1. There is no scientific evidence to prove sludge is safe for public health. The 503 Sludge Rule does not address risks from inhaling lime dust and irritant gases or serious complications when exposed to a combination of pathogens and chemicals. 

            2. David L. Lewis proposes: "Land applying Class B sludges in residential areas should be prohibited based on: 
(a) documented adverse health effects associated with lime stabilized Class B sewage sludges, 
(b) an inability to assess risks associated with Class B sludges in general, 
(c) an inability to protect the public from exposure to dusts generated at land application sites, and 
(d) the absence of any means of monitoring adverse health effects. 
Residential areas should include lands where public exposure to treated fields may occur within the immediate foreseeable future." Other sludges should be treated to eliminate all pathogens and then treated for long term stabilization. 
Ellen Z. Harrison proposes: "Ban Class B which have the potential to pose pathogen risks Everywhere (or at least within 3 miles of occupied buildings including places of employment)". Same for septage. Also "Ban or restrict Class A products unless they can be shown to be stable and not create objectionable odors when wetted."

3. June 2002, Dr. David Lewis published 2 peer-reviewed studies: 
(a) One article, "Pathogen Risks from Applying Sewage Sludge to Land" appears in the well-respected scientific journal Environmental Science and Technology. It addresses the health issues surrounding use of sewage sludge, and discusses the risks associated with interaction of pathogens and chemicals. This interaction creates irritant gases that can break down our natural barriers to infection, leaving us more susceptible to pathogens. 
(b) The second article, "Interactions of Pathogens and Irritant Chemicals in Land Applied Sewage Sludge", appears in a well-respected medical journal. It links most of the illnesses we experienced in Loudoun County and 2 deaths to sludge exposure.

4. A September 6, 2002 memo from the EPA Inspector General to Christine Todd Whitman says in the memo: "With inadequate treatment these Biosolids may contain a wide variety of chemicals and pathogens, the remains of the sewage treatment process. 
(a) EPA does not know whether current regulations, when adhered to, are protective of public health; 
(b) EPA does not have an overall understanding of the magnitude and quality of Biosolids production and disposal practices;  
(c) EPA does not know if the enforcement and compliance resources committed to managing biosolids are adequate to ensure that the regulations are adhered to.  EPA has not conducted the basic research needed to determine the risk associated with certain biosolids disposal practices. EPA has failed to adhere to its commitment to comprehensively assess the extent of the risk …EPA committed to conducting a comprehensive research program to assess the risks associated with land application of biosolids, yet it has not yet done so. EPA uses the Permit Compliance System (PCS)…but PCS is acknowledged by the Office of Water (OW) as inadequate for managing biosolids. EPA has divined compliance and enforcement away from this program.” 

5. CDC/National Institute of Occupational Safety Health (NIOSH) found the guidelines of the 503 Sludge Rule were inadequate to protect workers exposed to sewage sludge. 
(a) “Both Class A & B biosolids contain chemicals (including metals) and allergens. To protect public health, EPA’s 40CFR Part 503 rule prescribes a restricted period of up to 1 year to limit public access to lands where Class B biosolids have been applied, and warnings about breathing dusts blowing from these areas for up to one year." 
(b) “Do we know these pathogens can cause disease? Yes.... exposure may potentially result in disease...” 
(c) “These enteric organisms are usually associated with self-limited gastrointestinal illnesses but can develop into more serious diseases in sensitive populations such as immune-compromised individuals, infants, young children and especially the elderly.” 
(d) “Class A biosolids may also pose health risks to workers, since some chemicals and biologic constituents in Class A biosolids are not regulated by EPA."
(e) "Also, farm workers may be exposed to biosolids after application and during the restricted period." (One year).
(f) "NIOSH interviewed employees who worked in all phases of the biosolids operation. Some employees reported episodes of gastrointestinal illness after working with biosolids, either at the treatment plant or during land application."

6. Dr. Rob Hale’s, researcher from Virginia Institute of Marine Sciences, studies indicate that chemicals and toxins in sludge are making their way into the environment and our bodies. Pathways of exposure include airborne dispersion, soil contamination, plant uptake, meat, milk, fish, etc. These deposits are cumulative and do not disappear. Dr. Hale cautions there may be learning and developmental, as well as, health effects. The US EPA standards allow sludge to contain many times the allowable amounts of toxins and chemicals as other industrialized nations. Research shows that the same equivalent factor of allowable toxins shows up in sludge samples. (e.g. If we allow 40% higher levels of flame retardant than Europe allows, it shows up 40% higher levels in our sludge.) . Pre-treatment of industry and hospital waste does nothing to curb these toxins because the organic pollutants Dr. Hale studied were not from industrial/hospital waste, but from domestic waste. 

7. Lead is allowed in sludge by the same government, which banned it from paint and gasoline. Lead can contaminate soils and leach into groundwater or may be found in crops grown in contaminated soils, or, meats, milk, etc. 

8. At its inception "the 503 Sludge Rule failed an extensive peer-review by scientists in EPA’s Office of Research and Development.  Almost without exception, EPA’s own scientists found the rule to be scientifically indefensible with regard to safeguarding public health and the environment, from heavy metals, organic chemicals, and pathogens in land applied sewage sludge...” 

9. In 2000, EPA’s own Inspector General found oversight of land application of sewage sludge under 503 to be ineffective. The report states “...while EPA promotes land application, EPA cannot assure the public that current land application practices are protective of human health and environment.” USEPA Biosolids Management and Enforcement Audit Report 2000-P-10. 

10. In Spring 2002 a second EPA Inspector General report blasted the sludge rule finding 10 major deficiencies in the sludge program. A few of the deficiencies are as follows: 
(a) Sewage sludge contains “toxic pollutants and disease-causing organisms” and “failure to properly manage sludge may have adverse effects on human health and the environment.” 
(b) EPA never conducted a risk-assessment on the harmful pathogens contained in sludge. 
(c) There are” uncertainties” in the science underlying the risk-assessment previously conducted on the sludge rule, “related to human health, human exposure pathways, plant toxicity and uptake, effects on wildlife and groundwater impacts.” 
(d) The sludge rule is based on “limited documentation” regarding the “long term behavior of metals in sludge” and the plant up-take of metals “found in sludge. e. “Nitrate leaching from biosolids into groundwater” can negatively impact “local wells and “surface waters.” 

11. July 2002, the National Academy of Science/National Research Council issue a report extremely critical of the sludge rule. The report proposed about 70 recommendations to try to improve the weak science and technology behind the sludge rule. Findings and recommendations include: 
(a) “The primary purpose of this report is to provide an evaluation of the risk-assessment methods and approaches used to establish the biosolids land application standards and is not an investigation into the validity of allegations of biosolids-related illnesses.” 
(b) “The lack of risk-assessment approach means that there is no explicit delineation of acceptable risk concentrations for Class A & B biosolids in Part 503 rule.” 
(c) “EPA did not consider airborne and waterborne release and dispersal of microorganisms for off site exposure.” 
(d) ”The absence of microorganisms in a small amount of material does not ensure that microorganisms are absent in a large sample from the source.” (Spot testing is pretty meaningless). 
(e) ”Exemptions for nutrient management and site restrictions for land application of bulk EQ biosolids should be eliminated.” 
(f) “Thus it is not possible to conduct a risk assessment for biosolids at this time (or perhaps ever) that will lead to risk-management strategies that will provide adequate health protection without some form of ongoing monitoring and surveillance.” 

12. Cornell Waste Management Institute has the only independent university study of Rule 503 available called "A Case for Caution", August 1997, and updated February 1999. Among the many problems Cornell University’s scientists found were the following: 
(a) Damage to organisms in soil such as nitrogen-fixing bacteria. 
(b) Need for stringent standards to prevent leaching of sludge-borne contaminants into groundwater. 
(c) Disregard for hazards of mercury, which EPA wrongly assumed did not volatilize from land application. 
(d) Bacteria can actually increase in numbers during sewage treatment processes 
(e) Dioxin not considered by EPA”. 

13. The Merck Manual 16th Edition. R. Berkow, and A. Fletcher, eds. a common physician’s handbook points out the serious risks of a combined exposure to pathogens and irritant chemicals, such as with some of the gases associated with sewage sludge: “The more soluble irritant gases cause severe burning and other manifestations of irritation of the eyes, nose, throat, trachea, and bronchi...Bacterial infections, common during the acute phase, are the most serious complications.” 

14. Even the 503 Sludge Rule assumes a significant risk of infection for up to one year from pathogens in land-applied sewage sludge. 

15. Untold numbers of people throughout the US who live near sludge fields or sludge sewage treatment plants complain about a range of health issues. Most people are not aware sludge can cause illness and death. Illnesses include, but are not limited to: severe respiratory problems, including pneumonia, sinus infection, asthma, flu-like symptoms, headaches, nausea, vomiting, bloody nose, rectal bleeding, lesions, rashes, burning eyes, nose and throat. Dr. Lewis said, “These illnesses are well documented among people who breath dusts and fumes blowing from sewage and sewage sludge operations.” [Including those just mentioned]. 

16. Susan Schiffman, et al. (Dr. John Walker, US EPA) draw the same conclusion in their article on potential health effects of odor. “Complaints of health symptoms from ambient air odors have become more frequent in communities with confined animal facilities, water treatment plants, and biosolids recycling operations. The most frequently reported health complaints include eye, nose, and throat irritation, headache, nausea, diarrhea, hoarseness, sore throat, cough, chest tightness, nasal congestion, palpitations, shortness of breath, stress, drowsiness, and alterations in mood.” 

17. Helane Shields of Alton, NH has compiled a Victims Sludge Report which now runs over 400 pages listed on the internet. (Cited in NAS report), Also Cornell’s Waste Management Institute is tracking some 350 individuals complaining of health problems associated with sludge. (See links.) 

18. Loudoun County residents have reported health complaints linked to spreading of Class B, Class A and EQ sludge. Complaints have been ignored, denied and called psychosomatic. Over 500 Loudoun County signatures were collected in less than a week on a petition asking for a moratorium on spreading sludge. 

19. Michael Vatalaro reports from LYCOS, March 22, 2000. “Members of House Science Committee blasted EPA for inappropriate responses to citizens and scientists who voiced concern over the use of sewage sludge as fertilizer on farmlands.” EPA sent threatening letters to a California farmer. According to testimony, “The EPA has suppressed the opinions of both EPA and independent scientists and tried to discredit science that does not agree with their safety assessments.” Testimony of Joseph Covalis, an industrial hygienist at the CDC said “...the position currently being taken by the EPA concerning sewage sludge was ‘indefensible from a public health standpoint’”. 

20. Switzerland has banned the use of sludge on farmland. Holland has banned sludge since 1991. Austria is banning sludge as of 2004. Germany has called for a sludge ban after decades of problems. Swedish and French farmers tell members to stop dumping sludge. Finland and Luxemburg are generally hostile to sludge. Denmark insists ALL pathogens are killed and has very strict limits on contaminants. They admit the practice can never be 100% safe. UK continues to dump despite crisis in farming industry. 

21. US EPA Region 8 (CO, UT, WY, MT) prohibits discharge of prion wastes to sewage treatment plants because the infectious prions will pass through the treatment plant as a pollutant to be released into receiving waters and concentrated in the sludge.  Prions are an infectious agent and often associated with Chronic Wasting Disease.  Biosolids are the solids produced by treatment plant and typically land applied to food and non-food (grazing) crops.
(Reference: http://cipca.org/regulatory/factsheetcwdpretreatment.pdf)

22. Any research done must be by independent scientists, who are not funded by financially interested parties. 

23. Living with sludge can result in a loss in property value.  

24. Landfilling cost - Refuting the myth landfilling is "more expensive" than land application (Link to separate page on -> Landfill Cost)

In addition National Sludge Alliance has published numerous fact sheets:

• #100 - EPA Overcomes Federal Prohibition Against Open Dumps
• #101 - The Bell Tolls for EPA
• #102 - The Law vs. EPA Science
• #103 - SLUDGE MAGIC - From New York City to Sierra Blanca, Texas
• #104 - EPA's Reckless Endangerment of Public Health
• #105 - EPA's Sludge Options: Open Dumps or Landfill Disposal
• #106 - The People vs. EPA & the Courts
• #107 - The Sludge Gets Deeper
• #108 - Public Health vs. Removal Credits
• #109 - Food Safety Claims
• #110 - Beneficial Use, Disease/Death: By Design or Ignorance?
• #111 - Caution: EPA Scientist at Work
• #112 - Deception-Deceit-Diversion
• #113 - Is It Toxic Sludge or Cow Manure Poisoning Our Food Supply?
• #114 - Toxic Sludge: Timeline to Disaster
• #122 - Catch 22 -- The Plight of the Farmer Who Accepts Sludge
• #123 - The Terrible Truth
• #127 - SEWAGE SLUDGE IS HAZARDOUS TO ENVIRONMENT
• #128 - Toxic/Hazardous Sludge Management is State/Local Responsibility
• #129 - EPA UNDERPLAYS DANGER TO FARMERS AND PUBLIC
• #131 - FARMS AND PUBLIC HEALTH DESTROYED --- FOR REMOVAL CREDITS
• #132 - BIOSOLIDS: 60s SCIENCE BRINGS DEATH IN DISGUISE
• #133 - A NEW GOD IS CREATED -- Regulation Authorize Lying to Public and Courts
  
  Pennsylvania Environmental Network's Sludge Leadership Team lists additional facts
  from the National Sludge Alliance may be viewed at http://www.penweb.org/issues/sludge/#nsa

For more "sludge facts", see www.sludgefacts.org

In the images below, cows are feeding on fields where Class B (Lime) sludge has been spread.     

              
  (Click image to open new window and enlarge)