Sludge Watch ==> Rural America Demands an end to the land spreading of sludge

[Maureen Reilly]

Sludgewatch Admin:

Helane Shields, sludge researcher extraordinaire,  has updated her excellent 
list of reasons why there should be an end to lthe and application of sewage 
sludge.

...........................................................



RURAL AMERICA DEMANDS AN END TO THE LAND SPREADING OF
MUNICIPAL SEWAGE SLUDGE (“BIOSOLIDS”) FOR THE FOLLOWING
REASONS:

     BECAUSE the Federal Clean Water Act defines sewage sludge as a 
“pollutant”
[33 U.S.C.1362(6)];

     BECAUSE the Harper-Collins Dictionary of Environmental Science 
describes sludge as: “A viscous,
semisolid mixture of bacteria and virus-laden organic matter, toxic metals, 
synthetic organic chemicals,
and settled solids removed from domestic and industrial waste water at 
sewage treatment plants”;

     BECAUSE the US EPA acknowledges that the pollutants and pathogenic 
organisms in sewage sludge
“. . . upon exposure, ingestion, inhalation, or assimilation into an 
organisms either directly from the environment
or indirectly by ingestion through the food chain, could, on the basis of 
information available to the Administrator
of EPA, cause death, disease, behavioral abnormalities, cancer, genetic 
mutations, physiological malfunctions
(including malfunction in reproduction), or physical deformations in either 
organisms or offspring of the organisms.”
[40 CFR Part 503.9 (f)]

     BECAUSE official EPA policy is to dispose of landfill and Superfund 
leachates, radioactive wastes,
and toxic commercial and industrial chemicals into public sewer systems, to 
be combined with residential
sewage and other pathogenic sources, with the resultant sewage 
sludge/”biosolids” to be spread on the land
in Rural America;

     BECAUSE in 2004 the US EPA Office of Inspector General issued a 
critical report saying
industrial pretreatment programs are at risk, they are low priority with 
EPA, toxic pollutants are
still being transferred to sewage treatment plants, and  “the impact to 
human health and the environment
of some of these pollutants may still not be known;”

     BECAUSE FEDERAL LAW permits every business and industry in the United 
States
to dump 33 pounds of hazardous wastes into public sewers every month with no 
reporting
requirements [ 40CFR 403.12)P)(2) ];

     BECAUSE the EPA’s Toxics Release Inventory (TRI) and public records 
indicate industrial
pretreatment programs are inadequate, ineffective and/or not being enforced 
in states around
the nation to control the discharge of toxic industrial chemicals into 
sewers.    And the TRI reveals
that the quantities of toxic metals and other hazardous chemicals being 
discharged into public sewers
are increasing; and EPA acknowledges that the wastewater treatment process
reconcentrates the pollutants in the treated sewage sludge/“biosolids”;

     BECAUSE in 2006, the Cornell Waste Management Institute released a peer 
reviewed
study which found that some sewage sludges have such high levels of 
pollutants that they exceed
the US EPA’s Superfund Soil Screening Limits;

     BECAUSE the waste industry in 1999 convinced Congress to exempt sewage
treatment plants  (POTWs) from any Superfund liability with regard
to the toxic pollutants processed by such facilities;

     BECAUSE the EPA acknowledges all treated sewage sludge (“biosolids”), 
both
Class A and Class B, contains toxic metals including arsenic, antimony, 
beryllium, cadmium,
chromium, lead, molybdenum and mercury; dangerous pesticides; toxic, 
bioaccumulative
poisons including dioxins, furans, brominated flame retardants; and 
hazardous industrial wastes
including solvents, cyanide, polycyclic aromatic hydrocarbons and other 
volatile and semi-volatile
organic (carbon-based) chemicals;

     BECAUSE the EPA allows Class B sewage sludge/”biosolids” to contain
significant quantities of human pathogens [up to 2 million CFUs
(colony forming units) of fecal coliforms per gram of total solids, dry 
weight],
and slaughter house wastes, mortuary discharges and infectious
hospital and institutional wastes, including disease-causing bacteria, 
viruses,
virulent antibiotic resistant  microbes, protozoa,  intestinal parasites and 
parasitic worms;

     BECAUSE the EPA acknowledges that sewage treatment plants can 
reconcentrate
infectious prions from human and animal sources – (which can cause 
transmissible spongiform
encephalopathies in humans and animals including scrapie, bovine spongiform 
encephalopathy
[mad cow disease], and Creutzfeldt Jakob Disease (CJD), -- in Class B sewage 
sludge which is
being top dressed (surface applied) on grazing lands and dairy pastures 
across the nation
and also in Class A sewage sludge biosolids which is sold by the bag in 
WalMart,
Home Depot, hardware stores, nurseries, etc. across the country to 
unsuspecting home gardeners;

     BECAUSE the EPA has never conducted a risk assessment on the harm to 
human health from
the pathogens in surface applied (top dressed) sludge including airborne 
pathogenic dusts,
viruses, bacteria, endotoxins, molds, fungi, etc. despite increasing 
evidence from around the country
that neighbors of sludge sites are getting sick;

     BECAUSE the EPA acknowledges land applied sewage sludge emits 
toxic/irritant gases including
dimethyl sulfide, dimethyl disulfide, methyl mercaptan, trimethylamine and 
ammonia, which CDC, NIOSH,
OSHA, DOT, ATSDR and other government agencies warn can cause great
harm to human health if inhaled or ingested (“ingestion” includes 
‘inhalation of bioaerosols,
which are deposited in the throat and upper airway and swallowed’);

     BECAUSE a report published in November 2000 Journal of Agromedicine –
Dr. Susan Schiffman, Duke University Medical School, and Dr. John Walker, US 
EPA,
lead authors—details the harm to human health from sludge odors, odorants, 
bioaerosols and
airborne particulates including “ . . . eye, nose, and throat irritation, 
headache, nausea, diarrhea,
hoarseness, sore throat, cough, chest tightness, nasal congestion, 
palpitations, shortness of breath,
stress, drowsiness, and alterations in mood” and “ . . . exposure to 
increased levels of
particulates is associated with increased mortality risk, especially among 
the elderly and individuals
with preexisting cardiopulmonary diseases, such as chronic obstructive 
pulmonary
disease (COPD), pneumonia, and chronic heart disease.”

     BECAUSE the aforesaid sludge/biosolids dusts, bioaerosols, gases and 
airborne pathogens
can combine to form a noxious miasma which can engulf and adversely affect 
the health of neighbors
of sludge sites – particularly babies and young children, the elderly and 
people with compromised
immune systems.

        BECAUSE courts in California, Oregon and Kentucky have ruled that 
the odors and emissions from
sludge processing facilities are a “public nuisance”, and the judges in 
Kentucky and California cases
awarded monetary damages to the sludge victims;

     BECAUSE the land spreading of treated sewage sludge/“biosolids” has 
caused sickness
(and even death) in people around the country – (known as “sludge syndrome”) 
including
nausea, vomiting, diarrhea, eye, nose and throat burning and irritation, 
skin rashes and lesions, cysts,
bloody noses, eye infections, pneumonia, asthma and other respiratory 
illnesses, tumors,
immune system damage, viral and bacterial infections and a host of other 
physical maladies;
(See -  http://www.sludgevictims.net
and http://www.cfe.cornell.edu/wmi/Sludge/INCIDENTS.htm   )

     BECAUSE in their July 2002 report, the National Research Council 
acknowledged that despite
the fact that treated sewage sludge/”biosolids”is a complex mix of pathogens 
and toxic chemicals which may
affect human health:  “Because of the data gaps and lack of risk assessment 
methods for complex
mixtures, it is NOT POSSIBLE to integrate pathogen risk assessment with 
chemical risk assessment.”
(Page 6)      http://books.nap.edu/books/0309084865/html/6.html#page_middle

     BECAUSE the land spreading of sewage sludge has caused sickness and 
death of fish, livestock and family pets;

     BECAUSE sludge nutrients, toxins and pathogens are known to have 
contaminated drinking water wells, ground water
and surface waters around the country;

     BECAUSE treated sewage sludge/“biosolids” contains  brominated flame 
retardants (PBDEs),
nonylphenols, surfactants, phthalates and other persistent, bioaccumulative, 
toxic and  endocrine/hormone
disrupting chemicals which cause great harm to wildlife and aquatic life;

     BECAUSE Central and Northern European countries including Germany and 
Denmark
are moving away from land application because of the uncertainties about 
endocrine disrupting
compounds in sewage biosolids; and Switzerland has already banned land 
application based on the
precautionary principle;

     BECAUSE the EPA has never conducted a risk assessment into the risks of 
the harm to wildlife, soil biota
and other ecological biosystems from “top dressed” (unincorporated) sewage 
sludge/”biosolids”;

     BECAUSE a recently released study by AMSA (Association of Metropolitan 
Sewerage Agencies)
shows that DIOXIN levels in 2/3rds of sewage biosolids exceed the 
concentrations at which two EPA
Risk Assessments show can cause great harm to certain species of wildlife;
BECAUSE the EPA has established the least protective sludge regulations of
any developed country in the world -- (Canada and European countries use the
“precautionary principle” - or “no net degradation to soil quality”—to set 
limits on toxic metals from sludge
in agricultural soils many times  lower than US EPA );

     BECAUSE the EPA Inspector General in April 2000 stated:      “EPA does 
not have an
effective program for ensuring compliance with the land application 
requirements of Part 503”;
and “Accordingly, while EPA promotes land application, EPA cannot assure the 
public that current
land application practices are protective of human health and the 
environment.”   In February 2002,
the EPA Inspector General stated:    “The agency (EPA) can neither 
investigate nor keep track of all
of the complaints of adverse health effects that are reported.”

And in September 2002, the EPA OIG said “EPA does not know whether current 
regulations,
when adhered to, are protective of public health” and “When it issued the 
rule, EPA committed
to conducting a comprehensive research program to assess the risks
associated with land application of biosolids, yet it has not yet done so.”

     BECAUSE IN June 2001, Scientists at a Cincinnati, Ohio, workshop 
sponsored by
US EPA and USDA concluded present pathogen testing methods are inadequate 
and a
great deal more research must be done with regard to pathogens  before 
treated
sewage sludge/ “biosolids” can be pronounced  “safe”;

     BECAUSE state “environmental/regulatory” agencies across the nation are
PROMOTING land application of treated sewage sludge/”biosolids”, and doing 
nothing to
respond to sickness, water contamination and other concerns of Rural 
Americans who are
suffering health and environmental consequences, lower property values and 
destruction of their
quality of life by the disposal of this noxious waste in their communities;

     BECAUSE despite the fact that Congress always intended that sludge 
disposal be a local option,
sludge bullies have filed lawsuits in Pennsylvania, Virginia, California and 
Florida to force this toxic/pathogen
waste from urban and industrial  sources on unwilling rural communities 
which seek to protect themselves
by enacting local sludge control ordinances;  Courts in New Hampshire and 
California have ruled that
the use or disposal of sludge is a “local determination” in accordance with 
federal Clean Water Act
Title 33, Chapter 26, Subchapter IV, Sec. 1345.

     BECAUSE THE US EPA has made a concerted effort to cover up and avoid
any and all documentation and/or investigation into the sickness (and death) 
of sludge victims –
humans and animals;

     BECAUSE the US EPA has given over $19 million of our tax dollars to the 
WEF
(Water Environment Federation - the lobbying and public relations arm of the 
waste industry)
to promote sludge spreading and hire industry friendly, pro-sludge 
“scientists” ” to rubber stamp waste
industry/EPA sludge policies, and to fund their campaigns to debunk and 
discredit sludge
victims and people seeking more protective sludge rules;

     BECAUSE in August 1999, the EPA weakened federal sludge rules (40 CFR 
Part 503) –
by changing the wording of the certifications by the sludge producers/sludge 
spreaders
required under 40 CFR Part 503.17, so that they NO LONGER have to certify 
that the
“requirements” of federal law with regard to pathogen reduction, vector 
attraction reduction, management
practices and site restrictions “have been met”;

     BECAUSE despite the fact that EPA and the waste industry promote 
treated
sewage sludge/”biosolids” as “fertilizer”, in fact in March 2003 the 
National Farmers
Union called for an end to the land spreading of Class B sewage 
sludge/”biosolids”;

     BECAUSE the EPA has harassed and retaliated against any scientist 
within its agency
who dares to speak out in opposition to its sludge/biosolids  (or other 
waste mismanagement)
policies; and in May 2003 forced the resignation of renowned EPA 
microbiologist David L.
Lewis because of publication in prestigious scientific and medical journals 
in June and July 2002,
of his peer reviewed studies on adverse health effects reports by sludge 
victims; and

     BECAUSE the highly respected Waste Management Institute of Cornell 
University,
Ithaca, New York, has studied the land application of sewage sludge for many 
years and
has published a report in the International Journal of Environment and 
Pollution,
which concludes the EPA 40 CFR Part 503 sludge rules do not protect human 
health,
agricultural soil and the environment.


Prepared by Helane Shields, Sludge researcher since 1996
PO Box 1133, Alton, NH 03809     Phone  603-875-3842      Email: 
hshields at worldpath.net