Sewage Sludge
                          Hazardous Solid Waste

By Jim Bynum                                                                                                                8/11/2007
Retired Safety Consultant

The federal government owns some 264 million acres of land, but it claims we are running out of landfill space.
Due to a few government employees, requirements for some solid waste referred to as biosolids has to be diverted
from landfills to farmland, school grounds and home lawns. State laws have been revised to reflect the
government employees view that sewage sludge is not a hazardous or solid waste,  rather than comply with
federal law..

Prior to 1993, EPA could not legally use the term biosolids as a synonym for the
RCRA solid waste -- sewage
sludge. Nor could EPA use the term biosolids as a synonym for the CWA pollutants -- solid waste, sewage and
sludge.   The term biosolids is still not used in EPA regulations. However, today, biosolids has become the generic
name for any contaminated waste that is regulated or difficult to dispose of in safe manner.  Under EPA policy, by
calling the contaminated waste biosolids, and disposing of the waste as a fertilizer or soil amendment, on grazing
land, food crops, school grounds and home lawns, there is no requirement to comply with federal law or any
enforceable federal standard.

Examples are radioactive Superfind waste, PCBs and Cadmium.  Cadmium contaminated solid waste (biosolids)
applied to land under
part 257.3-5  is more restricted. A facility or practice concerning application of solid waste
to within one meter (three feet) of the surface of land used for the production of food-chain crops shall not exist
or occur, unless

(1)(i) The pH of the solid waste and soil mixture is 6.5 or greater at the time of each solid waste
application, except for solid waste containing cadmium at concentrations of 2 mg/kg (dry weight) or less.
(503.13 has no pH requirement and allows  85 mg/kg)

(ii) The annual application of cadmium from solid waste does not exceed 0.5 kilograms per hectare
(kg/ha) on land used for production of tobacco, leafy vegetables or root crops grown for human
(503.13 allows Cadmium...................................................   at       1.9 kilograms per hectare)

(b) Polychlorinated Biphenyls (PCBs). Solid waste containing concentrations of PCBs equal to or
greater than 10 mg/kg (dry weight) is incorporated into the soil when applied to land used for producing
animal feed, including pasture crops for animals raised for milk. Incorporation of the solid waste into the
soil is not required if it is assured that the PCB content is less than 0.2 mg/kg (actual weight) in animal
feed or less than 1.5 mg/kg (fat basis) in milk.
( 503 allowed rate is 50 mg/kg - unregulated)

In 1995, John Stauber and Shelton Rampton reported how the term biosolids name change was a public
relations ploy to dispose of sludge as a beneficial fertilizer by the Water Pollution Control Federation. Since there
was no longer any interest in pollution control, the federation dropped pollution control from its name and became
the Water Environment Federation (WEF).

EPA Office of Water and WEF had to highjack the law and science to create the biosolids fertilizer program. .
The law is  firm: ``solid waste'' means any garbage, refuse, sludge from a waste treatment plant,
water supply treatment plant, or air pollution control facility."

"Sludge means any solid, semi-solid, or liquid waste generated from a municipal, commercial, or industrial
wastewater treatment plant, water supply treatment plant, or air control facility exclusive of the treated
effluent (semi-clean water) from a wastewater treatment plant." (Public Laws. (1987).

If there are any chemical, or infectious characteristics in the sludge that may--(A) cause, or significantly
contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or
(B) pose a substantial present or potential hazard to human health or the environment when improperly treated,
stored, transported, or disposed of, or otherwise managed, then it is a hazardous waste.

In a
recent study of anaerobically digested solids from seven wastewater treatment facilities, counts of fecal
coliform bacteria increased after dewatering at four of the facilities tested. Immediately after centrifugation, fecal
coliform counts increased from very low or nondetectable levels, often by as much as several orders of
magnitude, at the four facilities where increases were observed.

1981 World Health Organization study found a direct Salmonella infection cycle from humans, to biosolids,  to
cattle, and back to humans. The
deaths of three children have been directly tied to biosolids disposal site. One
neurological study directly ties a
family's neurological damage to biosolids. One study by EPA microbiologist
David Lewis found high levels of
staph infections in neighbors of biosolids disposal site.

According to WEF, biosolids are "solid materials resulting from wastewater treatment that meet government
criteria for beneficial use, such as for fertilizer."

The EPA criteria is simple, it requires that sewage sludge used for fertilizer be generated from domestic sewage,
which only comes from humans or household operations. While it doesn't quite fit with the law, the wording is
503.9 (w) "Sewage sludge is solid, semi-solid, or liquid residue generated during the treatment of
domestic  sewage in a treatment works." 503.9(g) "Domestic sewage is waste and wastewater from humans or
household operations
that is discharged to or otherwise enters a treatment works". Under RCRA, it is a solid

Part 503 also acknowledges that if industrial
inorganic or organic chemical pollutants and hospital pathogen
contaminated waste is in the sludge it is a
hazardous waste. As an example, 503.13 lists nine pollutants. Two
of the pollutants would prohibit the disposal of sludge within 75' of a permitted surface disposal landfill's boundary
503.32  talks about Pathogens such as Salmonella and a fecal coliform level of 28 thousand (1,000 x 28
gram) most probable number of E. coli bacteria per ounce of Class A sludge as a safe level.  Class B sludge allows
56 million E. coli per once of sludge. Salmonella is one of the pathogenic
coliform   as is the deadly E. coli ,
is the primary fecal coliform detected in the color coded test under UV light.  EPA does not address
bacteria and viruses that require a high level of disinfection or fungus or the drug resistant and necrotizing
factors transferred during sewage treatment and
rampaging through the community.

EPA does follow the CWA and RCRA toxic pollutant and hazardous waste guide line warning in part
503.9(t), by
stating  that exposure to the nine pollutants and unknown number of disease organisms in sludge through air,
water or food could cause death, disease and  cancer as well as cause mental and physical problems. Under
RCRA, it is a hazardous waste. How can the bacteria, viruses and fungus be safe in our
air, food and water as
well as on play grounds and lawns, when they must be handled with Biosafety level 2 practices in a certified

The San Diego Metropolitan Wastewater Department who accepts industrial chemicals and hospital waste
understood the first part of the criteria for Biosolids and claims there is no industrial chemical waste in theirs,
Biosolids: "Nutrient-rich, organic material generated from household waste, removed during the
treatment process. Once digested and dewatered, the material, called Biosolids, can be beneficially recycled".

Even the state of Missouri understood that biosolids are generatered from domestic household wastewater and if
the biosolids couldn't be disposed of in a part
503.23 surface disposal landfill, it can not be biosolids.
Biosolids: "Organic fertilizer or soil amendments produced by the treatment of domestic wastewater. Biosolids
consist primarily of dead microbes and other organic matter. Untreated sludge or sludge that does not conform to
regulated pollutants and pathogen treatment requirements are not considered biosolids".

Since there are very few treatment plants that only treat domestic wastewater from humans and households, the
San Bernardino County Fire Department, Hazardous Materials Division has the definition right: Biosolids: Residuals
generated by the treatment of sewage, petroleum refining waste and industrial chemical manufacturing wastewater
with activated sludge.
See Activated Sludge.

Sam Hadeed, National Biosolids Partnership Technical Communications Director  has taken the lead in trying to
fool the public. Hadeed said, "Efforts to communicate with concerned individuals, groups and institutions should
include discussion of the quality standards for safe biosolids management, which are based on protective
assumptions about the impact of biosolids on the environment, animals crops, and humans. However, these
messages must be presented with an empathetic approach that acknowledges and speaks to the underlying
emotional issues, even if these issues appear to have no valid scientific basis. Careful and genuine listening will
enable you to discern what people are really saying and thinking, and respond credibly to their concerns. Biosolids
managers should understand thoroughly the information they provide in response to citizens' concerns and be
prepared to explain this information in as much detail as their audience needs. "

Virginia  did not understand the sludge science, or lack of a risk assessment, and repeats the lies when it states,  
"Furthermore, EPA conducted a comprehensive risk assessment for
pollutants in biosolids that are land applied.
The risk assessment evaluated risks to human health as well as ecological risks (to animals and plants) through 14
exposure pathways for land application. Current regulations based on the risk assessment, set forth conservative
pollutant limits and other requirements that protect public health and the environment."

Sam Hadeed has been involved in
EPA'S PUBLIC RELATION CAMPAIGN since it began in 1994 to debunk
certain situations and victims of sludge biosolids health and property damage. The sound science and protective
assumptions used by EPA, WEF and the National Biosolids Partnership was explained in the
1995 Guide to the
Part 503 Risk Assessment which stated on page 110, EPA did not include any organic chemicals in the risk
assessment and did not consider any inorganic (heavy metals) to be cancer causing agents for the purpose of the
biosolids risk assessment.  EPA employees behind the PR program ignored the
1989 documented list of cancer
causing agents in biosolids. There was no pathogen risk assessment for 1989 documented list of pathogens in
biosolids. Four of the pathogens are on the document list of disease causing

EPA acknowledges that Biosolids Compost may be hazardous to your Health in the
2006 Biosolids
Technology Fact Sheet:  Use of Composting for Biosolids Management

  • Potential environmental impacts may result from both composting operations and use
    of the compost product

  • Composting is not a sterilization process and a properly composted product maintains
    an active population of beneficial microorganisms that compete against the
    pathogenic members. Under some conditions, explosive regrowth of pathogenic
    microorganisms is possible.

  • In addition to odors, other bioaerosols, such as pathogens, endotoxins, and various
    volatile organic compounds, must also be controlled

  • Survival and presence of primary pathogens in the product.

  • Dispersion of secondary pathogens such as Aspergillus fumigatus, particulate matter,
    other airborne allergens

  • The spores of A. fumigatus counts at composting facilities are high, and-- persons
    handling composted biosolids being exposed to these spores is also high (Epstein,

  • While healthy individuals may not be affected, immunocompromised individuals may
    be at risk.

  • These organisms can potentially invade a normal, healthy human being and produce
    illness or debilitation

The description makes compost a hazardous waste under RCRA.

What you are not told by EPA's Office of Water.

Lead in biosolids is even more dangerous to children than adults because:  

  • Babies and young children often put their hands and other objects in their mouths.  These
objects can have lead dust on them.  

  • Children's growing bodies absorb more lead.  

  • Children's brains and nervous systems are more sensitive to the damaging effects of lead.

If not detected early, children with high levels of lead in their bodies can suffer from:  

  • Damage to the brain and nervous system  

  • Behavior and learning problems (such as hyperactivity)  

  • Slowed growth

  • Hearing problems

  • Headaches

  • Children's brains and nervous systems are more sensitive to the damaging effects of lead.

That also describes a hazardous waste under RCRA.