National Sludge Alliance (NSA) researchers were pleased with the House Science Committee Hearing held March 22, 2000. Strangely enough, it was not about science. It was called to address EPA's treatment of whistleblowers and Dr. Alan Rubin's intimidation of people opposed to EPA's policy of dumping of toxic sewage sludge on farmland as a fertilizer. EPA whistleblowers and researchers have long opposed the EPA's 13 year old states' program of using the most toxic concentration of hazardous sewage residue from the treatment process (sludge) as an uncontrolled fertilizer on food crop production land. Just so the city folks don't feel left out, EPA, USDA, FDA and CDC also signed off on a much longer running program to heat dry or compost this toxic mixture of death-dealing chemicals and disease organisms as an unlabeled fertilizer for your lawn and garden.
NSA researchers -- as well as irritated and agitated city, state and EPA officials -- have completed serious research to get at the truth of why EPA and health departments would not investigate human health and environmental damage caused by the use of toxic sludge. In the process, they discovered EPA has a multimillion dollar debunking program, the federal BLM prohibits sludge use on government land because of Superfund concerns, and there has been a dramatic increase in food poisoning incidents in the last ten years. Researchers found that not only had food poisoning incidents soared to 81 million annually since sludge has been considered to be a fertilizer, over ten percent of our dairy herds are now infected by Salmonella and E. coli, which contaminate the milk and the meat. This has not been an easy process of discovery as they have had to face outright lies, humiliation, harassment and intimidation.
In spite of the opposition and lack of support, the researchers found that ocean dumping of sludge was banned because it was destroying the marine environment. In exchange for getting it stopped, prominent environmental groups signed a consent decree agreeing not to hinder US EPA's plan to promote land application. EPA forgot to tell them it was going to put toxic sludge on their lawns and food, and still let toxic pollutants drain into the ocean. Armed with that information and the heartbreaking stories of the victims, they and the whistleblowers have faced the lies, humiliation, harassment, and intimidation as they marched on in lockstep to the House Science Committee Hearings.
EPA operated true to form during the hearings. Rubin help write a hastily assembled Inspector General's (IG) report which pleaded EPA did not have the people, the money or the power to monitor the sludge disposal program, enforce its guideline, or do any recordkeeping. Nor could it assure the Committee that the public health and the environment was being protected. Not only that, but the report noted GAO had reported these same problems existed in 1990. The report also reiterated the EPA policy of limiting sludge dumping liability by stating that any improper or misapplied sludge use which harmed public health or the environment would be treated as an unknown source of pollution (nonpoint source). This was old news, Including:
DR. ROSEMARIE RUSSO of EPA: "EPA failed to conduct research in six areas vitally important to determining the public health risks associated with sludge."
DR. JIM SMITH, EPA EXPERT ON PATHOGENS: "conceded that the 503 sludge rule never was subjected to a vigorous risk assessment based on the harmful health effects which may arise from bacteria in the sludge."
Attorney Kohn told the Commission Joseph Cocalis of the CDC testified under oath that the 503 sludge rule is indefensible from a public health standpoint ...and that under oath the EPA director of the Ecological Research System said the 503 sludge rule is NOT SCIENTIFICALLY DEFENSIBLE ...people will die from the rule!
Apparently, the Medical School at Harvard never got the message. On May 3rd, in a desperate attempt to preserve some of the governments' credibility, toxic contaminated sewage sludge (biosolids) was sprayed on the quad lawn at Harvard Medical School. This was truly an amazing demonstration of the power the governments have over the educational system.
In a copyrighted article, Secretary of Environmental Affairs Robert Durand said, "Biosolid composts can be applied safely by landscapers, farmers and homeowners." Durand said the Harvard display was aimed at making people more comfortable with using human feces as a fertilizer, an idea he conceded people aren't thrilled about. "I think the general public needs to be convinced," Durand said. "They've got to get over their hang-ups."
Ned Beecher of New England Biosolids, which promotes the use of biosolids for individual and municipal use, said the compost applied Wednesday at Harvard was probably cleaner than the soil already at the site. "This is as safe as you can ever find," he said.
Dr. William Yanko, took exception to that line of thought in the original compost research for EPA. However, the neat thing about this is that the Medical School can now use its own students in the first direct controlled study of human exposure to the toxic chemicals and pathogenic disease organisms in sludge. The down side for Harvard is the liability, as the students get sick, the doctors may not know what to test for, but the lawyers will have a field day. Then there is the liability of having turned the quad lawn into an illegal open dump under the RCRA and the Solid Waste Act. Need we mention the fact that sludge is a pollutant under the Clean Water Act. Do you think these bright young men were told that the act of disposing of sludge on the quad lawn was based on an exclusion in the Superfund Act, for commercial fertilizer?
Just how clean are the biosolids? Even the EPA does not know what is in it. The best guess of the EPA group responsible for the Community Right to Know Act estimates there are over 500,000 reportable chemicals. Any or all of them could be in sludge at varying levels on any given day. Using standard tests, EPA doesn't even know how many pathogenic disease organisms survive the treatment process, but it knows the pollutants will kill or at least make you wish you were dead.
After the original Hearing date was canceled, a NSA researcher asked Carol Browner about the toxic effects of sludge, "I am requesting information available to you, as Administrator of EPA, that shows a pollutant is any organic or inorganic substance, or combination of inorganic or inorganic substances, or pathogenic organism that, after discharge and upon exposure, ingestion, inhalation, or assimilation into an organism either directly from the environment or indirectly by ingestion through the foodchain could 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."
EPA's Dr. Alan Rubin, who claims there is 40 years of research proving the safety of sludge was caught between a rock and a hard place on this, he had to tell the truth: "The definition of "pollutant" in section 503.9(t) of the 40 CFR Part 503 Biosolids Rule is taken directly from the definitions section of the governing statute, the Clean Water Act. This definition of "pollutant" indicates the type of impacts that these materials (inorganics, organics, pathogens) could cause to humans and other species if humans and other species are exposed to these materials at sufficient doses and over a sufficient period of time. The main classes of these pathogenic organisms are bacteria such as salmonella, viruses such as polio, protozoa such as giardia, and helminths such as ascaris. EPA or "The Administrator" has enormous amounts of information on these "pollutants" compiled over decades of studies and research. This information clearly indicates that if humans and other living species are exposed to these materials at sufficient doses and over sufficient periods of time, there is a potential for adverse effects to be observed"
Did the EPA forget to mention these small details to the National Academy of Science for its study on the use of sludge and effluent in crop production or Harvard? The adverse effects of direct exposure could be mistaken for food or waterborne poisoning which manifests within hours, or up to six months later, for some organisms. On the other hand, it may take from 3 to 20 years for the cancer causing agents to manifest their damage. Then there are the unknowns in sludge which can cause internal organ and systems damage as well as kill without leaving a trace marker in the body to indicate the cause of death. Cornell did some research in this area in the early 80's. This is Exceptional Quality (EQ) biosolids.
While EPA has released very little information on pathogens in sludge used as a fertilizer, English researchers have, "PHLS scientists have told MPs that the deadly food poisoning bacterium and viruses such as hepatitis A are present in effluent used to fertilise fields housing livestock or growing vegetables. "There's clearly the potential for a nasty incident," agrees Hugh Pennington, a microbiologist at the University of Aberdeen who led the inquiry into the E. coli O157.
Yet EPA created a raging scientific debate over how much of the nine least threatening toxic metals (out of 126 listed Toxic Priority Pollutants) in sludge it would take to harm public health and the environment. EPA even removed all references to Chromium (a carcinogen) from the beneficial use section of its sludge policy and no one asked why. Not only that, but EPA claims it has little or no data on airborne toxic contamination, even though 5 of the chemicals it proposed for regulation in 1989 were acknowledged cancer causing agents by inhalation.
EPA whistleblower Dr. David Lewis gives us a different perspective on airborne contamination. He says,
"In particular, it appears that sufficient amounts of organic amines, such as trimethyl amine (TMA), can develop from microbial and chemical reactions that occur in sludge.
Exposure to sufficiently high concentrations of gaseous organic amines can cause severe irritation of the eyes and skin, and damage to mucus membranes leading to pulmonary edema (bleeding in the respiratory system). These toxic gases can also cause damage to the lungs, liver, and other internal organs. Initial symptoms include eye irritation, skin rashes, burning in the mouth, nose, or throat, generation of mucus, headaches, nausea, and vomiting. Such damaged tissues can serve as a port of entry for bacterial or viral pathogens, leading to flu-like infections, pneumonia, or bacteremia/septicaemia.
Nitrogen-based, cationic polymers added to sewage sludge during the dewatering process enhance the potential for biosolids to generate large amounts of organic amines, formed by biodegradation. The amines are released in gaseous form when the alkalinity is raised somewhat above pH 10, such as by adding lime.
It appears that sufficient quantities of organic amines can be generated by sludge to cause clinical symptoms in individuals working with the material or living in areas where large amounts are applied. Adverse reactions may be manifested immediately among workers where sewage sludge is dewatered and limed at a waste treatment facility. Or, symptoms may be experienced among people living in and around areas where fresh biosolids are deposited and still degassing. Delayed exposures may also occur in the field when additional lime is applied, or rain causes dried biosolids to begin reacting again.
Symptoms associated with organic amine poisoning are occurring with some frequency among waste treatment plants workers.
This complex substance poses a significant neurotoxic threat to farmers, their workers, nearby residents, and possibly to the general population through the food supply."
One of the substances produced is H2S, Hydrogen Sulfide. The only gas more deadly is Hydrogen Cyanide. A study funded by MERCO Joint venture asked Texas Ag Experimental Station of Texas A & M to determine whether airborne pathogens from New York City sludge being spread in Texas could impact the residents of Sierra Blanca -- 10 miles away. You may remember Merco was the outfit that sued EPA's Hugh Kaufman and Tri-Star. The study appears to vindicate Kaufman's statement that the fish are being protected in the ocean, the people of New York are being protected but the people of Texas are being poisoned. The study produced surprising and unintended results. According to the study, "[t]hough there have been numerous reports on pathogen survival in agricultural lands and waterways exposed to sewage sludges, there is surprisingly, only limited information on the occurrence of airborne microbial pathogens during sludge application."
"SALMONELLA spp (spores?) and pathogen indicators ... since hydrogen sulfide-producing bacteria (Salmonella, Citrobacter, Clostridium, Proteus, Edwardsiella and some Klebsiella species) have been shown to be associated with the presence of fecal contamination ... the PathoScreen medium ... was utilized as a presence-absence assay for detecting H2S (hydrogen sulfide) producers."
THESE RESULTS FURTHER CONFIRM THAT CLOSTRIDIA AND H2S PRODUCERS ARE BETTER INDICATORS OF AIRBORNE SEWAGE OR SLUDGE-DERIVED MATERIAL THAN TRADITIONALLY EMPLOYED BACTERIAL INDICATORS.
IT MUST BE MENTIONED THAT THE ABSENCE OF FECAL COLIFORMS AND FECAL STREPTOCOCCI IN THESE AIR SAMPLES IS IMPORTANT, CONSIDERING THAT THE LEVELS OF THESE INDICATOR BACTERIA IN THE SLUDGE PILES AT THE HOPPER LOADING SITE WERE 230,000 MPN (most probably number) Salmonella spp., and OVER 100 MILLION FECAL COLIFORMS, and 3.5 million MPN fecal streptococci per gram of wet sludge.
If those numbers are true, that is some pretty dangerous stuff they are spreading on ranchland. The coliforms are only 98 million above the regulated level. Salmonella is only 230,000 above the EPA's safe level for human contact. Streptococci is an unknown at this point. While it is generally associated with sore throats, it would appear that the streptococci bacteria may be one of the organisms that have mutated. On the cover of the February 29, 2000 issue of Proceedings of the National Academy of Sciences is a photo of the structure of streptococcal exotoxin. B (specB), a tissue-degrading virulence factor secreted by the human "flesh eating" bacterium. SpecB belongs to a new subfamily of cystine proteases which can kill within hours.
NSA researchers say, NEVER again can they (governments) claim the problem with Class B sewage sludge is just "odor". Now we know the truth... thanks to the LeSourdesville Health Hazard Evaluation by NIOSH (National Institute for Occupational Safety and Health) we also know that these fumes contain:
NIOSH reports "One location where a major amount of physical agitation of the sewage sludge occurred, had detectable levels of hydrogen sulfide producing bacteria and clostridium spp on three of the four days monitored at that site."
The question that begs to be answered is: Did the EPA Office of Water promote the use of sludge as a fertilizer for crops and home use knowing people would get sick and possibly die or was it all just a stupid mistake?
The Technical Support Document for composting (Occurence of Pathogens in Distribution and Marketing Municipal Sludges, (Yanko, 1988) indicates there was/is a serious problem with the regulation and Rubin's claims for safety of sludge use for crops and home use. Yanko states, "Although the use of sludge as a soil amendment is attractive, it is not without potential health risk. Toxic chemicals, including heavy metals and industrial organics may enter the food chain and present long-term health risks. Pathogenic mircooganisms present in sewage and the resulting sludges [E. coli (pathogenic strains), salmonella sp. Campylobacter jejuni, Yersinia, enterocolitica, Lepotospira spp.,Shigella spp. and bibrio cholerae] increase the potential for disease transmission." Yanko also statess, "Salmonellosis outbreaks that may have been initiated by infectious doses as low as 10-100 cells have been described in the literature. It would certainly appear imprudent to overlook moderate salmoneeae populations because of "convential wisdom" concerning infective doses."
The 1988 study also outlined the public health risk from pathogens. "The relative public health risk associated with the beneficial use of sludge is directly related to the extent of public exposure.----risks increases if the sludge is used on food crops or public access areas. ---The routes of exposure may take various forms, including handwork in gardens and eating uncooked vegetables, grown in sludge amended soils---Perhaps at the highest risk of ingesting pathogenic organisms are the very young children playing in yards and gardens that have been treated with sludge products.
Yanko also warns of the fungi that can be found in compost, "such as certain specious of Candida. Cryptocuccus and Trichosporon, and PATHOGENIC members of some filamentous genera, such as Aspergillus, Phialophora, Geotrichum, Trichophyton, and Epidermophyton." Also, "Parasitic infections present a potential health risk associated with home use of sludge due to the existence of highly resistant stages of the organisms and low infectious doses."
This is a study that was never widely circulated. The EPA only distributed a six page summary on microfisch to selected Land Grant College repository libraries.