Press Release

COMPOST STUDY FACT SHEET

Kennedy Krieger Institute & Johns Hopkins Bloomberg School of Public Health

Summary of Biosolids Compost Study to Reduce Lead Hazards
For Immediate Release: April 21, 2008

Recent media coverage has reported that researchers spread “sludge” or
“human and industrial waste” on the lawns in neighborhoods in East Baltimore.
W hat is referenced in these stories is in realityEckology/Orgro Class A compost
that is a commercially available from the Baltimore City Composting Facility. The
product is used by topsoil manufacturers, nurserymen, contractors, landscapers,
golf courses, and commercial growers throughout Maryland, the District of
Columbia, Virginia, West Virginia, Pennsylvania and New York. Unlike the forms
of “sludge” referenced as causing harm in many of these articles, Class A
compost is tested every two months to ensure it meets MDE requirements for low
levels of metals like lead. This composting process also kills germs in
Eckology/Orgro.


This exact same product is used on President’s lawn at the White House, the
grounds of the Naval Observatory where the Vice President resides, sport
stadiums, golf courses, as well as the lawns and gardens in private residences.

Further, the neighborhoods focused on in the study were those that were known
due to lead levels reported to the city and state. This study was in direct response
to those communities that were most heavily impacted by lead poisoning and
was trying to give the community a means to reduce one source of lead exposure.
The following are some of the key questions and issues that have been raised by
various individuals and organizations:


1. What problem did the study address?

Soil on the property associated with approximately 7 percent of U.S. housing has
lead concentrations above U.S. EPA and HUD standards. Most of these cases of
lead contamination are clustered in urban areas such as Baltimore City. One
source of lead that causes intoxication is the soil around homes. The
compost study sought to address this epidemic of lead poisoning among
children in our surrounding community. The compost study tried to find effective
ways to prevent lead poisoning. Treating the soil with compost had been shown
to be effective in industrial towns but not in urban residential settings. Urban
soils are commonly contaminated with lead from multiple sources, principally
automotive emissions, exterior paint, and stack emissions. No government
programs exist to remediate lead in such soils unless an industrial source
caused the contamination. A copy of the abstract of the article on the study is
attached.



2. Why not have the contaminated soil removed?

Although it is possible to remove all contaminated soil, governmental agencies
and landowners have generally decided the cost of soil replacement is
prohibitive in all but the most grossly contaminated cases. Only properties
adjacent to Superfund sites have been recommended by EPA and HUD for soil
replacement.

3. What was the study?

Compost can reduce the likelihood that lead will be digested and absorbed by
the bloodstream, i.e., previous research had shown that biosolids compost can
reduce the bio-availability and bio-accessibility of lead in the soil. Researchers at
the Kennedy Krieger Institute (KKI) received funding from the U.S.
Department of Agriculture and U.S. Department of Housing and Urban
Development to conduct a field study (abstract attached) to better understand
how the use of the biosolids could reduce lead levels in residential yards in a
community where there was high level of lead in the soil. The idea for the study is
that trapping the lead in the soil would reduce lead exposure to children.

4. When was the study conducted?

The Johns Hopkins University (JHU) Institutional Review Board (IRB) reviewed
and approved the study in 1999 and the compost was applied between June and
September 2000. The study results were published in Science of the Total
Environment, Vol. 340, 2005.



5. What was the study design?

Working with local community organizations (Middle East [Baltimore] Community
Organization and Historic East Baltimore Community Action Coalition) and
residents during the study design, 25 residential yards in the East Baltimore
Empowerment Zone were reviewed for inclusion in the study. Based on the
study design, nine of these yards met selection criteria of moderate to high levels
of lead in the soil.

6. What community organizations were involved in the study?

The published study in Science of the Total Environment acknowledged the
involvement of various community leaders and partners including Lucille Gorham
(Middle East [Baltimore] Community Organization); Bea Gaddy (Bea Gaddy’s
Women and Children’s Center); Jeff Thompson (Historic East Baltimore
Community Action Coalition); Leon Pernell (The Men’s Center); and Justine
Bonner (Open Space Committee, Sandtown-W inchester Community Building in
Partnership).

7. What was Kennedy Krieger and Johns Hopkins involvement in the study?

The principal investigator in the study had a joint appointment at Kennedy Krieger
Institute and the Johns Hopkins University School of Public Health. In addition,
the Johns Hopkins University IRB reviewed and approved the study in 1999. The
co-authors of the article reporting on the study included staff from the
U.S. Department of Agriculture and the U.S. Department of Housing and Urban
Development (see abstract attached).

8. What was the result of the study?

The study showed significant reductions in the lead level in the treated yards,
providing a safer environment from the lead hazard for the families who
participated in the study.



9. What is the biosolid compost that was used in the study?

The study selected Eckology/Orgro High Organic Compost (Orgro). To create
Eckology/Orgro, municipal biosolid from a Baltimore City wastewater treatment
plant is composted with woodchips and sawdust.
The compost is “cured” for
several months to assure that pathogens are reduced to nondetectable levels.

The Maryland Department of the Environment and US EPA regulations require
testing of the stabilized compost to ensure it meets quality parameters, such as
pathogen control to ensure disease-causing organisms are at a safe level and
heavy metals contained in the compost are below maximum allowable
concentrations.












10. Where is Eckology/Orgro obtained?

Eckology/Orgro is sold in bulk to topsoil manufacturers, nurserymen, contractors,
landscapers, golf courses, and commercial growers throughout Maryland, the
District of Columbia, Virginia, West Virginia, Pennsylvania and New York.
ECKOLOGY/ORGRO is available from the Baltimore City Composting
Facility. The Baltimore City Composting Facility began operations in 1988 and
produces approximately 75,000 cubic yards of compost per year.













11. Are there legal or regulatory limits to Eckology/Orgro use?

No. Eckology/Orgro is approved by the U.S. EPA and the Maryland Department of
the Environment for unlimited use in lawns and gardens as a soil
conditioner/fertilizer. During the 1990s, more than 350,000 cubic yards of
Eckology/Orgro were sold for commercial and home use in the Baltimore region.
It remains widely available today. It should be noted that the Greening Committee
of the Historic East Baltimore Community Action Coalition has applied biosolid
compost to yards and gardens as part of local beautification efforts prior to this
study.











12. Did you provide information about the compost to the families in the study?

The consent form that was signed by all study participants included great detail
on the compost utilized in the study. The consent form for those having compost
added to their yards contained the following statement:
“Eckology/Orgro compost
is made from sterilized Baltimore sewage sludge mixed and composted with
wood chips and saw dust.
Eckology/Orgro compost is licensed and approved by
the Maryland Department of the Environment for distribution to the general public.
Eckology/Orgro compost is tested every month to ensure that it meets MDE
requirements for low levels of metals like lead.
The composting process used to
make Eckology/Orgro kills germs.”
It should also be noted that the compost
is currently approved as safe for use by the EPA and the Maryland Department of
the Environment. And the vast preponderance of scientific opinion shows that
Ecklogy/Orgro Class A compost did not then and does not now pose a known
threat to human health.



13. Do you feel that the use of Eckology/Orgro exposed the families and their
children to added risk?

No. The product was, and currently is, approved as safe for use by the EPA and
the Maryland Department of the Environment.
As science-based organizations,
KKI and JHU understand that new questions frequently arise about old studies
. If
there is credible evidence that the compost in question poses a health problem,
that certainly is worthy of study by experts in the field of bio solids.
This study was
not designed to conduct assessments of any risk of using the compost as this
commonly used product is approved for commercial and home use
. Previous
studies had demonstrated that the compost used in the study was effective in
reducing lead dust levels and studies on rodents and pigs had also
demonstrated its safety.
The purpose of the KKI study was to assess by how
much and how efficiently the product could help reduce lead dust in soil around
homes and it
ultimately proved highly effective in this regard.



14. Why did you not disclose the potential hazards of the exposure to the
compost?

We didn’t disclose potential hazards to the Ecklogy/Orgro Class A compost,
because at that time (and now) there were no known hazards.


15. Where were the homes located? Why did the study target those specific
areas?

The compost study was a direct response to community needs. The homes were
located in East Baltimore Empowerment Zone and the area was selected
because they were known to have dangerous levels of lead in the bare soil
around homes. Records from the city, state, and KKI's own lead clinic
consistently showed that these were the neighborhoods where the highest
incidences of elevated blood lead levels were being reported. It was the aim of
the research to learn how much this risk could be reduced for these families. It is
important to bear in mind that Baltimore City was in the midst of an epidemic of
lead poisoning and the compost study was a successful response to this huge
problem affecting our community.

16. Were these areas chosen because of planned redevelopment, which
would relocate the inhabitants, thus making it more difficult to find them if
questions were asked afterward?

Absolutely not. The residential areas were selected because they were known to
have dangerous levels of lead in the bare soil around homes. The KKI clinic that
treated children with lead poisoning was seeing about 1,000 children a year from
the community. It was the aim of the research to learn by how much this
risk could be reduced. Researchers could tell if the Orgo product worked in a few
months by measuring how easily the lead in the soil came out. There was no
need to follow the people who lived in the house to answer the research question.





17. What educational efforts were undertaken to alert the families of the
potential risk of the lead dust levels in the surrounding soil?

The study included extensive educational materials for the participating families
addressing lead prevention and reduction techniques for lead dust transmission
from soil around their homes and for lead dust exposure in their homes.
Additionally, letters that were mailed to families after the testing of their soil
were explicit in explaining the level of risk that the lead dust their yards posed and
provided numerous resources to help them address the problem.

18. Were the children living in the houses in the study tested?

At the time the study was designed, lead poisoning was a widespread threat that
was well known to exist. Health departments in Baltimore and other cities, along
with lead exposure clinics in hospitals, including KKI, were taking action. The
focus of the study was the soil around houses and not the people who may
have been living in the houses. Some of the houses may not have had any
children living in them at all. All children in Baltimore get tested for lead levels by
their primary care physicians. Their primary care physician is in the best position
to make decisions about risks from lead and need for any treatment. Any
information from the study would not have made a difference in the decision
about whether or not to treat a child for high levels of lead. Further, we didn’t test
children for any potential hazards related to the Ecklogy/Orgro Class A compost,
because at that time (and now) there were no known hazards.

19. Why were the children living in the houses not tested?

The study involved the measurement and extent of the effectiveness of the
compost in reducing lead dust in the soil. The compost proved to be an effective
tool and provide healthy grass growth that further reduced soil from being tracked
into nearby homes. KKI was aware that the study area was one where
children with high lead levels lived and many children from this and surrounding
areas were already being treated at KKI.

20. Why were the children not removed from the homes?

In Baltimore City and across the nation, it was recognized by public officials at all
levels that it was not feasible to remove all persons from lead contaminated
homes. In response, this study was designed to reduce one potential exposure
to lead in the soil surrounding these homes. Ultimately, the study was successful
in reducing the amount of lead dust in the soil. In addition, since this commonly
used compost product was, and is, approved for commercial and residential use,
there was no perceived risk from the Eckology/Orgro that would necessitate
removal of these children from their homes.

21. The article concludes that compost can provide “a simple low-cost”
technology for parents and communities “to reduce risk to their children.”

Why, if it provided such a benefit, is it necessary to protect their identities?
The consent form describing the study protocol, which was signed by all
participants, specifically promised to keep certain information confidential,
including their identities, those of their families, and their addresses.

22. What sort of follow-up was done to determine whether there were any
long-term health risks from exposure to the compost?

The use of this compost material was, and is, acceptable and even encouraged
by prominent scientists in the field. As noted above, the study was not designed
nor given the funds to determine long-term health risks of the compost or lead in
the soil. This study did not test children or families, nor was it designed to
conduct assessments of any risk of using the compost as this commonly used
product is approved for commercial and home use.


















23. Who explained the consent forms to the families?

As always in such studies, a qualified member of the study team reviews the
consent form with all consenting parties to ensure their understanding of the
study. Study participants were given the chance to ask any questions about the
study and take as long as they wanted to make the decision.

24. Did the local community support the compost soil study?

At the April 12, 2000 Historic East Baltimore Community Action Coalition
(HEBCAC) community meeting, Dr. Farfel briefed the community representatives
on the study and distributed related materials. After several questions from
community members, the HEBCAC Greening Committee formally approved the
study.
Response to Press Release                                                   4-24-2008

Baltimore Compost Study in poor neighborhood -- Fact Sheet Review

Jim Bynum, Retired Safety Consultant, VP, Help for Sewage Victims

Lead is a hazardous substance at 5 (five) parts per million (ppm) (mg/kg) (mg/l)

Media coverage has failed to report that "sludge" or "human and industrial waste" is in fact a
municipal solid waste by federal law. The
1989 EPA list of 21 known carcinogens in
sludge makes it a hazardous solid waste under
RCRA. The toxic pollutants in sludge make
It  a pollutant under the
CWA.  Eckology/Orgro municipal solid waste compost is only
considered to be a commercial product by EPA in order for the treatment plants to utilize  the
commercial fertilizer exclusion in the
CERCLA (superfund Act).  The Class A designation has
nothing to do with the levels of hazardous/carcinogenic metals in the compost. The Class A
designation indicates that on averaging multiple tests, the average level of one high
temperature strain of E. coli
(fecal coliform) that only grows at 112 degree F., is less than
1,000 most probable number of colony forming bacteria per gram of sludge. As EPA's
compost fact sheet points out the composting process does not kill all the germs.

EPA's original 1988 compost studies which were used to justify  the science behind Part
503 sludge compost use found that the process
did not kill all disease causing organisms.
Nor,  could most of the chemical constituents be identified. These 2 studies were only
released to the 12 national repository libraries. In 1994, EPA funded a WEF fact sheet on
debunking  an outbreak of Lou Gehrig's disease allegedly caused by
Milwaukee's
Milorganite sludge used on ballfields.  EPA promised a scientific study, that never
happened.

In reality,  the study was an attempt to justify the claim that pollutant contaminated sludge
was a viable commercial product. As noted above, EPA had documented 21 known
carcinogens -- five of them cancer causing agents when inhaled. By 1993, EPA claimed it
had
no data on most of the chemicals. By the time of this study, EPA did not consider any of
the 21 carcinogens to be cancer causing agents in sludge.

1. What problem did the study address?

Did it address the fact that these poor children were living on a hazardous waste site?
Did the study's authors really think they could prevent the epidemic of lead poisoning in
children by dumping unknown levels of chemicals and toxic metals on the soil.
Why would the study only look at a few of the toxic metals EPA lists in the Part 503,
rather than the full range of toxic/carcinogenic metal.
More importantly, why didn't the study's authors read the limitations placed on
Eckology/Orgro municipal solid waste compost? They state: "OrgroR is approved by U.S.
EPA and the Maryland Department of the Environment (MDE) for unlimited use in lawns and
gardens as a soil conditioner/fertilizer with lime addition to enhance plant growth for
establishment and maintenance of turfgrass,
forage grasses, and crops (vegetable,
nursery and field)"
EPA does not require testing for Iron.
"ORGRO may contain over 4% iron. Cattle and other ruminates can develop a health
condition from a diet too rich in iron, therefore, ORGRO is not recommended for use on
pastureland. ORGRO is not recommended for use on tobacco products."


2. Why not have the contaminated soil removed?
As hazardous material it must be disposed of in a hazardous waste landfill.
Government agencies and landlords have decided the cost is prohibitive?
Government agencies have also decided it is to expensive to properly dispose of sewage
sludge in a permitted sanitary landfill under the Solid Waste Laws which is why they are
dumping it on poor neighborhoods and operate a
multi-million dollar public relations
campaign to debunk the horror stories and convince the public its good for food crops.

3. What was the study>

One of the study authors, Rufus Chaney (USDA), had a serious conflict of interest.  As an
example, according to the study, "The APL provides riskbased limits
(Chaney et al.,
2000)
." Chaney was also one of the authors of EPA's, "A Guide to the Biosolids Risk
Assessments for the EPA Part 503 Rule" and in fact helped rewrite the Part 503 so that
it was less restrictive and no risk assessment:
Q: Were the limits for metals in the Part 503 rule established based on a 1 x 10~4 risk?

A: No, the Part 503 metals were considered noncarcinogens (they do not cause or
induce cancer) for the exposure pathways evaluated.

4. When was the study conducted?

The question is why would USDA and HUD fund a $446,231 study to research the effects
of unknown levels of toxic metals in sludge to reduce the availability of lead from soil,
since Chaney has been studying the uptake of metals in plants.
Chaney likes hazardous
waste and said. "It is irresponsible to create unnecessary limits that cost a hell of a lot
of money."      

5. What was the study design?

Did any of these organizations understand what was in sludge or more importantly, what
EPA and USDA did not know about the pollutants in sludge (i.e.
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.

6. Were the community organizations advised of the above statement.




7. Was the Kennedy Krieger Institue and Johns Hopkins School of Public
Health  and the University IRB appraised of the above statement from part 503?




8. What was the result of the Study?

That is not what the study says: "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).

9. What is the biosolid compost that was used in the study?

Apparently, no one looked at the history of Eckology/Orgro:  "In 1996, the compost facility hit
its lowest point as it was plagued with high operations and maintenance costs in addition to
turning out a product that offered little market value and generated minimal market demand."
The facility uses  
a "fourteen-day process of in-vessel composting". "Completing the
compost cycle
requires a minimum of 44 days from introduction into the reactors and
continuing through the extended curing period."

"according to the article "Pathogen Destruction and Biosolids Composting" in Biocycle of
June of 1996, "There is some evidence that coliforms and Salmonella sp. can survive
prolonged exposure to  temperatures of 55 C."  They cite a study done by Droffner and
Brinton (1995) using DNA gene probes, where they detected E. coli and Salmonella sp. in
samples collected from an in-vessel composting facility after the first 15 days of active
composting at a temperature above 55 C. In Table 5-4 Processes to Further Reduce
Pathogens in A Plain English Guide to the EPA Part 503 Biosolids Rule, composting time
and temperature requirements for within-vessel composting method was 55 C or higher for
three days!  Droffner and Brinton found that it took
56 days and 90 days for the densities of
Salmonella sp. and E. Coli, respectively, to decline below the detection limit...These
investigators also "
cite evidence of mutant strains of E. coli and Salmonella sp. resistant
to thermal environments in composting." (p. 68)


10. Where is Eckology/Orgro obtained?

Washington DC., where attorney  Warren A. Quinn, Director of Operations for American
Nursery and Landscape Association states (2002): "I got a Staphylococcus aureus infection
of my skin from handling composted sewage sludge ("biosolids") at my home, so that's
enough research for me. It was easily treated with antibiotics, but it could have been bad
news if I had not recognized it as something to see the doctor about before it got very far.
Now that I know about this risk, it is fairly simple to keep it from happening again by wearing
a dust mask and gloves, not scratching any itches while working with it, and washing up
well with an antibacterial soap.  Not sure where the PR is on this, but it seems to me that
the industry is not being very pro-active in educating the companies using the product (I was
in the landscape business for several years in the 80's and never heard of any risks with
using the product to amend soil on residential landscapes), and the general public is
certainly not aware of  it - yet.  Which makes this a classic case of a need for an industry to
get ahead of the negative PR curve - educating people about the risks and how to minimize
them - or risk a comprehensive regulatory response that would hurt the industry."

The PR on this is simple: "Synagro's George Clarke says illnesses are "Psychosomatic" --
VA. sludge "regulator" Cal Sawyer blames internet and "mass hysteria"

11. Are there legal or regulatory limits to Ekology/Orgro use?

No, But, EPA's 2006,  Biosolids Technology Fact Sheet, Use of Composting for Biosolids
Management,
 based on Yanko's  1988 study, states, "Under some conditions, explosive
regrowth of pathogenic microorganisms is possible." "
Composting is not a sterilization
process and a properly composted product maintains an active population of beneficial
microorganisms that compete against the pathogenic members
."[Note: EPA and partners
have assured the public that composting destroys pathogenic disease causing
organisms]
Limitations
  • Odor production at the composting site.
  • Survival and presence of primary pathogens in the product.
  • Dispersion of secondary pathogens such as Aspergillus fumigatus, particulate
    matter, other airborne allergens.
  • Lack of consistency in product quality with reference to metals, stability, and maturity.
  • In addition to odors, other bioaerosols, such as pathogens, endotoxins, and various
    volatile organic compounds, must also be controlled.
  • Biofilters are often used to control odors, but the biofilters themselves can give off
    bioaerosols.  (28)
http://www.epa.gov/owm/mtb/combioman.pdf

12. Did you provide information about the compost to the families in the study?

If composting does not sterlize the compost, why would the study authors make this
statement?  “Eckology/Orgro compost is made from
sterilized Baltimore sewage sludge
mixed and composted with wood chips and saw dust."

Why would the authors make the statement: "
The composting process used to make
Eckology/Orgro kills germs.”
FDA states: Bacteria "Spores show great resistance to high
temperature, freezing, dryness, antibacterial agents, radiation, and toxic chemicals. Under
favorable conditions, spores can germinate into actively growing bacteria and fungi. Many of
these spore-forming microorganisms are pathogenic to humans and have been implicated
in causing morbidity and  mortality."

When we look at the statement:  "the vast preponderance of scientific opinion
shows that Ecklogy/Orgro Class A compost did not then and does not now pose a known
threat to human health." We are forced to remember the multi-million dollar
EPA/WEF
public relation campaign to debunk the sludge horror stories.

13. Do you feel that the use of Eckology/Orgro exposed the families and their children to
added risk?

Oops, now they tell us the real purpose of the study.
"The purpose of the KKI study was to assess by how much and how efficiently
the product could help
reduce lead dust in soil around homes and it ultimately
proved highly effective in this regard."

Lets not forget the organic compounds, Nor that Chaney admits, "The analytical methods
currently used for the determination of organic compound concentrations in biosolids leave
many decisions to the discretion of the lab analyst and do not specify the extraction method
or necessary cleanup steps." "Unless analysts have extensive experience specific to the
determination of organic compound concentrations in biosolids, the reported levels of
organic compounds in biosolids should be considered suspect."

Lets not forget that
dried organic sludge causes "extrinsic allergic alveolitis"  (COPD) --
sewage sludge disease..

14. Why did you not disclose the potential hazards of the exposure to the compost?

As science based organizations, someone had to know that most of the metals in compost
are known carcinogens. Surely, someone did some basic research on the admitted
pollutants in the compost --
220 Hazardous Inorganic and Organic Constituents  

15. Where were the homes located? Why did the study target those specific areas?

There was no blood level testing done before or after the $446,231 study? Based on
laboratory tests lead bioavailability to poison children was only reduced 12 to 30%. Yet,
they say: "Baltimore City was in the midst of an epidemic of lead poisoning and the compost
study was a successful response to this huge problem affecting our community."


Getting  $446,231 to dump hazardous solid waste on a poor neighborhood was indeed a
success -- but accomplished nothing in the way of the huge problem affecting the
community. Well it did expose a few more people to danger who were not offered any
personal protective equipment. What about a follow up on these workers?


16. Were these areas chosen because of planned redevelopment, which would relocate
the inhabitants, thus making it more difficult to find them if questions were asked
afterward?

This may be one of the most interesting points of the "study". They say: "Researchers could
tell if the Orgo product worked in a few months by measuring how easily the lead in the soil
came out." I believe measuring how easily lead in the soil came out  (bioavailability) is best
done with the EPA's Toxicity Characteristic Leaching Procedure (TCLP) test for hazardous
waste. The reality is that unless the study authors are honest, we have no idea what the
numbers mean. As an example, if they tell us there is 100 mg.kg of lead we assume they
found 100 ppm of total metal for lead dry weight which has no enforcement value. If they tell
us there is 100 ppm/l we assume they have used the hazardous waste TCLP test which
has legal enforcement values.  The standard accepted conversion leach rate (bioavailability)
from total metal is 1 in 20 ppm.  The bioavailability of 100 mg/kg would be 5 ppm - the
hazardous waste level.


17. What educational efforts were undertaken to alert the families of the potential risk of
the lead dust levels in the surrounding soil?

As I understand it, these gentlemen explained that the yards were
hazardous waste sites posing severe health risk and the resources
available to help them were something or someone other than the City,
State or federal agencies.


18. Were the children living in the houses in the study tested?

The researchers had a rather caviler attitude about science  in this response. It is the
doctor's problem:  "
Their primary care physician is in the best position to make decisions
about risks from lead and need for any treatment. Any information from the study would not
have made a difference in the decision about whether or not to treat a child for high levels of
lead. Further,
we didn’t test children for any potential hazards related to the Ecklogy/Orgro
Class A compost, because at that time (and now) there were no known hazards."


Was that conclusion based on research or Chaney's reassurence?




19. Why were the children living in the houses not tested?

As note, bioavailability was not a concern, childrens health was not a concern -- "
The
study involved the measurement and extent of the effectiveness of the compost in reducing
lead dust in the soil." How much would it have cost to dump clean dirt on the lawns instead
of toxic sludge -- which would have reduced the lead bioavailability by 100% rather that 12 to
30%?


20. Why were the children not removed from the homes?

The EPA OIG can best answer that question: "EPA officials said investigating health
impacts from biosolids is not an EPA responsibility; rather, they believe it is the
responsibility of the National Institute of Occupational Safety and Health, the Centers for
Disease Control, and local health departments."




21. The article concludes that compost can provide “a simple low-cost”
t echnology
for parents and communities “to reduce risk to their children.”

You have to wonder if the consent form included a clause that the study
authors could not be sued?

22. What sort of follow-up was done to determine whether there were any long-term
health risks from exposure to the compost?
None, because:
The use of this compost material is encouraged by USDA's Rufus Chaney, co-author of the
study funded by USDA.  "Chaney has been deeply involved in the EPA's program to put the
health of our farmers and  farmland, as well as their neighbors at risk with the uncontrolled
dumping of toxic contaminated sewage sludge. He claimed to be an expert on metals when
he served on the
503 Peer Review  Committee, yet he doesn't seem to understand that
using lime to raise the  pH to 11 or 12 to make the disease organisms undetectable also
changes
Chromium 3 to the deadly [carcinogenic] Chromium 6 which is readily taken up
by crops.  Still Chaney claims that pollutants including disease organisms are not taken up
by plants. Yet, he knows that pollutants (cadmium) will be taken up in tobacco at the rate of
20 ppm to 1 ppm in the soil."
He did the study.

The implication of the study is that if children eat toxic contaminated sludge, the sludge
binds the metals, but that was disproved by
"United States Department of Agriculture
studies (1974)[which]  indicated there could be very serious problems with tobacco
grown on land where toxic sewage sludge was used because of the high uptake of
Cadmium. "Chaney et al. (84)--- observed Cd (Cadmium) content in tobacco to be 15 to 20
ppm at 1 ppm in the soil, and 45 ppm with 2 ppm Cd in the soil." (1) "

Chaney did help revise the sludge rule to remove all references to the disease
organisms in sludge as well as the 21 cancer causing organic and inorganic pollutants
in sludge. Five of the inorganic pollutants are known cancer causing agents when
inhaled in dust. Yet,
Chaney's name is on a document which states the 10 inorganic
pollutants included in the sludge rule where not considered to cause or induce cancer."


23. Who explained the consent forms to the families?

The question is, did the "qualified member" of the study team understand what chemicals,
disease organisms or carcinogenic toxic metals were in the compost?


24. Did the local community support the compost soil study?

The same question applies to Dr. Farfel, how could he brief the community representatives,
if he did not understand what chemicals, disease organisms or carcinogenic toxic metals
were in the compost?

Websites
Deadly deceit    
http://deadlydeceit.com/
sludge facts      http://sludgefacts.org/
sludge victims  http://sludgevictims.com/
the watchers     http://thewatchers.us/
The Sludgewatch-l Archives http://list.web.net/archives/sludgewatch-l/ a
Associated Press story -- Sludge fertilizer program spurs concerns  -- Raised a stink
BALTIMORE - Scientists using federal grants spread fertilizer made from human and industrial wastes on yards in poor,
black neighborhoods to test whether it might protect children from lead poisoning in the soil. Families were assured the
sludge was safe and were never told about any harmful ingredients.

THE Study
Biosolids compost amendment for reducing soil lead hazards: a pilot study of OrgroR amendment and grass seeding in urban yards
Authors: Mark R. Farfela,*, Anna O. Orlovaa,
Rufus L. Chaneyb [USDA], Peter S.J. Leesc, Charles Rohded, Peter J. Ashleye

THE RESPONSE