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WHY WE ARE OPPOSED TO THE LAND APPLICATION OF SEWAGE SLUDGE
  RURAL AMERICA DEMANDS AN END TO THE LAND SPREADING OF MUNICIPAL SEWAGE SLUDGE ("BIOSOLIDS") FOR THE FOLLOWING
REASONS:

BECAUSE the Federal Clean Water Act defines sewage sludge as a "pollutant" [33 U.S.C.1362(6)];

BECAUSE the Harper-Collins Dictionary of Environmental Science describes sludge as: "A viscous, semisolid mixture of bacteria and virus-laden organic matter, toxic metals, synthetic organic chemicals, and settled solids removed from domestic and industrial waste water at sewage treatment plants";

BECAUSE the US EPA acknowledges that the pollutants and pathogenic organisms in sewage sludge ". . . upon exposure, ingestion, inhalation, or assimilation into an organisms either directly from the environment or indirectly by ingestion through the 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 or offspring of the organisms." [40 CFR Part 503.9 (f)]

BECAUSE official EPA policy is to dispose of landfill and Superfund leachates, radioactive wastes, and toxic commercial and industrial chemicals into public sewer systems, to be combined with residential sewage and other pathogenic sources, with the resultant sewage sludge/"biosolids" to be spread on the land in Rural America;

BECAUSE in 2004 the US EPA Office of Inspector General issued a critical report saying industrial pretreatment programs are at risk, they are low priority with EPA, toxic pollutants are still being transferred to sewage treatment plants, and "the impact to human health and the environment of some of these pollutants may still not be known;"

BECAUSE FEDERAL LAW permits every business and industry in the United States to dump 33 pounds of hazardous wastes into public sewers every month with no reporting requirements [ 40CFR 403.12)P)(2) ];

BECAUSE the EPA's Toxics Release Inventory (TRI) and public records indicate industrial pretreatment programs are inadequate, ineffective and/or not being enforced in states around the nation to control the discharge of toxic industrial chemicals into sewers. And the TRI reveals that the quantities of toxic metals and other hazardous chemicals being discharged into public sewers are increasing; and EPA acknowledges that the wastewater treatment process reconcentrates the pollutants in the treated sewage sludge/"biosolids";

BECAUSE in 2006, the Cornell Waste Management Institute released a peer reviewed study which found that some sewage sludges have such high levels of pollutants that they exceed the US EPA's Superfund Soil Screening Limits;

BECAUSE the waste industry in 1999 convinced Congress to exempt sewage treatment plants (POTWs) from any Superfund liability with regard to the toxic pollutants processed by such facilities;

BECAUSE the EPA acknowledges all treated sewage sludge ("biosolids"), both Class A and Class B, contains toxic metals including arsenic, antimony, beryllium, cadmium, chromium, lead, molybdenum and mercury; dangerous pesticides; toxic, bioaccumulative poisons including dioxins, furans, brominated flame retardants; and hazardous industrial wastes including solvents, cyanide, polycyclic aromatic hydrocarbons and other volatile and semi-volatile organic (carbon-based) chemicals;

BECAUSE the EPA allows Class B sewage sludge/"biosolids" to contain significant quantities of human pathogens [up to 2 million CFUs (colony forming units) of fecal coliforms per gram of total solids, dry weight], and slaughter house wastes, mortuary discharges and infectious hospital and institutional wastes, including disease-causing bacteria, viruses, virulent antibiotic resistant microbes, protozoa, intestinal parasites and parasitic worms;

BECAUSE the EPA acknowledges that sewage treatment plants can reconcentrate infectious prions from human and animal sources - (which can cause transmissible spongiform encephalopathies in humans and animals including scrapie, bovine spongiform encephalopathy [mad cow disease], and Creutzfeldt Jakob Disease (CJD), -- in Class B sewage sludge which is being top dressed (surface applied) on grazing lands and dairy pastures across the nation and also in Class A sewage sludge biosolids which is sold by the bag in WalMart, Home Depot, hardware stores, nurseries, etc. across the country to unsuspecting home gardeners;

BECAUSE the EPA has never conducted a risk assessment on the harm to human health from the pathogens in surface applied (top dressed) sludge including airborne pathogenic dusts, viruses, bacteria, endotoxins, molds, fungi, etc. despite increasing evidence from around the country that neighbors of sludge sites are getting sick;

BECAUSE the EPA acknowledges land applied sewage sludge emits toxic/irritant gases including dimethyl sulfide, dimethyl disulfide, methyl mercaptan, trimethylamine and ammonia, which CDC, NIOSH, OSHA, DOT, ATSDR and other government agencies warn can cause great harm to human health if inhaled or ingested ("ingestion" includes 'inhalation of bioaerosols, which are deposited in the throat and upper airway and swallowed');

BECAUSE a report published in November 2000 Journal of Agromedicine - Dr. Susan Schiffman, Duke University Medical School, and Dr. John Walker, US EPA, lead authors-details the harm to human health from sludge odors, odorants, bioaerosols and airborne particulates including " . . . 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" and " . . . exposure to increased levels of particulates is associated with increased mortality risk, especially among the elderly and individuals with preexisting cardiopulmonary diseases, such as chronic obstructive pulmonary disease (COPD), pneumonia, and chronic heart disease."

BECAUSE the aforesaid sludge/biosolids dusts, bioaerosols, gases and airborne pathogens can combine to form a noxious miasma which can engulf and adversely affect the health of neighbors of sludge sites - particularly babies and young children, the elderly and people with compromised immune systems.

BECAUSE courts in California, Oregon and Kentucky have ruled that the odors and emissions from sludge processing facilities are a "public nuisance", and the judges in Kentucky and California cases awarded monetary damages to the sludge victims;

BECAUSE the land spreading of treated sewage sludge/"biosolids" has caused sickness (and even death) in people around the country - (known as "sludge syndrome") including nausea, vomiting, diarrhea, eye, nose and throat burning and irritation, skin rashes and lesions, cysts, bloody noses, eye infections, pneumonia, asthma and other respiratory illnesses, tumors, immune system damage, viral and bacterial infections and a host of other physical maladies; (See - http://www.sludgevictims.com
and http://www.cfe.cornell.edu/wmi/Sludge/INCIDENTS.htm )

BECAUSE in their July 2002 report, the National Research Council acknowledged that despite the fact that treated sewage sludge/"biosolids"is a complex mix of pathogens and toxic chemicals which may affect human
health: "Because of the data gaps and lack of risk assessment methods for complex mixtures, it is NOT POSSIBLE to integrate pathogen risk assessment with chemical risk assessment."
(Page 6) http://books.nap.edu/books/0309084865/html/6.html#page_middle

BECAUSE the land spreading of sewage sludge has caused sickness and death of fish, livestock and family pets;

BECAUSE sludge nutrients, toxins and pathogens are known to have contaminated drinking water wells, ground water and surface waters around the country;

BECAUSE treated sewage sludge/"biosolids" contains brominated flame retardants (PBDEs), nonylphenols, surfactants, phthalates and other persistent, bioaccumulative, toxic and endocrine/hormone disrupting chemicals which cause great harm to wildlife and aquatic life;

BECAUSE Central and Northern European countries including Germany and Denmark are moving away from land application because of the uncertainties about endocrine disrupting compounds in sewage biosolids; and Switzerland has already banned land application based on the precautionary principle;

BECAUSE the EPA has never conducted a risk assessment into the risks of the harm to wildlife, soil biota and other ecological biosystems from "top dressed" (unincorporated) sewage sludge/"biosolids";

BECAUSE a recently released study by AMSA (Association of Metropolitan Sewerage Agencies) shows that DIOXIN levels in 2/3rds of sewage biosolids exceed the concentrations at which two EPA Risk Assessments show can cause great harm to certain species of wildlife; BECAUSE the EPA has established the least protective sludge regulations of any developed country in the world -- (Canada and European countries use the "precautionary principle" - or "no net degradation to soil quality"-to set limits on toxic metals from sludge in agricultural soils many times lower than US EPA );

BECAUSE the EPA Inspector General in April 2000 stated: "EPA does 
not have an effective program for ensuring compliance with the land application requirements of Part 503"; and "Accordingly, while EPA promotes land application, EPA cannot assure the public that current land application practices are protective of human health and the environment." In February 2002, the EPA Inspector General stated: "The agency (EPA) can neither investigate nor keep track of all
of the complaints of adverse health effects that are reported."

And in September 2002, the EPA OIG said "EPA does not know whether current regulations, when adhered to, are protective of public health" and "When it issued the rule, 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."

BECAUSE IN June 2001, Scientists at a Cincinnati, Ohio, workshop sponsored by US EPA and USDA concluded present pathogen testing methods are inadequate and a great deal more research must be done with regard to pathogens before treated sewage sludge/ "biosolids" can be pronounced "safe";

BECAUSE state "environmental/regulatory" agencies across the nation are PROMOTING land application of treated sewage sludge/"biosolids", and doing nothing to respond to sickness, water contamination and other concerns of Rural Americans who are suffering health and environmental consequences, lower property values and destruction of their quality of life by the disposal of this noxious waste in their communities;

BECAUSE despite the fact that Congress always intended that sludge disposal be a local option, sludge bullies have filed lawsuits in Pennsylvania, Virginia, California and Florida to force this toxic/pathogen waste from urban and industrial sources on unwilling rural communities which seek to protect themselves by enacting local sludge control ordinances; Courts in New Hampshire and California have ruled that the use or disposal of sludge is a "local determination" in accordance with federal Clean Water Act Title 33, Chapter 26, Subchapter IV, Sec. 1345.

BECAUSE THE US EPA has made a concerted effort to cover up and avoid any and all documentation and/or investigation into the sickness (and death) of sludge victims - humans and animals;

BECAUSE the US EPA has given over $19 million of our tax dollars to the WEF (Water Environment Federation - the lobbying and public relations arm of the waste industry) to promote sludge spreading and hire industry friendly, pro-sludge "scientists" " to rubber stamp waste industry/EPA sludge policies, and to fund their campaigns to debunk and discredit sludge victims and people seeking more protective sludge rules;

BECAUSE in August 1999, the EPA weakened federal sludge rules (40 CFR Part 503) - by changing the wording of the certifications by the sludge producers/sludge spreaders required under 40 CFR Part 503.17, so that they NO LONGER have to certify that the "requirements" of federal law with regard to pathogen reduction, vector attraction reduction, management practices and site restrictions "have been met";

BECAUSE despite the fact that EPA and the waste industry promote treated sewage sludge/"biosolids" as "fertilizer", in fact in March 2003 the National Farmers Union called for an end to the land spreading of Class B sewage sludge/"biosolids";

BECAUSE the EPA has harassed and retaliated against any scientist within its agency who dares to speak out in opposition to its sludge/biosolids (or other waste mismanagement) policies; and in May 2003 forced the resignation of renowned EPA microbiologist David L. Lewis because of publication in prestigious scientific and medical journals in June and July 2002, of his peer reviewed studies on adverse health effects reports by sludge victims; and

BECAUSE the highly respected Waste Management Institute of Cornell University, Ithaca, New York, has studied the land application of sewage sludge for many years and has published a report in the International Journal of Environment and Pollution, which concludes the EPA 40 CFR Part 503 sludge rules do not protect human health, agricultural soil and the environment.

Prepared by Helane Shields, Sludge researcher since 1996
PO Box 1133, Alton, NH 03809 Phone 603-875-3842 Email: 
hshields@worldpath.net

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