National Sludge Alliance
Charlotte Hartman, National Coordinator
180 Boston Corners Road
Millerton, NY 12546
(518) 329-2120 (phone/fax)
email: chartmannsa@taconic.net
NSA Public Fact Sheet 129
EPA Underplays Danger to Farmers and Public
4/14/2002
The National Sludge Alliance (NSA) has called for an immediate ban on sludge
use in any form. Based on new research, it is evident that sludge used as a
fertilizer is an eminent danger to the environment, farmer, food consumer.
The EPA scientists involved in selling sludge and their partners could not
sell, give away, or pay enough to get a farmer to use sludge, if the farmer
knew the truth. Sewage sludge carries enough pathogens, which are
subject to explosive regrowth, to wipe out his farm and family.
While these EPA scientists have assured the farmers and regulators sludge is
safe, if all the rules work, that is not the case. In the RCRA, Congress
explained what a hazardous waste is and can do to human health. Under
the Clean Water Act, Congress explains what a toxic pollutant is and that the
EPA
Administrator has documented what they can do to human health. (CWA)
Sec.1362. –
Definitions —
“The term ”toxic pollutant” means those pollutants, or combinations of
pollutants, including disease-causing agents, which after discharge and upon
exposure, ingestion, inhalation or assimilation into any organism, either
directly from the environment or indirectly by ingestion through food chains,
will, on the basis of information available to the Administrator, cause death,
disease, behavioral abnormalities, cancer, genetic mutations,
physiological malfunctions (including malfunctions in reproduction) or
physical deformations, in such organisms or their offspring.”
It would appear that legislators, regulators, lawyers, scientists, and farmers
who have read the definition assume that “organisms” refers to very
small creatures of the soil such as bacteria and worms. However, according to
the official definition: “Organism: [is] any form of animal or plant
life.”
In effect, even legislators, regulators, lawyers, scientists and farmers are
“organisms”.
According to the EPA Environment Terms: “Pathogens: [are] Microorganisms
(.g., bacteria, viruses, or parasites) that can cause disease in humans,
animals and plants. ” Many of the pathogens could be used for
bioterrorism activities, including food contamination.
In 1989, EPA was fairly honest when it explained the problem it was having
with sludge disposal: “Wastewater treatment processes remove pathogenic
organism [and carcinogenic toxic/hazardous substances] from wastewater, not so
much by destroying them as by concentrating them in the residuals sludge
streams. Because sludge volume is much smaller than wastewater volume,
concentrations of pathogens [and carcinogenic toxic/hazardous substances] on
a volume basis are much higher in sludge than in the original wastewater. The
increased pathogen [and carcinogenic toxic/hazardous substances] content of
sludge makes it essential that the Agency require processing and other
procedures that minimize exposure of humans and animals to infectious
organisms [and carcinogenic toxic/hazardous substances] in sludge.” (54
FR 5829)
In the 1989 preamble to part 503, EPA made it very plain that it created a
list of primary pathogens based on a literature review. The pathogenic
organisms in Table IX-F.1 were included because they: “(1) are associated
with a high incidence of disease. (2) Are found in high concentrations in
sewage
sludge. (3) Exhibit resistance to environmental stresses [they don’t die off
easily]. (4) Can be detected with available methods, and (5) exhibit low
infectious does.” (58 FR 5829)
The following excerpt from a paper published by the New Mexico Environmental
Department, February 1993, shows the general state of
the information available to the public at that time:
“The EPA’s own research, which is stated in the preamble to the new
proposed (Coded Federal Regulation Section 40, Parts 257 and 503) sludge
regulation, has documented in addition to the toxic heavy metals, a list of 25
primary pathogens in sewage sludge. Among these are: 1) five bacteria
pathogens (Campylobacter juni, Escherichia coli, Salmonella, Shigetla, and
Vibrio Cholerae), 2) nine viruses pathogens (Entroviruses, Poliovirus,
Coxsackieviruses, Echovirus, Hepatitis A, Norwalk and Norwalk like viruses,
Reovirus, and Rotavirus), 3) five helminthes pathogens (among them are
Hookworms, Tapeworms, and Nematode worms), 4) five protozoan pathogens (Toxoplasma
gondii, Balantidium, Entamoeba histolyca, Giardia lambia, and
Cryptosporidium), and 5) one fungi pathogen (Aspergillus).
Most of these pathogens are very deadly to humans and animals. Although the
bacteria pathogens Campylobacter Jejuni and Escherichia coli primarily
cause a relative mild case of diarrhea [this was true in the 1980s],
Salmonella, Shigetla and Vibrio cholera affect the gastrointestinal tract and
can be fatal. Of the nine viruses, Entroviruses or Picornaviruses (152
species) pathogens can cause gastrointestinal problems, respiratory problems
and can also be fatal. Poliovirus (3 species) pathogens cause inflammation of
the gray matter of the spinal cord. Coxsackievirus A (23 species), B
(6species) pathogens are mostly mild, but they can cause inflammation of the
heart in newborns. While Echovirus (31 species) pathogens primarily cause
inflammation of the heart, spinal cord and brain, Hepatitis A virus pathogens
cause liver problems and can lead to death. Norwalk viruses and Norwalk like
virus pathogens cause mostly diseases of the gastrointestinal tract and
Rotavirus causes acute gastroenteritis.
The five Helminthes
pathogens (primarily, Hookworms, Tapeworms and Nematode Worms) cause damage to
vital organs, brain, retina vessels, liver,
lung and heart. The five Protozoan pathogens cause intestinal,
respiratory, and liver problems. The one fungi pathogen, Aspergillus,
causes inflamed
tissues in bronchi, lungs, aural canal, skin and membranes of the eye, nose or
urethra (Federal Register (FR), 54, P.5829 & Thomas 1988).”
According to the EPA’s Office of Research and Development (ORD) (1999), if
sludge with any of these pathogens in it is applied to land or placed on a
surface disposal site where humans and animals could be exposed, it is
probably being illegally applied.
There is serious implication here because EPA document references show that
since 1986 it has known bacteria and viruses can survive up to 1 year in
soil. The general survival period is 2 to 12 months for bacteria and 3 to 12
months for viruses.
What is perhaps more serious
is that the survival time on food crops and other plants.
According to EPA ORD, general survival times for bacteria on
plants are 1 to 6 months and for viruses it is 1 to 2 months. For
Helminthes ova the survival time on plants is 1 to 5 months — with a 2 to 7
year
survival time in the soil..
As of 1999, ORD still had no data on the survival time of Giardia cysts and
CRYPTOSPORIDIUM oocysts.
Exposure to pathogenic and carcinogenic toxic/hazardous substances could
either be direct or indirect
DIRECT CONTACT:
- touching the sewage sludge.
- Walking through an area — such as a field,
forest, or reclamation area — shortly after sewage sludge application. - Handling sludge from fields where sludge has
been applied. - Inhaling microbes that become airborne (via
aerosols, dust, etc) during sewage sludge spreading or by strong winds,
plowing, or cultivating
the soil after application.
INDIRECT CONTACT:
- Consumption of pathogen-contaminated crops grown on sewage
sludge-amended soil or of other food products that have been contaminated by
contact with these crops, or field workers, etc. - Consumption of pathogen contaminated milk or other food
products from animals contaminated by grazing in pastures or fed crops grown
on sewage sludge-amended fields. - Ingestion of drinking water or recreational
waters contaminated by runoff from nearby land application sites or by
organisms from sewage sludge migrating into ground water aquifers. - Consumption of inadequately cooked or
uncooked pathogen-contaminated fish from water contaminated by runoff from a
nearby sewage sludge application site. - Contact with sewage sludge or pathogens
transported away from the land application or surface disposal site by
rodents, insects, or other victors [birds & farm workers], including grazing animals and pets.
Dr. David W.K. Acheson, MD, FRCP, Associate Professor in the Department of
Epidemiology and Preventive Medicine, University of Maryland School of
Medicine, says, “More than 200 known diseases are capable of being
transmitted through food. [1] Thus, no simple algorithm can be used to
diagnose foodborne illness, ”
Furthermore, “Foodborne disease has many
different forms, involving a variety of bacteria, viruses, protozoa,
chemicals, and other types of agents that can
be transmitted through consumption of food. Although foodborne illness
typically presents with gastrointestinal symptoms, including nausea,
vomiting, abdominal pain, and diarrhea, it is important to remember that these
diseases can present in very different ways. Such manifestations
include fever, neurological symptoms (eg, headaches, paralysis, or paresthesia
(tingling), hepatitis, or renal failure.”
A recent media article mentioned that Russia had about 300 verities of
bacteria in its biowarfare program. Yet, EPA only mentions nine strains in
sludge. –LSI-