Sludge Watch ==> Barbara Rubin, Virginia - Sludge Panel's Biased Work

[Maureen Reilly]

From: Barbara L. Rubin
To: biosolids at deq.virginia.gov
Sent: Monday, October 29, 2007 11:51 AM
Subject: Sludge Panel's Biased Work


Barbara L. Rubin

1496 Teague Drive

McLean, VA 22101

October 29, 2007

Biosolids Expert Panel Members:

I want the Panel and Assembly to be aware that there are sludge victims and 
citizens who feel completely left out of the carefully orchestrated work of 
a group of members (who mainly have sludge industry affiliated jobs) plus 
two so called "citizen representatives. (See letter below.)

Henry Staudinger, who is labeled "citizen representative," does not 
represent the concerns of all victims or citizens involved in this issue. 
Therefore, his agreements and conclusions may not be acceptable to the 
greater public.

The second so called "citizen representative" Alan Rubin recently retired 
from the EPA. His entire professional career is dependent on the sludge 
program prevailing. Now he is a well paid consultant to the sewage sludge 
industry. Hardly what victims and those opposed to sludge would call a 
"citizen representative."

Please note the early activity of certain members in the initial meeting and 
letters generated by the above referenced panel members, make it clear the 
agenda is being hijacked by pro-sludge propagandists. The "private" meeting 
between the above two members was probably a rules violation. The panel 
appears to be ignoring the most important facts while being "steered" to 
focus on manipulated materials controlled by those intent to force this 
heinous program on unwilling citizens. Panel members themselves admit they 
have no allotted funds and "limited resources and time" to produce credible 
results.

The work product of this panel will be questioned by most citizens. As 
examples, I for one strongly dispute the premise in H. Staudingers posted 
letter:

"From the perspective of the public, it is hoped that the panels report will 
lead to better protection for health, the environment and quality of life 
'when' biosolids are land applied."(emphasis added)

This statement assumes that the program should continue because there is a 
way to spread sewage sludge so that the stench and airborne toxic particles 
will be safe for the health of neighbors. This is false propaganda that the 
EPA/sludge industry wants us to believe. I have researched sewage sludge and 
the exposure of neighbors for 5 years and have found no evidence of safe 
usage when regulations are followed. We know regulations are rarely 
followed, however, even the EPA Inspector General admits that if all 
regulations are followed there is NO ASSURANCE sewage sludge is safe for 
public health. One only has to visit Helane Shields website, 
http://www.sludgevictims.net to find that neighbors all over the US exposed 
to sewage sludge suffer from similar illnesses. There are also deaths linked 
to sludge exposure. Therefore, the only strategy that will provide citizens 
assurance that they are safe from the horrific health and environmental 
consequences of sludge exposure is to call a moratorium on the sludge 
program.

Similarly the following statement in A. Rubins posted letter erroneously 
assumes citizens should be responsible for providing scientific data.

"The publics inability to scientifically document the exposures relationship 
to biosolids that are in close proximity to their residence due to lack of 
information as to the constituents in biosolids has been particularly 
troubling." (Emphasis added.)

This is an outrageous assumption and should be condemned immediately. As to 
documentation, there is no documentation because the EPA/industry/local 
governments chose not to document, and they chose to ignore doctors letters 
and scientific studies linking illness and deaths to sludge exposure. 
Victims and citizens are not responsible for scientific evidence. EPA/local 
governments/industry are responsible for scientific evidence proving sludge 
safe for public health.

I would also like to take this opportunity to express my full support for 
the 10/23/07 letter from Mary Carwile. She rightly points out the 
infuriating lack of attention to health survey and exposure studies by 
independent scientists. This inattention is in spite of citizens repeated 
requests for these studies. Perhaps the sludge supporters know the results 
would support the citizens contention that sludge exposure is linked to 
numerous health problems and even deaths.

Mary also correctly points out that the panel seems to be ignoring the only 
peer-reviewed study (which has never been refuted) ever done on health 
effects of sludge. She goes on to say:

the constituents in land applied sludge have long since been proven to be so 
complex and so unpredictable that a reliable health risk assessment of land 
applied sludge based solely on trying to identify contaminants in sludge, 
without considering interactions of chemicals and the effect of breakdown
products will never be possible."

Why is the Panel ignoring these crucial facts? A. Rubin suggests in his 
letter working on "adequate" buffers would be an acceptable substitute. 
There is not a shred of scientific evidence dealing with the matter of safe 
buffers. The original "guess" on buffers has been a disaster. Why should 
citizens have any more faith in a second guess by unresponsive promoters of 
this dangerous program?

So far, this panel has verified citizens worst fears and will never have 
credibility with the public until our real concerns are addressed, our 
unfiltered views are included, and we are represented in adequate numbers. 
Why arent the sludge propagandists forced to present credible scientific 
evidence by independent scientists that sludge exposure is safe for public 
health, instead of false propaganda?

Barbara L. Rubin

Loudoun Neighbors Against Toxic Sludge

www.LoudounNATS.org





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Barbara L. Rubin

1496 Teague Drive

McLean, VA 22101

September 14, 2007



L. Preston Bryant, Jr.

Office of the Secretary of Natural Resources

Patrick Henry Building

1111 East Broad Street

Richmond, VA 23219

Dear Secretary Bryant:

I consider myself a sludge victim. I had my initial exposure in August 2001 
which resulted in an immediate virulent Mycoplasma pneumonia and lung 
infection. It took a 5 day hospital stay, 4 months, and 8 courses of 
antibiotics, to force the infections into remission. I have never gotten rid 
of these infections and since that initial exposure my overall health has 
steadily deteriorated resulting in numerous chronic illnesses.

Unfortunately, my health does not allow me to appear at the meeting on 
September 18, 2007. I will be undergoing medical treatment at this time. I 
would however like to register my objection to the list of panelists for the 
"Expert Panel Studying Biosolids."

Often an agency or industry is forced to name a "Panel of Experts" to 
appease an unhappy public. While authorities reluctantly "agree" to the 
concept of "study," they carefully control it by stacking the panel with 
members who will eventually reach predetermined conclusions which they hope 
will quiet the public. The sludge industry has engaged in this maneuvering 
numerous times before (Stakeholders Research, Sludge Summit.) None of these 
carefully planned events have succeeded before. This new study panel has all 
the ear markings of the past fiascos

In general the current panel list is stacked heavily with state government 
representatives whose jobs depend on their defense of the sludge program 
and/or representatives from institutions that depend on the sludge industry 
for their functioning. In other words far to many panelists have financial 
ties to the sludge industry. Why arent there more people who have had their 
lives shattered by this program on the panel? They are certainly expert on 
sludge and its effects. Why do I only see one member (out of about 27) who 
does not directly or indirectly have their job connected to sludge money, 
represented on this panel?

Because of the grossly unbalanced nature of the "members," one must conclude 
this is by no means an unbiased panel objectively looking at the sewage 
sludge issue. Instead, it is a carefully planned and controlled response 
which will whitewash the issue and claim there is no foundation to the 
scores of valid complaints that have plagued the ill founded sludge program 
in Virginia


In further attempt to control all data, I am told the many "citizen 
representatives" who were carefully excluded from the "panel" may not even 
be able to speak at these meetings. If they are allowed to speak they will 
need to severely limit their input. This unfair control assures that the 
citizens real concerns and issues will never be considered at these staged 
meetings.

The first of a number of examples of people who raise grave concerns on this 
panel is Dr. Alan B. Rubin (no relation to me.) Dr. Rubin has recently 
retired from the EPA where he was one of the original developers and 
promoters of the sludge program. He was instrumental in "pushing through" 
the 1992 Sludge Rule which had failed the peer-review process of the EPAs 
own research department. Dr. Rubins entire professional career has been 
dependant on implementation and continuation of the 503 Sludge Rule. He is 
currently employed as a consultant, reaping huge financial rewards from the 
sludge industry. To include Dr. Rubin as "Citizen Representative" of the 
people of Virginia is outrageous. His position of biased, unquestioning 
support of sludge is already represented by almost all of the other members.

Virginia Tech has had a long close working relation with the VDH/DEQ in 
forcing the unwanted Sludge program on counties all over Virginia. In 
particular Dr. Greg Evanylo has traveled all over the state participating in 
t he state/industry sponsored "staged "meetings" in which they blanket new 
areas, which are fighting inclusion in the sludge program, with untrue 
propaganda. Even though much of the propaganda has been proven factually 
false, it is still repeated by these faithful promoters of sludge.

Chris Peot from the Blue Plains, Sewage Sludge Treatment Plant is another 
member of the group that can hardly be seen as unbiased. He is a manager of 
a sewage sludge plant that supplies much of Virginias sewage sludge. Not 
only would his position eliminate him from an "unbiased panel" but he too 
travels around the country in staged "meetings" preaching that sewage sludge 
is the best thing since sliced bread. Add to this the fact that Mr. Peot has 
testified for the sludge industry at a wrongful death case, we begin to see 
how this so called "unbiased panel" is predestined to endorse a very 
dangerous and harmful program because it is stacked with "pro-sludge" 
individuals.

I would hope this panel is not in its final form. It needs to be 
substantially adjusted to be more balanced and therefore more credible to 
the citizens of Virginia. If it is not, the intended appeasement of citizen 
concerns will never be attained.

Sincerely,

Barbara L. Rubin

Loudoun Neighbors Against Toxic Sludge

www.LoudounNATS.org