National Sludge Alliance Fact Sheets

Public Facts # 116

July 4, 1997


* If you or your family have experienced flu like symptoms, upset stomach and diarrhea, you may be one of the 80
million people in the United States touched by one of the plagues now running rampant across America. (Emerging
Infectious Diseases, Ralph J. Touch, Chief Sanitarian, US Department of Health and Humans Services, May 27, 1996)

Between 1988 and 1992 there was (796) an average of 200 bacterial foodborne disease outbreaks annually. The
worse disease outbreak in our nations history was caused by the waterborne Cryptosporidiosis parasite in 1993 and
affected over 400,000 people in Milwaukee, Wisconsin. More recently, a waterborne outbreak in Las Vegas caused at
least 20 deaths.

.(Food Safety from Farm to Table, A Report to the President, May 1997) According to the CDC's Dr. Davis Swerlow, the
problem has been getting worse. As an example, "Between 1982 and 1992 there were 15 reported deaths from of E.
coli . Now there are an estimated 200 to 250 deaths and 20,000 cases of E. coli-imduced disease reported every year
in the United States." (Public Facts #113)

* Not only that, but if your family has experienced life threatening liver, lung, heart, or brain illnesses, cancer, death or
even birth defects, you may have been touched by the plagues that have been released upon our lands by the same
three federal agencies, USDA, HHS, and EPA, who suggested to the President that cow manure was causing the
plagues. These food borne plagues have emerged under a 1981 policy decision by EPA, FDA (part of HHS), and
USDA, which promoted the use of toxic pathogen (disease causing organisms) contaminated sewage sludge as a safe
fertilizer for food crops, lawns, and gardens. The EPA created a written policy in 1984 and a federal regulation in 1993,
which eliminated all safety provisions of federal laws in the handling of sewage sludge, as long as it was called a

* President Clinton may have been serious when he made this statement: "We have built a solid foundation for the
health of America's families. But clearly we must do more. No parent should have to think twice about the juice they
pour their children at breakfast, or a hamburger ordered during dinner." -President Bill Clinton, Radio Address, January
25, 1997. To accomplished this he pledged 43 million dollars to fund a nationwide early-warning system for foodborne
illness. However, the  Agencies he directed to identify specific steps to improve food safety, Department of Agriculture
(USDA), Department of Health and Human Services (HHS) and the Environmental Protection Agency (EPA), were not
very serious when they presented their report, FOOD SAFETY FROM FARM TO TABLE, A Report to the President ,
May 1997. The Report suggested that the uncontrolled use of cow manure was the primary problem. It caused the E.
coli outbreaks in meat  and apple juice, Salmonella in eggs and on vegetables, Cyclospora on fruit, Cryptosporidium in
drinking water and Hepatitis A in frozen strawberries.

* The federal agencies, EPA, HHS, and USDA, have a serious problem with their facts. The Report to the President
quotes a 1994 report from The Council for Agricultural Science and Technology (CAST), a private nonprofit
organization, which only indicates "6.5 to 33 million illnesses in the United States each year are food related.", and only
9,000 deaths are attributed to food poisoning. (p.8) Where is the science?

The non-profit organization could not get closer than a 26 million case spread in its facts and there is still a difference
of 50 million cases of food poisoning between their best guess and the Center for Disease Control's (CDC) 1996 figure
of 80 million cases of foodborne diseases.

* The question is, why didn't the HHS use its own 1996 figures (CDC is a part of HHS), instead of the 1994 CAST
figures? In a paper presented at the Fourth World Congress on Environmental Health, Environmental Health - A Global
Challenge, in Aberdeen, Scotland, Ralph J. Touch, Chief Sanitarian, for the Department of Health and Human Service
quotes CDC in referring to the 80 million food poisoning incidents in the United States. (Emerging Infectious Diseases,
May, 27-31, 1996) Did the agencies lie to the President or did food poisoning incidents jump by 50 million cases in two

* The Report to the President implies a lack of scientific knowledge about disease causing agents, "Our understanding
of many pathogens and how they contaminate food is limited; for some contaminates, we do not know how much must
be present in food for there to be a risk of illness; for others we do not have the ability to detect their presence in food."

* The big push in the Report is to blame farmers and a lack of regulations for cow manure. "Milk, eggs, seafood, poultry,
and meat can become contaminated from contaminated feed, misuse of veterinary drugs, or poor farming practices, in
particular, mismanagement of animal manures." (p.9)

"Animal manures are currently excluded from the definition of solid waste under EPA's solid-waste-disposal regulation,
and therefore, an EPA regulatory mechanism does not exist for these materials." (p.11) "Food animals and their
manures can carry human pathogens, without any clinical manifestations. Likewise, fresh fruits, fresh vegetables, and
grains can  harbor pathogens or mycotoxins without any discernable loss of quality." (p.35)

* Furthermore, "Today, many pathogens in food and animal feed cannot be identified. Other pathogens have
developed resistance to time-tested controls such as heat and refrigeration." (p.6) The EPA's Office of Science and
technology also notes when the changes began and why new and resistance diseases are developing in a two page
paper on CAFO's prepared by Rita Schoeny, . "The incidences of  other morbidity and mortality from infectious disease
has been increasing over the past decade." 4/97

In fact, this is the same time frame in which we have seen the dramatic increase in the use of pathogen contaminated
sewage sludge. According to the Water Environment Federation, about half of the 8 to 9 million tons of sewage sludge
generated each year are now used on food crop production land, landscaping, home gardens, public sites, etc. In the
past decade we have seen the change from heat-dried sewage sludge fertilizer mixtures, which would have destroyed
most of the pathogens, to wet pathogen contaminated sewage sludge with reduced pathogens being dumped on food
crop production land as a safe fertilizer. Indirectly, in trying to blame the problems on manure, EPA's Schoeny tells us
what is happening when pathogens are only reduced in sludge used as a fertilizer, not eliminated. Sludge is
concentrated human manure from homes and hospitals and according to Schoeny "Manure provides a rich medium as
well as a natural incubator for growth of animal microflora. Organisms can grow rapidly (population doubling time can be
less than an hour) which provides opportunity for mutants or variants to develop. For a human variant (for example one
resistant to disease) to become established in a population may take decades if not hundreds of years. A bacterial
mutant can develop and become established in a matter of days. In addition, there are data to indicate that bacteria
with increased virulence have greater than normal rates of mutation."

Furthermore, "Manure spread on land and feedlots are visited by vectors which can spread micro-organism: these
include insects, animals such as rats or dogs, birds and humans. Manure is also the ideal place for various
microorganisms to encounter one another and exchange genetic material: bacteria and viruses exchange DNA
frequently and across species lines. "

* The EPA documented 25 family groups of pathogens in its 1989 proposed sludge regulation 40 CFR 257/503 which
promoted the use of pathogen contaminated sewage sludge as a safe fertilizer for food crops, pasture land and lawns
as well as gardens. Whereas, the USDA only gave medical cost and productivity loss estimates for seven specific
pathogens in the Report to the President. The estimated cost was 6.5 to 34.9 billion dollars annually. (p.8)

* How contaminated is the sewage sludge? No one knows for  sure. According to EPA regulation 503, most of the
sewage sludge used as a fertilizer on food crops is "required" to have less than 2,000,000 fecal coliform bacteria per
gram of solids or 2,000,000 colony forming units per gram of solids. The EPA assumes this will protect our food supply
from being contaminated by the other 25 family groups of pathogens as well as the unknown pathogens, even though it
acknowledges the explosive regrowth potential of the pathogens.

* According to the EPA, the situation is much worse than the National Sludge Alliance (NSA) imagined, when it was
formed one year ago to stop the plagues. NSA emphasized the need for a food labeling law as a quick fix because 46 of
the 50 states allowed the uncontrolled dumping of pathogen contaminated sewage sludge on food crops. However, the
real extent of the potential food poisoning problem from pathogen contaminated sludge was given on CNN's Hazardous
Harvest report (6-27-1997) by EPA representative Dana Minerva, "For one thing, Biosolids sewage sludge are in a lot
of different -- they are in a lot of different fertilizers, used as filler in fertilizer, so you'd almost have to label ever single
jar and can."

* If our food supply has been contaminated to the extent that every single jar and can of food would have to be labeled
that was grown on sewage sludge land, America as we know it, is in serious trouble and there is no reason to question
the CDC figure of 80 million annual cases of food poisoning.

* EPA engineer, Hugh Kaufman, who exposed the toxic waste dumping problems at Love Canal, NY. and Times Beach,
Mo. (the people of both places had to abandon the sites) was quoted in the same CNN report and put a face on the
plagues in simple terms, "Official U.S. government policy in the Clinton administration is to grow food-chain crops - The
food supply of America - on poison and not to tell the public." The question left unanswered is, what happens after our
farmlands are poisoned beyond the point of use?

* The official government policy is that toxic pathogen contaminated sewage sludge (Biosolids) has been scientifically
proven to be a safe fertilizer when used as directed by EPA regulations. However, as Kaufman noted, that is not the
case. The EPA's 1993 Sewage sludge Use and Disposal Regulation verifies his claim. According to the definition of a
pollutant in the regulation, the EPA administrator has information that exposure to any of the pollutants in sewage
sludge, i.e., pathogenic disease causing organisms, organic or inorganic toxic elements (or a combination of them) may
cause disease, cancer, death, physical or mental problems, genetic problems or birth defects when exposure is through
the food-chain. Of course the same pollutants are more deadly when the exposure is direct, by inhalation or ingestion.

* The Report to the President also failed to note that pathogenic contamination of food products could be caused by
transportation of food products in sewage contaminated trucks and trailers, as documented by the Pennsylvania
Environmental Department, January 10, 1997.

* If Mr. Clinton is really interested in stopping the plagues that are destroying the people and land of our great nation,
he could save 43 million dollars, the laws are already in place. The Resource Conservation and Recovery Act classified
sewage sludge as a solid waste which must be safely disposed of in a sanitary landfill! There is no exclusion in any law
for the sludge generated by a treatment plant to be used as an uncontrolled fertilizer, by the simple act of calling it a
fertilizer. -LSI-