Dear Neighbor,

There is growing concern among farmers and neighbors in Loudoun County and throughout the country about the health and environmental safety of Class A, B and EQ sewage sludge applied to pastures, fields, gardens, schools, and recreational areas. At the present time, the Environmental Protection Agency (EPA) and the Virginia Department of Health (VDH) act as both regulators and promoters of land-applied sludge. In this conflicted role, the EPA and VDH promote land application of sludge while failing to acknowledge fully the risks to humans, livestock and land. 

Farmland has become the cheap dumping ground of waste for government and industry. Those who permit Class A, B and EQ sludge on their fields may benefit temporarily from "free" fertilizer and increased yields, but they have not been provided all of the facts relating to long-term possible health hazards, damage to crops and livestock, restrictions on land use and sale, and potential civil liability. 

To begin with, we are told that sewage sludge, also known as biosolids, is recycled "domestic waste." In fact, it is "a semi-solid mixture of bacteria, virus-laden organic matter, toxic metals, synthetic organic chemicals, and settled solids removed from domestic and industrial waste at sewage treatment plants." Harper-Collins Dictionary of Environmental Science. Making matters worse, current federal regulations allow every business to dump 33 pounds of hazardous waste into public sewers every month without reporting or scrutiny. It is little wonder that the Federal Clean Water Act has classified sewage sludge as a pollutant. The EPA is charged with safe disposal. But this is not happening.

In 2002, the National Research Council of the National Academy of Sciences and the EPA's own Inspector General conducted independent investigations of the EPA's regulation of sludge. Both issued reports sharply critical of the analysis and management policies of the EPA's 10 year old 503 Sludge Rule. The reports concluded that the scientific research essential to support the 503 Sludge Rule were outdated, inadequate, or simply never were conducted. 

Of first importance is our health and safety. Dr. David Lewis, a prominent EPA microbiologist, recently co-authored a peer-reviewed study in a medical journal linking human proximity to sludged fields with a variety of illnesses and two deaths. The most common symptoms are burning eyes, nose, and throat; headache; difficulty breathing; rash; nausea/vomiting; diarrhea; respiratory illnesses; flu-like symptoms; nose bleed; rectal bleeding; and fatigue. The many illnesses that have been reported in Loudoun and neighboring counties near where sludge has been applied are the same as those Dr. Lewis, physicians and scientists describe in their study. One death attributed to sludge generated a lawsuits that settled out of court for an undisclosed amount. Landowners are potentially liable if sludge spread on their fields is shown to be the cause of injury or death, even if they play no direct role in the processing or application of the harmful sludge. On the other hand, farmers themselves can be the injured parties. A federal jury in Miami awarded $3.9 million to a farmer who proved contaminants in 296 tons of Dade County sewage sludge destroyed 500 acres of papayas. 

On November 26, 2002, Dr. Lewis and Patricia Millner, a US Department of Agriculture scientist chosen by the EPA to study the health effects of sludge, addressed the Loudoun County Technical Committee on Land Application of Biosolids (TCLAB). The TCLAB was appointed by the Board of Supervisors to study the issue of sludge use in the County as a result of citizen concerns and complaints. While Dr. Lewis laid out the current evidence linking sludge to illness, Ms. Millner was unable to give assurance of the absolute safety of sludge applied to fields because the studies needed to reach that conclusion are just now being considered and would take years to evaluate. Two previous speakers before the Committee also acknowledged there are no existing scientific studies that prove sludge is safe for pubic health. 

In the 1980s, the Wisconsin dairy industry was driven to near ruin by the PCBs in sludge that found their way into milk. Sludge spread on farmland may contain contaminants such as dioxin that were not even considered when the 503 Sludge Rule was drafted. The EPA currently regulates only 9 metals in sludge and tolerances are up to 100 times greater than other industrial countries allow. Heavy metals can pollute surface water and can leach into ground water. Even if sludge processors and haulers follow all existing requirements, serious harm may come to farmers and their neighbors. 

Only some 15 of the over 1,000 farms in Loudoun County have sought permits for Class B sludge use. However, these Class B permits encompass several thousand acres, some of it close to residential neighborhoods. Because farms applying Class A or EQ sewage sludge have no permit or other reporting requirement, the number involved is virtually impossible to uncover.

Awareness of this serious health and environmental problem is growing. We want Loudoun County farmers and their neighbors to be informed. Neighbors Against Toxic Sludge believes accurate information is empowering. We have collected hundreds of signatures on a petition asking the Board of Supervisors to suspend the spreading of sludge in the County until the questions raised by leading scientists, as well as our own common sense, can be answered. Much is at stake. We seek your involvement and support in safeguarding our health and well-being.

We would appreciate your comments and questions on this important issue. 

Sincerely,
Barbara L. Rubin
Susan Williams
Loudoun Neighbors Against Toxic Sludge (NATS)