Kennedy Krieger Soil-Lead Hazard Control Study
Funded by the Department of Housing and Urban
April 18, 2008

1. HUD awarded a lead technical study research grant to the
Kennedy Krieger Institute in Baltimore in 1999 to determine if
a low-cost treatment could be developed to reduce soil-lead
hazards in inner city neighborhoods that presented a high risk
of childhood lead poisoning.

2. The study was conducted in 2000-2001, and the results
were published in a peer-reviewed scientific journal in 2005.   
There is no evidence that families and their children were or
will be harmed as a result of the research.

3. The compost material used in this study was expected to
bind to lead and reduce the amount of lead that would be
absorbed by a child if the soil were ingested.  A thick grass
cover added further protection against direct contact with lead-
contaminated soil.

4. The compost used in this study has been approved without
restriction for residential and garden use as a fertilizer by the
U.S. Environmental Protection Agency, the Maryland
Department of Environment.  It is widely available for
residential use at many garden centers around the State.  The
material has been applied on the White House lawn, the
grounds of the Naval Observatory, Camden Yards and FedEx

5. The researchers worked with community organizations to
identify 25 residential yards in Baltimore neighborhoods at
high risk for lead poisoning for possible inclusion in the study.  
Nine lead-contaminated yards were selected based on the
highest levels lead in the soil.  The presence of children was
not a factor in selecting the homes.

6.  Families were not put at risk from the use or presence of
the compost.  

7. The material used is classified as a “Class A biosolid.” It is
composted with wood chips at high temperature killing any
disease-producing agents.  Lime is then added to it to control

8. The treatment is inexpensive compared to removal and
replacement of contaminated soil ($150-to-$350 vs.
thousands of dollars per home) and can be performed by low-
income home owners themselves.

9. Although not required by regulation, HUD asked the
researchers to conduct additional study to ensure the product’
s safety exceeded EPA standards and other, more stringent,
guidelines for biosolids applied to gardens.  The study
confirmed that the compost’s safety surpassed required
standards and guidelines.

10. There was and is no expectation of an adverse health risk
to families. The researchers obtained a review of the study’s
procedures regarding the protection of the health of the
children in these homes.  The review by one of the Institutional
Review Boards registered by the U.S. Department of Health
and Human Services’ (HHS’) Office of Human Research
Protection, a Board at the Johns Hopkins University School of
Medicine, assured that the study complied with the HHS’
regulations for the protection of the families.  Since there is no
expectation of adverse health risks, the Board did not require
health assessments prior to or following the intervention.

11. The researchers developed an informed consent form,
which was signed by an adult in each participating family.  This
consent form fully described the composition of the compost
and that it is approved for residential use by the Maryland
Department of Environment.

12. The study was successful in showing that the amount of
lead that would be absorbed if ingested (“bio-accessible lead”)
was significantly reduced for the soil with the highest lead
levels when tested one year after treatment.  Thick grass
growth was achieved, further reducing children’s lead
exposure risk.  In short, the study demonstrated the hoped for

HUD’s Office of Healthy Homes and Lead Hazard Control’s
mission is to eliminate childhood lead poisoning as a major
public health problem by 2010 nationwide.  The Centers for
Disease Control and Prevention reports that 310,000 children
had elevated blood lead levels in 2002, down from 890,000
children in the early 1990s, as a result of Federal, state, local
governmental, and private sector efforts.  The Office
implements public outreach, regulatory enforcement, and
grant programs.  The Office’s competitive lead research
program is conducted as required by the Residential Lead-
Based Paint Hazard Reduction Act of 1992 (“Title X”),
including the requirement for HUD to “conduct research on
strategies to reduce the risk of lead exposure from other
sources, including exterior soil” and to “develop improved
methods for reducing lead based paint hazards in housing,”
which include soil-lead hazards.
The Kennedy Krieger Soil-Lead study is an example of the EPA/USDA program to get
third party scientists, who know nothing about EPA's own research or the law, involved
as proof that sludge is safe. How could they know about the"(14) BLM policy opposing
use of biosolids on Federal lands: equating it(s) use to hazardous waste dumping and
landfilling raising SUPERFUND liability concerns."

1.  The HUD research grant appears to be a part of the EPA/USDA/CDC program to
find a cheap way to dispose of an RCRA hazardous solid waste -- sludge -- containing
carcinogens and other unknown chemical pollutants under the federal agency's
national policy. Yet, Federal law requires you "Have qualified professionals do lead
clean up work. "There are standards in place for certifying lead-based paint
professionals to ensure the work is done safely, reliably, and effectively."

2.  No research does not equate with no harm from: Part 503.9(t) Pollutant is
an organic substance, an inorganic substance, a combination of organic and
inorganic substances, or a 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 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 (humans) or
offspring (children) of the organisms.

3. The organic material and other carcinogenic aerosols in compost may
be more dangerous than ingested lead. In 1989, EPA identified 21 known
carcinogens in sludge. Five were known to be carcinogenic when inhaled:
Arsenic, Beryllium, Cadmium, Chromium 6, and Nickel based on sufficient
epidemiological evidence.

HEALTH. EPA states: 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.
Dispersion of secondary
pathogens such as Aspergillus fumigatus, particulate matter,other airborne allergen

5.  children were not a factor?

6. EPA  says that if you are exposed to the pollutants (503) in compost they could
cause death, disease, cancer, etc -- Congress (RCRA) said that is a hazardous

7. Biosolids is not a legal term. Class A refers to the reduction of a single high
temperature strain of E. coli to less than 1,000 per gram that only grows at 112
degree F. in the laboratory test.  EPA's original compost studies show disease
producing agents are not killed. Lime only inactivates some disease causing agents
for about 30 days and turns chromium 3 into the highly carcinogenic Chromium 6.

8. Dumping hazardous solid waste on lawns is not inexpensive when you consider
hospital cost these days. You also have to consider that some of the compost may
be too contaminated with arsenic, chromium and nickel to be disposed of in a Part
503.23 landfill (monofill)

9.  Due to the fact that pathogens are not killed and the carcinogens are not
considered in Part 503, Sludge is a hazardous waste under RCRA and a pollutant
under CWA -- and -- this is only legal if you consider sludge to be a commercial
fertilizer under the Superfund Act (CERCLA). This was noted in the 1979 sludge
waste regulation 257.3.5(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).

10.  EPA's original compost study states: "Although the use of sludge as a soil
amendment is attractive, it is not without potential health risks. Toxic chemicals,
including heavy metals and industrial organics, may enter the food chain and
present long-term health risks."
significant increases in bacterial populations,
including salmonellae, occurred during subsequent production of commercial soil
amendment products.

The children were not considered.

11. It would appear the informed consent was based on "a composite sample of the
OrgroR applied to each yard was collected prior to its application to test for metal
concentrations (As, Cd, Cr, Cu, Ni, Pb, Zn)."
 The composition was not described.
Part 258 lists 220 hazardous constituents including: Antimony, Arsenic, Barium,
Beryllium., Cadmium, Chromium, Cobalt, Copper, Cyanide, Lead, Mercury..,
Nickel., Selenium., Silver, Thallium, Tin, Vanadium, Zinc.

12.   The study assumes a lot based on lab tests. A 12 to 30% reduction in
bioaccessibile Pb does little to help the children. "OrgroR application was associated
with a 12–30% decrease in bioaccessible Pb concentration at each sampling line
immediately after treatment (Table 3). At 1-year follow-up, reductions in bioaccessible
Pb concentrations compared to those before soil treatment (pretilling) were 64% for
Line 1 (from 1655 to 595 mg kg1) and 67% for Line 2 (from 1381 to 453 mg kg1). At
1-year follow-up, little or no reduction was found in mean bioaccessible Pb
concentrations compared to pre-tillage at Line 3 (from 620 to 764 mg kg1) and Line 4
(from 436 to 425 mg kg1)."
Not only that, but at a 1 in 20 ppm leach rate from total metals to TCLP
hazardous level these people live on a hazardous waste Superfund site.

You have to consider that EPA and USDA's National Policy mission has
been to disposed of sludge with the least amount of regulation with little
regard for law and none for human health. As a partner, CDC gets to play
the numbers game and these are suspect since these partners agreed to
dump sludge as close to humans and their food chain as possible in the
earlier 1980s. Since EPA published the part 503 policy "regulation" food
poisoning has jumped from two million case in 1986 to 81 million cases in
1997.   In 1999 (Mead, (CDC) estimates there are only about 76
million foodborne cases annually, 325,000 Hospitalized and 5,000 deaths.
CDC still uses these figures which = 6.3 million illnesses per
month,  27,000 people hospitalized each month, 416 dead each

Lets not forget the epidemics/pandemics raging through this country now that
correspond to the same timeframe as the sludge policy!
Baltimore -- Kennedy Krieger Soil-Lead Hazard Control Study -- Funded by the Department of Housing and Urban
Development April 18, 2008 --
April 22, 2008 review by Jim Bynum, Retired Safety Consultant -- VP Help for Sewage Victims

Congress has always been very clear about its intent: "(1) it is the national goal that the discharge of pollutants into the navigable waters
be eliminated by 1985." "(3) it is the national policy that the discharge of toxic pollutants in toxic amounts be prohibited;" (Title 33, part

The EPA has actually promoted the use of toxic sewage sludge on lawns, gardens and food crops: by statement (1981), by policy (1984),
and by regulation (1993). (EPA report SW905, WH-595, 40 CFR 257 et al./503)