Risk Assessment Impossible
National Sludge Alliance
Fact Sheet # 136
RISK ASSESSMENT IMPOSSIBLE SCIENTISTS WARN
The National Academy of Science 's (NAS) recent Committee report on toxicants, states
that it is impossible to do a risk assessment to prove sludge use under part 503 is safe. The scientific statement is very
blunt: FINDINGS,"-----the remaining uncertainty for complex mixtures of chemical and biological agents is sufficient to
preclude the development of risk-management procedures that can reliability result in acceptable levels of risk." (5)
In effect, the Committee agrees with part 503.9(t) that due to the multitude of chemicals, pathogens and radioactive
material, EPA’s waste disposal policy could be killing more people than the law allows.
EPA lists 9 chemicals as simple pollutants in the Part 503 blanket permit policy. The nine chemicals actually have
multiple compounds. Many are incompatible and chemically react, sometimes violently.
With the exception of Molybdenum, all of the metals and compounds are listed as toxic pollutants under the Clean
Water Act (CWA) section 307, 40 CFR 401.15, and priority pollutants under CWA Section 313, 40 CFR 423, Appendix
A. as well as hazardous constituents under CWA landfill regulation 40 CFR 258. Molybdenum is recognized by OSHA
in 29 CFR 1910, subpart Z as a Toxic and Hazardous substance.
Chemical reactions and partial health effects from only nine chemicals in Class A (EQ) and Class B sludge
Arsenic forms highly toxic gas on contact with acids or active metals such as iron, aluminum and zinc. It forms the
deadly arsine gas in reaction to contact with hydrogen gas. Acids in contact with cadmium react to form hydrogen gas.
Arsenic chemicals react with acids and Chlorine, Chlorates, Dichromate fluorine, Perchlorates, Peroxides,
Permanganate and Nitrates (oxidizers). It also reacts to other chemicals such as Chromium trioxide, Nitrogen trioxide,
Silver nitrate, bromine, azide, etc.
Arsenic attacks the liver, kidneys, skin, lungs and lymphatic system. It can enter the body by inhalation, through the
skin, as well as ingestion of dust and food.
Arsenic can cause itching, a burning sensation or rash on the skin. It can cause irritation and burns to the eyes.
Inhalation can cause irritation of the respiratory tract. "High exposure can cause poor appetite, nausea, vomiting and
muscle cramps---nerve damage with numbness, "pins and needles" sensation, weakness of the arms and legs."
Long term it can cause brain damage, nervous system damage, gastrointestinal damage,
and skin lesions. A human carcinogen, it also causes birth defects and genetic damage in test animals.
Cadmium reacts to acids to produce hydrogen gas. Cadmium also reacts to oxidizers such
as Chlorine, Chlorates, Dichromate Perchlorates, Peroxides, Permanganate and Nitrates. It also reacts to acids,
ammonium nitrate, potassium, sulfides, selenium, zinc and tellurium.
Cadmium attacks the respiratory system, lungs, kidneys, prostate and your blood. Inhaling the dust can cause irritation
of the nose and throat with severe chest pain, cough, difficulty in breathing, headache, chills, muscle aches, nausea,
vomiting, diarrhea and fluid in the lungs. Exposure may also cause dizziness, irritability, gastrointestinal problems,
fever, sweating, exhaustion and inflammation of the lungs. Death could result in seven to ten days.
Ingesting Cadmium could cause increased salivation, choking, vomiting, abdominal pain, anemia, kidney malfunction,
diarrhea, and persistent desire to empty the bladder.
Low levels of Cadmium over a period of time may cause cancer, kidney disease, neurological dysfunction, diminished
fertility, immune-system changes, and birth defects. It has caused tumors and birth defects in rats.
Copper in contact with strong oxidizers such as, Chlorates, Dichromate Perchlorates, Peroxides, Permanganate and
Nitrates may react violently creating explosive gases. Copper also reacts to acids, azides, ethylene oxides, as well as
chemical active metals such as potassium, sodium, magnesium, zinc Zirconium, etc. Copper chloride in contact with
strong acids forms monovalent copper salts and toxic hydrogen chloride gas.
Copper attacks the respiratory system, lungs disease, kidneys, skin, and kidneys , liver, including risk of Wilson's
disease. Contact causes itching, erythema, and dermatitis as well as conjunctivitis, ulceration and turbidity of the eye
cornea. Inhaling copper causes congestion of the nasal mucous embranes, upper respiratory tract, metallic taste in
the mouth, nausea, and could cause a fever.
Ingesting copper produces salvation,nausea, vomiting, gastric pain, hemorrhagic gastritis, and diarrhea. Copper is can
be highly toxic decreasing fertility in men and women. It can cause chronic irritation of the nose including creating a
hole in the septum. In the copper smelting industry there is an excess of cancer cases. Damage to the nervous system
and kidneys have been recorded and jaundice has been observed. In some cases, the liver has been enlarged.
Lead chemically reacts to sulfuric acid, and oxidizers like ammonium nitrate, chlorine trifluoride, and chemically active
metals such as hydrogen peroxide, sodium actylide, sodium azide, disodium, sodium, potassium, and zirconium as well
as chlorine and fluorine.
Lead and its compounds attack the eyes, skin, heart, brain, lungs, gastrointestinal tract, central nervous system,
kidneys, blood, lymphatic, and gingival tissue. Lead at low levels over a period of time cause brain and bone damage.
It has caused malignant tumors in test animals. It is a carcinogen of the lungs and kidney, skin, an experimental
teratogen and affects the central nervous system. Lead enters the body by inhalation of the dusts, fumes, mists or
vapors, by ingestion of lead compounds trapped in the upper respiratory tract or introduced into the mouth on food,
fingers or other objects, or through the skin.
Lead is a cumulative poison. Increasing amounts build up in the body and eventually a point is reached where
symptoms and disability occur. It affects the red blood cells producing anemia. It also damages organs or tissues with
which it comes into contact.
Symptoms may include irritation of the eyes, respiratory tract, and alimentary tract. It causes tiredness, asthma,
fatigue, sleep disturbance, high blood pressure, anemia, paralysis of forearm, wrist joint and fingers, leg cramps,
abdominal pain, colic, severe constipation, nausea, vomiting as well as kidney and brain damage. Lead may also
cause dizziness, headaches, personality changes, retarded mental development, ulcers, convulsions, coma,
delirium and death. Lead also causes decreased fertility in males and females as well as miscarriages and birth
defects. Recent research has shown that as older people lose bone mass lead is released which can cause the same
Mercury creates toxic gases when heated. When mercury cools it may create toxic gases of sulfur oxides, mercury
cyanide and nitrogen oxides. It also chemically reacts to alkali metals, azides, ammonia gas, chlorine, chlorine dioxide,
sodium carbide and ethylene oxide. Contact with acids can create toxic mercury and cyanide gases.
Mercury and its compounds attack the eyes, skin, respiratory system, central nervous system , peripheral nervous
system and kidneys. Inhalation or ingestion as well as skin contact of the pollutants can cause simple symptoms
including shyness, insomnia, anxiety or loss of appetite. The exposure progresses to flu-like symptoms, to headaches,
salivation, metal taste, chills, cough, fever, tremors, abdominal cramps, diarrhea, nausea, lung irritation, as well as
lung tissue damage.
Mercury accumulates in the brain, liver and kidneys over a long period of time. Long term exposure includes brain
damage, dizziness, memory loss, loss of central nervous system muscle control, loose teeth, liver damage, skin
problems, and clouding of the eyes. Mercury is a teratogenic damaging the fetus and can cause genetic damage in
humans as well as death.
Molybdenum and its compounds chemically reacts to alkali metals, sodium, potassium, nitric acids, sulfuric acid, etc.
There can be a violent chemical reaction to oxidizers such as Chlorine, Chlorates, Dichromate fluorine, Perchlorates,
Peroxides, Permanganate and Nitrates.
Molybdenum exposure is by inhalation, ingestion, skin and/or eye contact. Molybdenum and its compounds attack the
eyes, respiratory system, kidneys and liver. It is highly toxic based upon animal experiments. It is a poison by
intraperitoneal and intratracheal routes. Inhalation of Molybdenum causes headache, fatigue, loss of appetite, muscle
and joint pains. In animals it is known to cause anorexia, diarrhea, listlessness, liver, kidney damage and death.
Nickel can have a strong chemical reaction in contact with acids and chemically active metals. Nickel also chemically
reacts to nickel nitrate, potassium, sulfur, selenium, and organic chemicals.
Nickel and its compounds attack the nasal cavities, lungs, skin, heart, liver, and kidneys. It is known to cause nasal,
lung and throat cancer. Irritates and burns the eyes and skin. Inhalation of nickel can cause a sore or hole in the nasal
septum, lung allergy like asthma, cough, shortness of breath, liver and kidney damage, and a pneumonia like illness,
as well as a delayed pulmonary edema emergency, which can lead to death a few hours or a few days after exposure.
Many nickel compounds are experimental carcinogens. All nickel contaminated
dusts are regarded as carcinogenic by inhalation.
Selenium reacts with water at 50 degrees C to form hydrogen and selenious acids. In contact with acids, it may create
hydrogen selenide gas. There is a very strong chemical reaction when in contact with acids, oxidizers such as
chromium trioxide, potassium bromate and cadmium.
Selenium and its compounds attack the eyes, skin, respiratory system, liver, kidneys, blood, and spleen. Selenium is a
poison by inhalation and intravenous routes. It is an experimental carcinogen. Long-term exposures may be a cause of
amyotrophic lateral scleroses in humans (Lou Gehreg's Disease). In animals it causes anemia, liver necrosis, cirrhosis,
kidney and spleen damage as well as "blind staggers" in cattle.
Contact with Selenium can burn the eyes and skin. Inhalation of Selenium can cause visual problems, headaches,
chills, fever, bronchitis, difficulty breathing, gastrointestinal problems, as well as lung irritation peumonitis). Selenium
can also cause, irritability, fatigue, increased dental cavities, upset stomach, loss of nails and hair, depression and
delayed emergency pulmonary edema.
Zinc chemically reacts violently with sulfur, halogenated hydrocarbons, acids such as alkali hydroxides, and bases. It
also reacts to oxidizers such as chromic anhydride, manganese chloride, chlorates, chlorine and magnesium. It also
reacts with water. These reactions could cause spontaneous combustion or explosive hazards.
Zinc and its compounds attack the eyes, skin, heart, blood, pancreas, nervous system, respiratory system, lungs, liver,
kidneys and cardiovascular system. It can cause cancer in the lungs and throat. Inhalation and ingestion may cause
irritation of the mouth, nose, throat and digestive tract.
Exposure to zinc can cause skin rashes, headache, personality changes, poor appetite, lethargy, and confusion as
well as delayed emergency pulmonary edema, which can lead to death in a few hours or days. Symptoms may include
cough, copious sputum, breathing difficulty, chills, fever, weakness, (exhaustion), pains in muscles and joints, chest
pain, bronchopneumonia, pulmonary fibrosis, nausea and vomiting, bloody diarrhea, swelling of the throat, blood in
urine and shock.
(NIOSH, Pocket Guide to Chemical Hazards (7) and Sittig's Handbook of Toxic and Hazardous Chemicals and
Carcinogens (8) tell the story EPA does not want you to know.)
The EPA/WEF's public relations campaign to change pubic perception about the dangers of sludge has worked. But
what was it trying to hide?
In 1979, the EPA began promoting the use of all sewage sludges (now including those contaminated by pathogenic
hazardous waste and radioactive materials) as beneficial use fertilizers. And, in 1980, " The Agency decided that
growth of food-chain crops need not be banned at hazardous waste land treatment facilities but rather should be
carefully regulated." (1). By 1983, the EPA decided, "- to avoid conceivable stigmatization, we are willing to re-name
recycled hazardous wastes "regulated recyclable materials."(2). And, in 1985, the "regulated recyclable materials" title
was shortened to "recyclable material"." In addition "---commercial hazardous waste derived fertilizers would not have
to undergo chemical bonding to be exempt." from the law (3). The EPA just had to sell the concept to make it
commercial, and it did. But what happens to lawn care companies who believe the PR campaign?
As an example, Scotts Company publication, Ortho's "All About Lawns" says, "Composted sewage sludge, [is], an
organic fertilizer." In fact, "Among the ones most suitable for use on turf are those made from sewage sludge and
However, sludge contractors know the law and the truth. As an example, New England Organics acknowledges on its
sales promotion web site that sludge is a regulatory waste disposal risk to municipalities. It states, "New England
Organics recognizes the risks inherent in handling materials defined by regulatory agencies and legislation as
"wastes". ------We provide our waste generating clients with the assurance that their interests in risk
minimization are protected."(6)
William Sanjour (retired EPA Hazardous Waste Division ) sums it up, "The great liberal dream of establishing powerful
institutions to protect and perfect our lives turns out to be just the same old nightmare of corruption and abuse." (10) -
(1)FR 45, No. 98, Monday, May 19, 1980, p. 33207.
(2) FR 48, No. 65, Monday April 4, 1983, p. 14485.
(3) FR 50, No. 3, Friday January 4, 1985 p. 646.
(4) Ortho's All About Lawns, Fertilizer, (p.32), Copyright 1999, The Scotts Company
(5) National Research Council, July 2002,
(7) NIOSH, Pocket Guide to Chemical Hazards, U.S. Department of Health and
Human Services, CDC, OSHA, Publication No. 97-140, June 1997
(8) Sittig's Handbook of Toxic and Hazardous Chemicals and Carcinogens, edited
by Richard P. Pohanish, fourth edition, 2002, Noyes Publication/William
(9) National Sludge Alliance fact sheets, http://www.penweb.org/issues/sludge
(10) Sanjour, William, 1978-80 sludge wars, http://pwp.lincs.net/sanjour/Sludge3.htm