and enzymes) far outweighs any short-term benefit which these substances may provide. 

 Not only is potentially irreversible damage done to the system itself, but the infiltrative 

 capacity of leach field soils may be permanentiy compromised, and severe chemical 

 contamination of receiving waters may result 



Groundwater testing has revealed chemical contamination likely attributable to ISDS 

 additives in Rhode Island. Despite the current regulatory ban on use of acids in ISDS 

 maintenance except in leaching lines, many pumpers are unaware of the prohibition, and 

 are known to routinely offer clients "the acid treatment" as a component of pumping 

 maintenance. 



RIGL Chapter 24.3, entitied "Substances or Compounds Used as Sewerage System 

 Cleaners", presentiy gives the Director of DEM the authority to designate any sewerage 

 system cleaner as a "restricted material." When a four-step designation process has been 

 completed, and a product has been designated as a restricted chemical, the director has 

 authority to issue orders to persons engaged in the manufacture, distribution, or sale of 

 cleaners, including the recall of these materials. Civil and criminal penalties may be 

 assessed. The availability of this regulatory tool has allowed RIDEM to negotiate 

 alterations in product composition with manufacturers, but no products have thus far been 

 banned. 



Recommendations to RIDEM 



**Draft legislation for submission to the next session of the General 

 Assembly providing for an across the board ban on the sale of ISDS 

 additives in the state of Rhode Island. Prepare a comprehensive position document 

 on additives, and the hazards presented by their use, expanding upon the findings 

 presented to the ISDS Subcommittee on Regulations. 



***At a minimum, ban the sale of septic system cleaners in the state which 

 contain organic solvents listed by EPA as potential drinking water 

 contaminants. Use of such products should be prohibited throughout the state, 

 particularly in designated critical areas and areas where groundwater is or may potentially 

 be used as potable water supply. 



**Until a ban on sale of additives can be authorized, establish a system of licensing sale of 

 system additives in the state, using licensing systems applied in other states (e.g., 

 Connecticut) as models. A listing system is needed which places the burden of proof on 

 die manufacturer in demonstrating that a product (or its in-tank generated byproducts) does 

 not and will not degrade groundwater or surface water resources. Such a system would be 

 preferable to the system now in place, which places the onus on the state to prove harm 

 with each individual product. 



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