SOUND SLUDGE SCIENCE                Pages 1, 2, 3, 4
                         and why there will be no
EPA/WEF Rapid Incident Response to Health Complaints From Land Application of Biosolids

by Jim Bynum                                                                                                                                                                                        5/20/2008
Help for Sewage Victims
Retired Safety Consultant

The Truth Will Prevail

Dr. Caroline Snyder reminds us that "The Dirty Work of Promoting "Recycling" of America's Sewage Sludge"
began in the late 1970s when the first land application regulations were formulated by political appointed "managers
and scientists in EPA’s Office of Water (OW): Henry Longest II, John Walker, and Alan Hais." "Despite the fact that
sewage sludge is a contaminated waste product, it is being commonly treated and used as a fertilizer, without
informing the recipients about the complete contents of the sludge." EPA and it's wastewater industry partners have
attempted to "control the flow of scientific information, manipulate public opinion, and cover up problems, ignored or
concealed reported health problems, threatened opponents with litigation, distributed misleading information to the
media, legislators, and the public, and above all, attempted to silence critics."

Lying to the public through the media has become a national pastime for the  wastewater industry since the Powell
Public Relations firm laid out the strategy in 1993 to convince the public that toxic sludge is good for you.
An example is the April 30, 2008 story in the
Baltimore Examiner by Karl B. Hille , "Reports confusing Orgro Class A
compost with sewage sludge irk compost makers. Treated compost not same as sludge, maker stresses.
" According to
John Myers, "a consultant for the Curtis Bay Orgro Composting Facility", "The EPA routinely tests both the incoming
sludge and the final product for harmful bacteria and heavy metals." He said, "Compost is a safe, biologically rich
topsoil spread in gardens, lawns and landscaping."  

Routine testing at maximum capacity of 210 ton a day would be once a month.
  • Facilities that produce up to 290 metric tons annually must monitor once each year;
  • Facilities which produce 290 to 1500 metric tons annually must monitor once each quarter (four times per year);
  • Facilities producing 1500 to 15 000 metric tons must monitor once every 60 days (six times per year); and
  • Facilities producing 15 000 or more metric tons must monitor monthly (12 times per year).

If the compost was not classified as a sludge product, it would have to be disposed of as a solid waste. Furthermore,
the EPA does not  test Orgro Class A sludge compost for harmful bacteria.  Nor does EPA require that the Orgro
facility operators test for harmful bacteria.
EPA admits harmful pathogens will be in the final compost product.  EPA
only requires that a combined multi-sample (7) of sludge be tested for a high temperature
mutant indicator coliform
which EPA says is not harmful. Not only that, but Orgro is only required to test for 9 toxic heavy metal (pollutants) out
of the
CERCLA (superfund) Priority List of 275 Hazardous Substances determined to pose the most significant
potential threat to human health due to their known or suspected toxicity and potential for human exposure at
superfund sites.

The nine pollutants the compost facility are required to test for are also priority toxic pollutants.  According to EPA,
"The term
"toxic pollutant" is not used in the final part 503 regulation because this generally is limited to the list of
priority toxic pollutants developed by EPA. The Agency concluded that Congress intended that EPA develop the part
503 pollutant limits for a broader range of substances that might interfere with the use and disposal of sewage sludge,
not just the
126 priority pollutants."

Therefore, the compost facility operators, Baltimore and elsewhere, have no idea what level of hazardous toxic
pollutant substances are in the final sludge product. According to the original
1988 compost studies for distributed and
marketed compost, "Composts modified with various materials to produce commercial soil amendments contained
significantly higher concentrations of bacteria and fungi than the base compost material. The data suggested a
nutrient-related regrowth phenomenon."  Not only that, but "Efforts to characterize major unknown organic components
were limited to computer comparisons of GC/MS peaks to the NBS mass spectral library. In none of the cases was a
tentative identification made. " "As a result, a significant portion of the major peaks were
multi-component peaks whose
identities remain completely unknown

No one knows what is in this sludge product, but the public has become the victim of this outrageous conduct.
ultimate insult to Congress and the American public was given in a letter to Congressman Conduit, dated
October 1, 1993, by Martha G. Prothro, (EPA) Acting Assistant Administrator. She states that, "If the placement of
sludge on land were considered to be "the normal application of fertilizer"--it--"would not give rise to CERCLA  
[superfund] liability for the municipality generating the sewage sludge, the land applier, the land user or the land
owner." This was also stated in the preamble to Part 503.

So, what happens when a sludge site is sold to a developer?
In Riverside, California, "Based on the alleged
contaminated soil, residents from three homes in the more than 200-home tract who filed the lawsuit say they and their
families have suffered health problems including weight loss, hair loss, fevers, sinus problems, nose bleeds, fatigue
and a host of other ailments."   What could cause the problem? Hazardous "Endotoxins, which are released when
bacteria is destroyed, have been known to cause severe inflammation in any tissue exposed to them, including lung
tissue, according to the national Centers for Disease Control and Prevention."

It would appear EPA's sludge rule relieves everyone of federal liability for creating a hazardous waste open dump site
on agricultural land, even if becomes your lawn. However, that doesn't prevent the present or future land owner from
having to deal with lawsuits over the contaminated land. Now, EPA denies any responsibility, "EPA's role in the
management of industrial nonhazardous Waste [sludge] is very limited. Under
RCRA Subtitle D, EPA issued minimal
criteria prohibiting "open dumps" (40 CFR 257) in 1979. The states, not EPA, are  responsible for implementing the
"open dumping criteria," and EPA has no back-up enforcement role."

EPA and WEF have recklessly promoted sludge as a safe fertilizer. Yet, the documents tell a much different story.
In 1993, EPA claimed it did a 14 pathway risk assessment for sludge used as a fertilizer on agricultural land under Part
503. At the same time it claimed to have a
lack of data on most chemicals in sludge. Part 503 was Peer Reviewed by
old time sludge researchers and regulators, including EPA's James Ryan and USDA's Rufus Chaney. In a 1992 EPA
memo we discover that
Ryan and Chaney also rewrote the part 503: "The sludge rule discussions with OW are on hold
waiting for Ryan and Chancy' s rewrite." The question was: "Are human health and the environment "pretty safe" with
the application rates drafted, or does the Administrator need to hear that major work is necessary just to be pretty
safe? Can we feel ok as long as the uncertainty is fully discussed, both in the preamble and the guidance
documents?"  "Options facing the Agency if the problems persist in the next edition include boldly publishing on
admittedly weak science, using a factor of safety to compensate for any weakness, or scrapping the whole exercise,
promulgating the Feb 89 proposal as interim." In the guidance documents in 1995, EPA admitted it did not use any of
13 chemical risk assessments on file and did not consider any of the toxic heavy metals to be carcinogens --
contrary to EPA's
own 1989 list of carcinogens in the proposed 503 --  which was not included in the final part 503.

"In a 1995 paper, James Ryan of the EPA and Rufus Chaney of the USDA, describe how even flawed risk
assessments are used in making risk management decisions. According to them: In this risk assessment process it is
soon apparent that lack of data, inappropriate data or inadequate data on the dose-response relationship,
environmental exposure or population risk make implementation of the risk assessment difficult and lead to
generalization and or acceptance of inadequate data. However, even with these flaws, if done in an objective manner
the risk assessment serves as a useful analysis for risk management. "

Of course, any sludge researcher or judge, who did not read the paper, or the preamble to Part 503, might assume
EPA actually did a legitimate risk assessment. EPA/WEF pro-sludge research is done by third parties with strict
guidelines. Generally, a pro-sludge researcher can make positive statements based on limited research and data
without their integrity  being questioned because of the limitations noted in the study. However, when EPA agents with
an agenda funds a sludge study such as the one focusing on the Georgia cattle deaths, scientific researchers should
Julia Gaskin of the University of Georgia is learning this lesson the hard way, in court charged with fabricating
data to cover up cattle deaths on a Georgia farm.
"She  also says that the paper was never intended to study
problems with biosolids on the dairy farms. “The purpose of this paper was not the focus that has been
alleged,” she says. “That was not part of this effort."
It will be interesting to see how that defense holds
up in court.

EPA warned the public and researchers,  "When sewage sludge is not used to condition the soil or to fertilize crops or
vegetation grown on the land, the sewage sludge is not being land applied. It is been disposed of on the land. In that
case, the requirements in the subpart on surface disposal in the final part 503 must be met."

You have to read that sentence twice. Yes, it really does say if you are not fertilizing some type of plant life, the
sludge/biosolids must be disposed of in a
permitted part 503.23 surface disposal monofill (landfill). In many cases the
sludge/biosolids will be too contaminated to do so.

Moreover, "EPA concluded that
adequate protection of public health and the environment did not require the adoption
of standards designed to protect human health or the environment under exposure conditions that are unlikely and
where effects were not significant or widespread."

Baltimore lead study in the black neighborhood is a good example of unlikely exposure conditions. With only nine
yards involved and a few children involve, the effects were not significant or widespread. The same is true for the
black neighbors around sludge sites in Virginia, Carolinas' and Georgia. It isn't really a racism thing -- these waste
industry people (EPA/WEF) have no respect for human health and life regardless of race. It is unfortunate that Dr.
Gary W. Goldstein, president and chief executive officer of the Kennedy Krieger Institute and Dr. Michael J. Klag is
dean of the Johns Hopkins University Bloomberg School of Public Health happen to get caught in the middle of the
EPA/USDA/WEF public relations ploy.

The EPA statement that adequate protection of public health wasn't required for the sludge rule is in direct conflict with
the mission statement: "
The mission of the Environmental Protection Agency is to protect human health and the
environment." "Since 1970, EPA has been working for a cleaner, healthier environment for the American people."

However, the operating legal theory behind the sludge rule has been that the laws and regulations are there to protect
the general public (i.e. American people) , not individual people. As an example, if a farmer is too damn dumb to
question why it is safe for him and his family to be exposed to sludge/biosolds, but the public can not be expose to it,
then he deserves to suffer the ill effects and possible death of his loved ones as EPA outlines in
Part 503.9(t). Not to
mention possible lawsuits from the damage he does to his neighbors health and environment. This is a case where
having close neighbors is unlikely, and if he did, they would be so few the effects would not be significant or

As Helane Shields documents on her website  the health and environmental effects can be
horrible for those few neighbors. "Sludge victims suffer burning eyes and throats, respiratory seizures, intestinal
attacks, nausea, sore throats, nose bleeds, irritable bowel and crohn's disease, skin lesions, malignancies, abnormal
hormone levels (autoimmune diseases), liver damage and other adverse health effects such as terrible headaches,
severe fatigue, asthma, dizziness, and pathogenic infections such as dental cavities, Necrotizing fasciitis (flesh eating
bacteria), heart disease, meningitis and death."

Medical general practitioners (family doctors) have no idea how to deal with sludge victims exposed to so many
pollutants. As my doctor says, "its impossible, the government would not allow that to happen." So doctors treat the
symptoms and if they don't understand the autoimmune system symptoms, the patient has to be imagining the health
problem, that only an endocrinologist could understand. As
Andrew F. Stewart MD, Chief, Division of Endocrinology,
University of Pittsburgh School of Medicine noted there are serious problem ahead. In 2006, according to the
American Board of Internal Medicine (ABIM),there were "approximately 4,000 M.D. endocrinologists available in the US
whose primary focus is to provide clinical care." "The endocrinologist shortage has impaired access to care by patients
with diabetes, obesity, metabolic syndrome, lipid disorders, thyroid nodules, thyroid cancer, osteoporosis, pituitary
disease, adrenal disease, menopausal symptoms, and reproductive disorders. It is standard to encounter waits of 3 to
9 months, and many endocrinology practices are closed to new patients."

The rural victim of sludge exposure is literally up the creek without a paddle. Of course, the city dweller exposed to
hormone disrupting chemicals released in sewage effluent and passed through the drinking water treatment plants are
in the same boat. This is just a prelude to an admitted  
pandemic when doctors will have to decide who to let die.

Two sides to this coin

Since the EPA/WEF position is that all sludge/biosolids use and drinking water is safe and the victims are
required to prove its not, "

Jodi L. Sokolowski, reporter for the VIRGINIA  newspaper -
us two examples of this mentality. 1).
" Synagro's public affairs manager, George Clarke, said the
cause for concern is mostly psychological. "If it smells bad, it must not be good for me," he said rhetorically." and
2). Cal Sawyer, of the Virginia Department of Health's Division of Wastewater Engineering, said these medical
mysteries  are worrisome. "If these people are alleging that biosolids are causing all these problems, some of these
people might have health problems that aren't being looked into," he said. Blaming biosolids "is not doing them a
favor. They're not looking at what really might be the problem." He added that the department did not start to receive
complaints about biosolids until Internet use became more common. "
It's mass hysteria. If you suggest they will get ill,
they will get ill," he said." What the Internet did was expose the industry lies to public scrutiny. That is a good thing.

As pointed out in the document,
the public to sludge and reclaimed water use, the industry claims there have  been no health problems within the
wastewater industry. Therefore the public can not possible experience any health problems from exposure to sludge
and reclaimed water.  That is a serious indicator that we can not trust the words of the wastewater treatment industry.  
In fact,  Hadeed,  National Biosolids Partnership (NBP) Technical Communications Director it appears, likes to have a
little fun at the expense of country folks, He said  "Odors, quite frankly, are the number one reason for lack of public  
acceptance of biosolids." Then he gives us a little rhyme,  "Odors, odors everywhere and all the biosolids did stink,
Odors, odors everywhere but Not In My Back Yard you fink! - Rhyme of the Ancient Biosolids Manager (S.J. Hadeed,

The fact is these folks making fun of us have to know the chemicals causing
odors can be killers. Yet, It would - appear
Mr. Hadeed never completely read the EPA document on  Amines in ODOR CHARACTERIZATION, ASSESSMENT
AND SAMPLING from sludge. Based on the above opinion, it is probable that Mr. Haeed  stopped reading when EPA
somatic impacts of odors.  Somatic means "of the body", or Somatic Cells from the body that compose
the tissues, organs, and parts of that individual other than the germ (sex) cells.

Psychosomatic (neurotic) appears to be the way the term somatic was interpreted. Like Hadeed,  "William Toffey, who
oversees Philadelphia's waste program, swears biosolids is safe. He is, in fact, a little giddy about composted human
waste. "Biosolids are fun," he said." Toffey even wrote a  paper,
Biosolids Odorant Emissions as a Cause of Somatic
.  However, Toffey admits, "noxious odors, have occurred, even with some regularity. Examples of such cases
are putrid biosolids compost along highways, noxious advanced-alkaline stabilized biosolids near elementary schools,
and  stinky piles of biosolids pellets in a farmer’s field." But then he said, " Experts to the wastewater profession have
not been able to dismiss the role of biosolids in triggering IEI and
psychogenic illnesses." "The psychogenic theory
presupposes that idiopathic environmental intolerance (IEI) is an overvalued idea explained by psychological and
psychosocial processes."
I do believe he just said us old country folks are crazy and the industry bought experts will
not consider otherwise?"

Of course, us crazy folks are not supposed to know that these EPA/WEF members don't do their job very well.
According to
government documents,  "A recent EPA report [2004] by the Office of Enforcement and Compliance
Assistance documented extensive non-compliance with the CWA. In 2002, 83 percent of facilities in SNC [significant
non-compliance] were repeat SNCs. In 2001, 25 percent of major facilities were in SNC. Sixteen percent-29 percent
remained in that status for 2 years  or longer. Of those that returned to compliance, there is a 50/50 probability that
they will return to SNC again within 2 years."

Dr. Edo McGowan noted in a 2007 editorial, "A 2004 WERF paper that studied sewer plants from coast to coast
noted problems not only with reclaimed water but with the standards as well. The WERF study noted that plants in their
production of recycled water actually met standards somewhere between 33% and 66% of the time. Giardia cysts were
found in 84% of the final recycled/reclaimed water samples. Enteric viruses were detected in 31% of the final effluents
of two-thirds of the studied facilities and Cryptosporidium oocysts in 71% of the final recycled/reclaimed effluents.
Viable Cryptosporidium oocysts were detected in 30% of the final recycled/reclaimed effluents in two-thirds of the
tested facilities". The study concluded that the standards did not protect public health." The authors of the
paper, Joan B. Rose, made a strange claim, "Reclaimed water as monitored in this study in Arizona,
California and Florida is not pathogen free, and exposure of the public to these waters carries some risk,
albeit this level may be very low and quite acceptable to most populations.
" Does that mean the use of
reclaimed water with low pathogen levels used on l
ettuce and spinach grown in the Salinas Valley, California outbreak
was acceptable to the population that got food poisoning, the dead population or to the population that didn't get food
poisoning  -- or just to most populations operating and regulating  the treatment systems, and the promoters of
reclaimed water? As retired government soil scientist Frank  Pecarich says, "I have to accuse these people of a cover-
up, pure and simple. They have been dissembling information for years it appears. It is time to put an end to this
collusion and subterfuge. Our food safety, our lives and our children's lives are at stake."

The sludge promoters like to bring religion into the mix.
In BSE, The Bible and Biosolids: Fighting Fear with Fun,
Frankness and Familiarity, we find that If  William Toffey, manager of Philadelphia's biosolids program, can
not convince us we are crazy -- then its best to make fun of us -- because the industry is operating on
instincts rather than science. Toffey said, "
Can it be possibly true that biosolids are part of a process for making
humans, as well as the soil, healthy!  The concern we hear in the community about exposure risks may prove, in the
end, to have an ironic twist – it may be a health benefit. Certainly, we need to explore the scientific aspect of the issue,
and not cede ground on this one either."

Toffey says sludge exposure is good for you, "One of the citations in the litany of “scientific” documents took me to
some exciting health literature about which we need to be more aware, science that proves the Hygiene Hypothesis,
previously known as the Clean Kid Syndrome.  This hypothesis says that unless we are challenged as young people to
dirt and manure, our bodies do not develop an immune response that protects us from allergens and toxins; allergies,
asthma and cancers can occur in higher than expected incidence rates if kids are too clean!" I believe the theory is:
"if it does kill you, it makes you stronger."

Toffey admits the product may have problems, "Achieving a good quality biosolids product has been an afterthought in
many treatment plant designs.  In the future, a commitment to a good looking and pleasant smelling biosolids will need
to be foremost.  We need to communicate this new commitment to our utility customers."

Toffey also admits the industry has no idea of the sludge exposure risks, "The biosolids industry is facing many new
questions -- emerging pathogens, persistent organic pollutants, radioactivity, and endocrine disrupter's.  No matter
how keenly our instincts tell us that these issues pose very little risk, we have no conclusive data on the risks they

Dr. McGowan has researched this issue. He said. "Keep in mind that the industry does not require knowledge in these
areas, so, how would they know if they did or did not have problems, they don’t even understand the question. DHS is
the states dept of health services and has recently changes its name to dept of public health, but still they don't know
any more. The number 2 man in their drinking water division, same division that handles recycled water told me that if I
wanted the agency to look at antibiotic resistance, to go out and get a politician to make new law that would force them
to look at this, otherwise they were unable to do anything. In reality, they are moribund by lack of funds and interest
because of other priorities, and they don't seem to really understand the issue which is odd for an agency compelled
by law to look out for the public health. Perhaps that is the key ---- compelled by law and not necessarily common

What people really don't understand is why Toffey and the industry works so hard to get this pollution so close to
humans and have no concern for polluting the air, water and food supply when they have known about the pathogen
reactivation/regrowth phenomenon in sludge during sludge treatment since 2001."  Of course, they have known about
antibiotic resistant and viable, but nonculturable bacteria for 30 years.

In a document
Prepared by Biosolids Pathogens Task Force of the Water Environment Federation, Reactivation and
Regrowth of Fecal Coliforms in Anaerobically Digested Biosolids.
Toffey is listed as a member.

I do believe Dr. McGowan was right about the industry's level of knowledge.
There is no such thing as Fecal
.  Fecal coliform are the mutant coliform that grow at 44.5° C. (112.1° F).  A coliform includes all of
the gram negative bacteria that are defined by their ability to ferment lactose within 24 - 48 hours
incubation at human body temperature of  35-37° C (95-99°F).  EPA falsely claims that none of the bacteria
included in the coliform bacterial group cause diseases in humans.

E. coli and Salmonella are two of the coliform bacterial group as well as the fecal coliform bacterial group.  The
document really does not tell us much when it states, "In summary, the body of knowledge to date from a limited
number of plants seems to indicate that some plants with a combination of anaerobic digestion and centrifuge
dewatering may be experiencing fecal coliform reactivation and/or regrowth. For utilities that use BFPs for dewatering
of anaerobically digested biosolids, fecal coliform reactivation/regrowth was not observed in the small number of plants
reviewed. However, it is important to note that the literature to date suggests that anaerobic digestion processes—
whether mesophilic, thermophilic, or TPAD—rather than destroying fecal coliforms, may convert them to a viable but
nonculturable state, whereby they can be reactivated by centrifuge dewatering but not BFP dewatering. Because the
mechanism for reactivation is unclear, it is conceivable that the viable but nonculturable fecal coliforms in the BFP
biosolids could also subsequently be reactivated at some point. Thus, low counts in the BFP cake versus elevated
counts in the centrifuged cake may not be relevant. Because fecal coliforms are indicator organisms, the “reduction” of
which during digestion is assumed to coincide with a reduction to acceptable levels of pathogens, it raises the question
as to whether there is really an issue or simply an analytical artifact. Thus, evaluating the direct relationship between
fecal coliform regrowth/reactivation and actual pathogenic activity in biosolids is needed."

Has the WEF really changed since it started it
"sludge horror story" debunking program in 1995? Now WEF says,
"Agencies may also want to share the information from the WERF regrowth/reactivation study with their citizen
constituents and other interested parties. It may take considerable effort (presentation and discussion) to share
this information and what utilities and the wastewater profession are doing as a result. However, this will be worthwhile
as it will inform people as to the complex issues that environmental professionals and their served communities
sometimes have to address."

It is clear, WEF members can no longer hide the science showing sludge use is unsafe including such information as
the study by  
Dr. Julia Ljubimova which found "Hundreds of studies have linked air pollution to early deaths,
heart attacks, reduced lung function, lung cancer and various other health problems. Ljubimova is among
a handful of scientists who are focused on finding out what air pollution does to people's
brains." Yes,
"Research suggests breathing in pollution could trigger brain cancer"

Another study found,"
Harmless protozoa that live on grocery store greens can shelter deadly food
pathogens like E. coli and Salmonella. A laboratory study has found that food pathogens survive being
eaten by protozoa living on spinach and lettuce. The temporary asylum might help bacteria stick onto leafy
greens or resist efforts to kill them before packaging."

EPA/WEF have been claiming a
1984 Ohio sludge study that was never competed to prove sludge use was
safe. However, a new                                 found just the opposite. The authors state, "We observed an
association between respiratory, gastrointestinal, and general symptoms linked with infectious diseases
and residence in homes near farm fields permitted to receive Class B biosolids. Moreover, we found a
significant dose-response relationship for excessive secretion of tears, abdominal bloating, and
dehydration. These findings are in agreement with the findings of Lewis et al9 and studies
on wastewater treatment workers.7 However, they contradict an earlier study from 3 areas in Ohio, in
which researchers reported no significant differences in the risk of respiratory, gastrointestinal, and
general symptoms between sludge-farm residents and control-farm residents. In the Ohio study, the
biosolids application rates were low and thus exposure levels may not have been comparable to those in
this study."

"In conclusion, our findings suggest an increased risk for certain respiratory, gastrointestinal, and other
diseases among residents living near farm fields where the application of biosolids was permitted.
Moreover, the reported occurrence of certain chronic diseases, such as multiple sclerosis, were
elevated in the exposed group. Further studies are needed to determine the relation between time from
last application of biosolids and reported health effects as well as to address cited limitations."

But the PR program goes on in an effort to control the media and public response.
NEXT             Page 4