Desert Dispatch
[Alan Rubin's]
Letters to the Editor

February 20, 2007 - 3:01PM

While biosolids have long been an integral component to
the recycling industry, most folks tend to think of
recycling in terms of bottles, aluminum cans or
newspapers. Biosolids, which are derived from human
sewage, is a topic most would rather just flush and forget.
But biosolid management is a necessity and biosolid
recycling is the environmentally preferred alternative.

The challenges to biosolids recycling aren't a matter of
safety or science; it's strictly a problem of perception.
Disappointingly, much of the debate is based on
emotions and feelings and not on science.

Biosolids begin at the wastewater treatment facility where
95 percent of the pathogens are removed leaving just
nutrient-rich material that is an effective and beneficial
organic fertilizer. In fact 60 percent of biosolids in
California are directly applied to crops.

However, Nursery Products will add a margin of safety to
this recycling activity by composting the biosolids. That
means biosolids will be mixed with green material like
wood chips and wood scraps from furniture
manufacturers. During the composting process, the
product heats up to 131 degrees for a minimum of 15
days killing off the remaining 5 percent of pathogens and
viruses that possibly survived the wastewater treatment
process. This results in compost that is 100 percent safe.
In fact, this is the same compost sold in your local Home
Depot or Lowe's garden department.

Scientists have been studying biosolid recycling for
decades and there is not one peer-reviewed study that
shows evidence that this process poses any human
health risk. Not one.

There are open-air biosolid recycling facilities in more
than 4,000 other communities throughout the United
States that have operated safely and successfully for
decades. Many of these facilities have neighbors much
closer than eight miles yet there is no evidence of any
health impacts to these communities.

In fact, the open-air composting site in Austin, Texas,
which has operated since 1989 is closer to downtown
Austin than the Nursery Products site is to Hinkley. The
Austin composting site is less than six miles from the
University of Texas, Sixth Street, and even the State
Capitol and Governor's Mansion downtown. Austin is one
of the top tourist destinations in Texas and many of the
Austin residents purchase the compost created at the
site for their own gardening use. There is no evidence
that any Austin residents or tourists have suffered any ill
health effects and in fact the Longhorns football team
won the college national championship in 2006 practicing
and playing their home games within six miles of this
biosolid composting site.

This project is safe and this process is safe and will have
no impact on Hinkley. Anyone who claims that biosolid
recycling poses public health risks is using scare tactics
and not science.

Alan B. Rubin, Ph.D

Dr. Rubin is an environmental consultant for Nursery
Products and was the Environmental Protection Agency's
(EPA) Chief of the Biosolids Risk-Assessment Branch.
During his 28-year tenure at EPA, Dr. Rubin appeared as
a federal government expert witness to testify in support
of the Part 503 Standards that were developed to protect
public health and the environment as they pertain to
biosolids management.
Dr. Alan Rubin's February 20, 2007 letter to the editor
would be funny if he wasn't the expert and knows better and
likes to tell half truths sometimes. Biological solids in
sewage are derived from human waste and industrial waste
that pass through the sewage treatment process. Biological
solids sludge management is mandated under the
where it is listed as a solid waste. In spite of the laws, a few
powerful people created a recycling program before most
pollutants could even be identified.

Since EPA has admitted there is absolutely
no science or
safety behind biosolids recycling, It is strange that Rubin
would still be trying to
change public perception just to
justify wasting his life and destroying many more.

Wastewater treatment does remove about 95 percent of the
chemicals, pathogens (bacteria, viruses) and solids from
sewage. These biological solids make up 1/2 to 4 percent of
the sludge leaving the treatment plant.
 60% of these
biological solids are now directly applied to crops in
California?. Some pathogens may be inactivated for a short
Others are not affected.

EPA has stated in the current Biosolids composting fact
sheet that "Potential environmental impacts may result from
both composting operations and use of the compost
product. Survival and presence of primary pathogens in the
product." "Composting is not a sterilization process and a
properly composted product maintains an active
population of beneficial microorganisms that compete
against the pathogenic members. Under some
conditions ,explosive regrowth of pathogenic
microorganisms is possible. Dispersion of secondary
pathogens such as Aspergillus fumigatus, particulate
matter,other airborne allergens"

What Rubin meant to say is that there is
not one peer
reviewed study that states the biological solids in sludge are
safe for public exposure. EPA's own
David Lewis had a peer
reviewed published study showing health risks to real

What Rubin meant to say was that since EPA and the state
environmental departments approved these composting
all agencies have refused to investigate any
health complaints from the people in these communities.

The agencies have betrayed their trust.

Since 1986,  food poisoning incidences have explode from
2 million to 76 million in 1999. But when we observe the big
Papillomavirus now infect 25 million female
children  and women. No one has any idea how many male
children and men are infected even though CDC classified
it as a sexually transmitted disease.
Attention-Deficit/Hyperactivity Disorder (ADHD) among our
children and adults has  exploded and is now epidemic
effecting 5-7-percent or more of our children -- and adults.
The paramyxoviruses, which causes mumps and measles
caused 745,000 deaths in 2001. Human Obesity is now
epidemic. Autism is epidemic with 1 in 150 children effected.
Acid refux disease is epidemic. Alzheimer's disease is
epidemic. The we have the flesh eating bugs,  Staph bug
causes new (Necrotizing) pneumonia,  Aspergillus
Necrotizing pneumonia, Group A Strep Necrotizing
pneumonia, E. Coli Necrotizing pneumonia, Yersinis
pneumonia. Without immediate medical attention, life
expectancy is from 72 hours to one week.

EPA acknowledges that
exposure to a pollutant (chemical,
bacteria, virus, etc.) in biosolids/sludge through the air,
water or 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
[people] or offspring [children] of the organisms [people]."
FR. 58, 32, p. 9389 - part 503.9(t)

Jim Bynum

17 year
sludge researcher.
Biosolids management is not addressed anywhere in the
Part 503 Standards. "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." (FR. 58, p. 9252)
                                with response by Jim Bynum

Chemicals, and pathogens - bacteria and viruses- (biological solids) IN
SLUDGE are known to cause
neurological damage. Could Rubin have been

Time article, September 27, 1999

Response to Rubin's letter to Editor
by Jim Bynum

Letters to the Editor March 30, 2007
Alan Rubin claims to have written the Part 503 sludge
guidelines, which was based on
exclusions in the laws,
and published in
February 1993.
Jim Bynum wrote the paper "Sludge Disposal: Sanitary
Landfill-Open Dump-Superfund Site?" which was published
by the New Mexico Environment Depart. in
February 1993