April 27, 2008
Look closely at the Baltimore Orgro Lead Contamination Study:
Maureen Reilly
Sludge Watch

"Biosolids compost amendment for reducing soil lead hazards: a
pilot study of Orgro amendment and grass seeding in urban yards"
by Farfel, Orlova, Chaney, Lees, Rohde, Ashley

Intro - Why is lead contamination allowed to continue in poor

Many of us have been deeply shocked that in the USA rental residences
that have lead contaminated yards are not remediated....whether by
order to the owner, or at state expense. It is shocking that children living
in these housing units continue to be exposed to lead contaminated
properties and suffer neurological damage as a result.

How does the Ontario Government respond to contaminated

I recently asked Ontario officials what would happen if such contamination
were found in this jurisdiction.

I was told that this would be considered environmental pollution that is
causing an 'adverse effect' and that when the provincial government
became aware of the problem they would order the property owner to
remediate the yards.  If the contamination was linked to an offsite
industrial source, then the owner of the pollution source might receive an
order to clean up the properties.

The owners would likely hire consultants to develop a remediation
strategy which the Ministry of the Environment would review, or the
Ministry experts would order a clean up, specifying how it would be done
and when it would be completed.

The site would be tested...and if say, the surface of the soil was the most
contaminated, they would remove the soil with the highest lead
concentration very carefully, so as not to release it as dust during the
clean up. The point is not to just dilute the problem contamination but to
isolate and remove the high concentration contaminated soil. Then they
would remediate the rest in such a way to minimize the amount of fugitive
dust, and in a way that would keep the lead from being dispersed
throughout the community.

So why doesn't this happen in the USA?

Let us compare this with what happened in Baltimore

In Baltimore the suggestion is that there was no lead remediation
because there is said to be no industrial source responsible for the lead.  
Is anyone really clear where the lead came from?  I hear lead paint on the
exterior of the buildings, and maybe a smelter was once in the

So if it is from the rental units, why are the property owners not obligated
to do the cleanup?

So in Baltimore, rather than spending a half million to remove the lead
from these properties,  Farfel, Chaney, et al were given nearly a half
million dollars in government funds to undertake this research project.  .   

Did they remove any contaminated soil?  No

Did they contain the contaminated soil?  No

Did they take steps to be sure not to get dust into the air?
No - just the opposite. They rototilled it - twice

Did they expose families and children to dust during the yard
remediation? - YES

First- by rototilling the lead contaminated soil twice

Second  - Did they seek to make sure that the bare soil (some of it 5 or 6
times the EPA maximum for children's play area) was covered, so families
were protected from lead dust ?  

NO - indeed they took off all the plants that were holding down the soil,
rototilled the contaminated soil into fine dirt, and then LEFT THE SOIL
BARE.  Instead of putting down sod to hold down the contaminated dirt
(contaminated with lead and whatever was in the sludge) they just put
grass seed on.

Third - They did not rope off or fence off the now bare soil yards. There
was nothing to stop people from walking across the bare soil, crushing
the grass seedlings, and tracking the lead and sludge contaminated soil
into homes and cars -tracking it into dust to blow around the

Did they maintain the yards?  No....only one yard was maintained by the
researchers.  The residents were somehow supposed to maintain the
seeded yards by themselves.

Did they provide the residents with the means to maintain the new growth
on the lead contaminated sludge spread properties?  No
Did they provide sprinklers and hoses?  Lawn mowers?    

No.   In fact the authors say a follow up study is needed to "assess the
ability of residents to maintain a grass cover". see page 93

Is there any evidence that the grass grew in these bare soil yards seeded
with grass? - No.

There is only one photo of grass growing in a yard - which was likely the
one yard the researchers watered and maintained

So the researchers - claiming that the poor black kids would now ingest
soil that was mixed with sludge argued that eating the sludge-amended
lead-contaminated soil would result in lower lead levels in the childrens'
blood.  Not only did they not take steps to stop fugitive lead contaminated
dust - they argued that ingesting the sludge amended dust would be

But they didn't check the childrens' blood - neither before nor after the
experiment.  They did not check for lead, they did not check for sludge
related diseases or conditions either.

What the researchers did left this community MORE exposed to lead than
before during the course of the experiment.  And even though they said
the purpose was to see if they could reduce the exposure of the residents
to lead, they never used ANY indicators to see if the experiment actually
resulted in lower exposure to lead.

Many Unanswered questions

Why were the residents not told that sewage sludge compost would be
brought to their homes?

Why did the researchers not disclose the levels of all the Part 503 and
Maryland state sludge compost requirements for toxic metals and PCBs?  
Why did they fail to provide the required test results on selenium,
molybdenum, mercury, and PCBs?  Why is there no data on the
pathogens in the sludge compost?  Why is all the historic analytical data
for Orgro toxic metals  in the form of ‘personal communications’ and not
lab reports?

The researchers declared the experiment a success - because they said
that the bioavailability of the lead in the amended soil was lower in the
final soil than in the unamended boxed soil samples.

Certainly some of the lowering of the lead levels was due to the dilution
effect.  But  - had they put far more lead dust into the community and the
community homes by their actions?  As a result of stripping off the grass
cover and tilling up the lead contaminated yards  and leaving them in a
bare and friable state have they dramatically increased the lead ingested
by the families and children?

They never checked.  Did the contaminants including metals, neurotoxins,
and pathogens in the sludge result in illness?  

They didn’t check.

Researchers made the yards more dangerous by digging up the
contaminated soils

The researchers claim, in the study, that the original condition of the
yards - with a few bare patches of hard packed lead contaminated earth -
was a risk to the community from windblown dirt.  So what did they do?  
They took off all the plants that were holding down the contaminated soil,
rototilled it up twice to make it loose and friable, and then left it like that -
to blow around the lead contamination on a wholesale basis.

And of course, did the families - already weakened from lead exposure -
suffer other health problems because their immune impaired bodies now
had to deal with arsenic, mercury, and other toxins  and endotoxin
pathogens in the sludged soil?

We don't know. They didn't do any health checkups.  Not for lead. Not for

While explaining that they were looking for a cheap way for lead
contaminated residents to do their own  hazardous lead home
improvement project -  these researchers arguably endangered these

Was there even one yard that was kept as a ‘control field’?

The researchers put some dirt from the yards in a container and kept it
for a year.

Even this dirt showed an 8% reduction in lead bioavailability.  
If they really wanted to show that their treatment made a difference they
should have used one yard as a control.  Maybe they did, and then just
wrote it out of the study?

Could any reviewer think it is not extraordinary to have an experimental
design that involves waiting a year, scraping off the top layer of soil,
testing what is underneath,  and representing the results as an accurate
sampling of the community exposure ?   Would the local families scrape
off the top level of soil and be exposed to the under soil?  No. At the year’
s end, the community  would be most exposed to the top level of soil…the
soil that was not tested.

But the journal “Science of the Total Environment” refuses to say who
peer reviewed this paper.

Project designed to achieve skewed results.

Here is a curious fact.  When they did the first tests on the yards they
measured the dirt in the yards 'as is'.   When they went back one year
later they scraped off the top - most contaminated - layer of soil off the
sampling site and THEN took their sample.  Voila - lower levels of lead.

The project design on page 83 states:

“Thus, the composted biosolids amendment approach has the potential to
reduce risk from Pb in urban soils by reducing direct contact with bare soil
-transfer of soil into the house and The bioavailability of Pb in ingested

But we see that what the researchers did to the soil in the yards
INCREASED direct contact with bare soil, and was likely to INCREASE
transfer of soil into the house.

So lets look at Lead (Pb) bioavailability

Was there a genuine drop in lead bioavailability?
Hard to say.  There is an intriguing note on page 93 that states that there
may be a drop in in bioaccessible lead “as a result of an artifact of
bioaccessibility testing in that the chemical reactions to make
pyromorphite occur during the extraction as well as in the field.”

So was the bioassessibility data in any way meaningful?  Was the
bioassessibility only an artifact of the test methods they used?
Were there weeds at the test location?  In fact if there was clover growing
on some yards, the clover could have done a phytoextraction of the lead
in the soil samples.  

And why are there suddenly only 8 yards under study? What happened
to the 9th yard?  Why is there no yard by yard data? Why is the data all

Dust studies

The big issue for community exposure was said to be the dust that could
blow into homes.  So why is there no detailed analysis of this dust
provided in the study?  Why are we told that dust followup studies are


If the top layer of soil is such an important reflection of community
exposure, why is this layer removed in the experimental design, before
arriving at the soil test results at the one year {follow up} mark?  This
project was designed to advertise sludge as providing a method for lead
remediation, when in reality the testing and test reporting was skewed to
provide misleading results and unsupported conclusions.

Where is the community participation?

They claim they did this study with the participation of community

Where is their input? Where are their comments on the study?
The researchers claim they sent the participants copies of the lead tests
on their yards. Why is this data not included in the study?

Were Occupational Health and Safety requirements met?

My understanding is that remediating a lead contaminated site requires
workers with respirators and hazmat training. These residents don't have
the equipment or training to do soil remediation. This is a preposterous

What about the money?

What the researchers do want is to find a way to get rid of all the sludge
compost.  Interesting that the Orgro webpages say the sludge compost is
available for $3 - $9 per yard.
(http:// wasteage.com/mag/waste_composting_baltimore_city)

But the Farfel paper says it is worth $30 per yard.

Did USFilter get a charitable receipt for their 'donation' of Orgro?  Did
they inflate the value fraudulently to get a tax receipt for their 'charitable

And where did all that grant money go?  The researchers brag that they
did this 'clean up' for only $150 - $350 per yard.   Lets see...that is less
than $4000 for the whole nine yards.

Grant money of  $446, 231 minus $4,000 which includes the $10 in food
coupons they gave each household as an inducement to participate and
... lets see....

So what did they do with the other $442,231?

This research was to justify more sludge dumping in poor, contaminated

This piece of fiddled research was meant to provide academic cover to
use sewage sludge to ‘remediate’ poor contaminated neighborhoods.
Even though there is absolutely no evidence that this treatment reduced
lead exposures or improved local health, the study team declared that
“this study confirms the viability of in situ remediation of soils in urban
areas where children are at risk of high Pb exposure from lead in paint,
dust, and soil.”

It confirms no such thing.  After the sludge application not even one of the
9 yards had their soil levels reduced to under the EPA  lead in soil limit  of
400 ppm.

All the properties still tested out at over 400 ppm lead – over the
children’s playground limits for lead - at the close of the experiment.

Where do we go from here?

WE need an audit of this experiment.  
A science audit.  
A toxicology audit.
An occupational health and safety audit.  
A financial audit.
A granting projects audit.
An ethics audit.  
We need an inquiry into what kind of research is being
undertaken at the expense of these lives.

Maureen Reilly
Sludge Watch
April 27, 2008
Downloaded April 27, 2008

Tuesday, April 15, 2008
Scientific Literacy and Sensationalist Journalism

Sarah Werning
Museum of Paleontology and Department of Integrative Biology University
of California, Berkeley

This morning my friend Dan sent me a link to this AP News story: Sludge
Tested As Lead Poisoning Fix.

The story begins: "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."

Holy crap. This is good lead, well-written, and it suggests everything is still
wrong with the world. The government is funding scientists to run
experiments on the effects of toxic and human waste on poor black
families? It's a horrible, horrible thing, if it's true, and both the US
government and agribusiness have funded this sort of terrible experiment
on minorities and on the poor in the past. It brings to mind all sorts of
eugenics nightmares, and our country unfortunately has a rich tradition of
doing much worse to the poor and to minorities. So on the surface it
seems tragically plausible.

The story continues: "Nine low-income families in Baltimore row houses
agreed to let researchers till the sewage sludge into their yards and plant
new grass. In exchange, they were given food coupons as well as the free
lawns as part of a study published in 2005 and funded by the Housing and
Urban Development Department." It then goes on to explain that the high
levels of phosphate in the sludge can bind to heavy metals, including lead,
"allowing the combination to pass safely through a child's body if eaten",
and that federal policy has been based on this idea for decades, despite a
1978 Environmental Protection Agency (EPA) memo that said the sludge "
'contains nutrients and organic matter which have considerable benefit for
land and crops' despite the presence of 'low levels of toxic substances' ".

Wow. So the sludge itself, already toxic, contains additional toxins, and the
EPA has known for years. Furthermore, a scientist at the National
Academy of Science (who is a Johns Hopkins professor of public health)
worries that the sludge is worse than that: it's human waste, so there's
nasty microbes in it. And the EPA funded another study to test the sludge
in another poor black neighborhood in East Saint Louis, IL, to see if the
phosphates did bind to lead... this time in a vacant lot next to an
elementary school. So, all in all, things look bad for this study. At this point
I asked, "Why would the government fund this sort of study? Especially
when I have such non-controversial paleo research in need of funding?"

At this point, the story started raising red flags with me. It quotes a local
environmental advocate: "If you wanted to do something very
questionable, you would do it in a neighborhood that's not going to be
there in a few years", then launches into a description of the main
researcher, Mark Farfel, also at the Johns Hopkins School of Public Health
(remember? his critic above also was there. But so are three more of
Farfel's co-authors. Red flag.). Apparently, he is also the recipient of
several government-funded projects looking at the effects of lead in urban
poor neighborhoods. The article seems to imply that his reign of lead and
toxic waste terror extends further than this study, but to me it makes sense
that if he studies the effects of lead poisoning, he would do it more than
once, and in areas with high levels of lead. I dismissed this as the
reporters not understanding the nature of scientific specialization. The
story briefly mentions that the study passed the standards at Johns
Hopkins for public health studies involving humans.

The story then takes an abrupt turn for the conspiratorial. The last part of
the article starts by saying Farfel denied repeated requests for interviews
(What does he have to hide???), then makes a point of stating that Farfel
now works interviewing 9/11 victims. Are we supposed to assume he is
now torturing 9/11 victims, poisoning them with human and toxic waste, like
he did to the urban poor? The story next explains that some of his
previous work has been controversial, that people associated with his
previous research have sued for lead poisoning. Scientifically, this is a
methodological red flag for me, but the article doesn't dwell on what
happened to those people, only commenting on the resulting court case:
"The Maryland Court of Appeals likened the study to Nazi medical
research on concentration camp prisoners, the U.S. government's 40-year
Tuskegee study that denied treatment for syphilis to black men in order to
study the illness and Japan's use of 'plague bombs' in World War II to
infect and study entire villages." So you are left with the impression that
this racist, immoral asshole is exploiting American tax dollars to poison the
poor. He's done it in the past, therefore he is doing it now.

So, is this a case of horrible people (Nazi-esque, even) taking advantage
of government funding to perform experiments on poor minorities? Is this a
return to eugenics? Or, is this a case of a story taking advantage of
Americans' lack of scientific literacy to sell papers (or gun for a Pulitzer)? I
decided to look into it. Fortunately, the research in this study was
published [1] (though I couldn't track down a reference for the case that
went to court), and even better, my university had access to the journal.
So I read the article, and now I would like to call into question some of the
'facts' in the AP story:

As it turns out, it's not raw sewage at all. It's not a sludge. It's not even
liquid. The product they used in this study is a compost fertilizer called
Orgro, and you can buy it in bulk commercially, or at a garden store. One
of its ingredients is treated human sewage, but it is composted with
woodchips and sawdust first. According to the study, Orgro "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". This is
important because to get that certification, you have to make sure it is safe
to put on people's lawns. So the rules are: any fertilizer that uses any
animal or human waste must be pasteurized to kill pathogens before it can
be sold and used for residential purposes. This process is how we make
milk safe to drink. While you probably wouldn't want to make an Orgro
milkshake, I think it's safe to assume the bad microbes are pretty much
nonexistant in Orgro. The article points out that there were already people
in Baltimore using it to make their lawns look nicer before the study
started. And this site claims that Orgro is "sold for use on golf courses,
athletic surfaces and the lawn of the residence of the Vice President of the
United States". So: safe enough for rich people.

Orgro is rich in phosphate and iron, and both (but especially phosphate)
bind to lead (and zinc, another contaminant) in a way that makes it
nonsoluble (so it won't dissolve when it rains) and bio-inaccessible (so
organic things can't break it down with enzymes and then become
poisoned). So it's marketed as a fertilizer that can make your
contaminated soil grow plants again. And because of this, it also has been
used as a treatment for toxic soils. In this study, they mixed the Orgro
(which, again, is compost, not raw sewage) with the first ten or twelve
inches of soil, then seeded it.

So where does this research come in? There are two problems the study
is trying to address: there is a lot of lead in urban soils, and the soil is well-
exposed because plants can't grow there (because there's too much lead
and lead is toxic to plants). So when kids play on the soil, it's easy for kids
to get at and be exposed to the lead in the soil. The kids undoubtedly
already had lead levels before the start of the study. Now, the best way to
clean up lead contaminated soils is to completely replace it with new clean
soil, which brings us to the second problem: most cities can't afford to
remove all the soil and bring new stuff in, and federal government
regulations are written such that unless it is a Superfund site, they will not
pay for soil replacement. The study cites long-term studies on the health
risks of this stuff, and it has been used before in non-urban toxic places
(in MO, ID, PA, and Poland, as well as several Superfund sites). They
know what high doses do to small animals and adult humans. Orgro just
had not been field tested in an urban setting before. The idea behind the
study was that it could be a cheaper way (and thus, affordable to urban
homeowners and cities) to treat soil for lead, and at the same time, get the
soil covered up with grass so the kids had less direct access to it.

The study did not test whether stomach acids can break the bonds
between phosphates and lead. That may be true, or it may not be. I don't
know how long something that is bio-inaccessible can stay that way. But
the study did find that the bio-accessible lead levels were reduced by 50-
70% in one year, in the areas of highest concentration. We're not talking
low levels of lead here, either; many of these lawns had lead levels 3-5
times higher than the EPA's maximum safe amount. If anyone in this study
has elevated lead levels at the end of the study, I'd bet a lot of money that
they had them before the start of the study. And it did show that Orgro can
be used to grow grass where little grass grew before (the pics are pretty
amazing). So the study succeeds in both counts: neutralization of lead and
preventing access to lead in soils by covering it up with grass.

This interested me a lot. What were the toxins that Orgro (again, not
sludge) was putting into the soil, the toxins the landowners weren't
informed of? We know from above that it's not microbes. Does the study
address this at all? It turns out that it does. The toxins in question are...
heavy metals. That's right, stuff like lead and zinc, which is present in all
soils to some extent. And they know how much was in the Orgro, because
they tested it. They needed to measure it as a control on the experiment;
they needed to know how much they were adding to the system, because
those were the exact things they were trying to neutralize in the soil. It
turns out that the levels of heavy metals in the soil were very, very low;
much lower than the EPA's safe amounts, and negligible when compared
to what was already in the soil.

Now, I have no idea what motivates Mark Farfel to do his research. He
could hate the poor. He could hate black people. He could take personal
delight in seeing them sick and suffering. It does not come through in his
writing. His research seems sound to me, and he seems to be motivated
by helping people, not harming them. But I'm not an environmental
scientist, nor an epidemiologist. And, furthermore, I'm not completely sure
about the quality of the journal in which this study was published, "Science
of the Total Environment" (impact factor: 2.359, read more about it here).
But the article I read was peer-reviewed and pretty straightforward, and
didn't raise any statistical or methodological red flags with me. If you have
compelling arguments against the article, I'm open to hearing them. But in
the meantime, I think we can chalk this up to journalistic sensationalism.
Which kind of sucks for Mark Farfel, his co-authors, the study participants
who now feel victimized (unnecessarily), and the government agencies
who will now be pressured not to fund future research in this vein.

1. Farfel MR. 2005. Biosolids compost amendment for reducing soil lead
hazards: a pilot study of Orgro(R) amendment and grass seeding in urban
yards. Science of the Total Environment 340: 81– 95.

Posted by Sarah Werning at 4:34 AM
                                            SCIENTISTS CON SCIENTISTS
by Jim Bynum                                                                                                                                                                                                                                4/2008

When JOHN HEILPRIN and KEVIN S. VINEYS, Associated Press Writers exposed a very dangerous scientific study  perpetuated on a black Baltimore
neighborhood in their article
"Sludge fertilizer program spurs concerns", they were immediately attacked and accused of a lack of scientific literacy and
sensationalist journalism. Apparently, the attack was based on the mistaken belief that scientists don't con scientists and that a published peer
reviewed study actually meant that everyone involved understood the test, the science, and the law, governing the study.  If one assumes that is the
case, it becomes very easy to con scientists when a
government agency dangles a lot of money in front of a scientist who needs to be published and
organizations who need to raise money. The con game , backed up by a public relations campaign, extends into the scientific community at large and
the con game works.  The NAACP has requested a full investigation as it should.

The Feds gave the scientists $446,231.00 to dump
toxic carcinogen contaminated sludge compost on nine yards in a black neighborhood. The point
was to see if it controlled lead dust and bioavailability. There was no reason, or requirement, to test the actual children for
carcinogenic lead exposure
"-- a 1994 E.P.A. brochure says that biosolids may "protect child health." The brochure cites a study showing that animals that ingest
"biosolid-treated soil and dust may have a decreased absorption of lead into the blood stream, thus lessening the potential for lead-induced nerve and
brain damage."

As the Circuit Court for Baltimore City points out, "It can be argued that the researchers intended that the children be the canaries in the mines but
never clearly told the parents. (It was a practice in earlier years, and perhaps even now, for subsurface miners to rely on canaries to determine
whether dangerous levels of toxic gasses were accumulating in the mines. Canaries were particularly susceptible to such gasses. When the canaries
began to die, the miners knew that dangerous levels of gasses were accumulating.)"

Highly educated people don't like to think they can be conned. But it is easy. As an example: Sarah Werning posted the following on Treehugger blog:
"I encourage you to read the original study (which I would be happy to send you if you email me). I think the ABC/AP journalists are taking advantage of
American scientific illiteracy and our country's unfortunate history of screwing over the poor and minorities to push a sensationalist piece that seems to
reflect reality very poorly. I actually read the original scientific article (and blogged about it over at
http://bio-rocks.blogspot.com). Before it ever
reaches lawns (or the store, this product is commercially available), it is
composted for 45 days and then pasteurized (which is how we make milk safe
to drink). The substance they used is actually an organic compost fertilizer and not "sludge", as the article claims. As part of the study, the researchers
measured the amount of toxic chemicals (actually: trace amounts of lead, zinc, and other substances found naturally in soil) in the compost fertilizer
(which turns out to be extremely below the EPA's safe limits, and also negligible compared to what was already in the soil)."

She said, "One reason I wish more journals were open-access is that the media couldn't exploit people who don't have access to the original research
and make false claims. What we have here is an
environmentally-friendly, organic way to deal with human waste, that has been on the market for many
years. These journalists make it seem like the scientists poured raw sewage on poor people's lawns. They did not."
April 15, 2008 6:07 PM

Email correspondence with Sarah indicate this is her honest opinion. However, Canadian researcher Maureen Reilly thinks the study is flawed joke.

There are always two scientific views -- here are U.S and Canadian views. Which one do you accept?

Was Sarah Werning conned? Yes!
Read her reasoning
Was Maureen Reilly conned?  No!
Read her reasoning
128a00[1] Lead study.pdf