COMPOSTING  DOESN'T WORK, THAT COULD BE A CRIME.

If you know people exposed to pollutants in compost are subject to death, disease, etc,
The question posed to the US Composting Council, Why does pathogens [a pollutant] regrowth occur in
composted materials?

Schellinger, David A. (,"US Composting Council Compost Discussion List" October 31,
2006) answers, "Of coarse not all pathogens are destroyed during the PFRP process. So, if conditions
are adequate, pathogen populations can increase after composting is complete."

On the other hand in an newspaper article,
Project has an X factor, San Bernardino County Sun, 11/04/2006,  Chuck
Mueller, Writes, "But
Alan Rubin, chief author of the EPA's regulation-setting standards on using and composting
biosolids, said no illnesses result from composting the materials." "Composting kills off harmful microbes in biosolids," he

You have to wonder what Rubin actually did at EPA, since the statement indicates he never did any research or even
read EPA's Biosolids Composting fact sheet. And of course there are no precautions  to mitigate exposure to Aspergillus
in compost. The basic premise of society is that ignorance is not an excuse for causing harm, and based on EPA
documentation, Rubin can not even lay a claim to ignorance.
EPA and its partners in crime have assured the public that composting sewage sludge destroys pathogenic disease
causing organisms. It seems a shame that EPA's partners have let their high priced educations go to waste by failing to
evaluate the available information. There is documentation to show composting sludge has never been a safe option
due to deadly fungi and viable, but non-culturable bacteria and viruses.

Mycotoxins (damage lungs and liver)

In a 1979 study, Marsh and Millner (USDA) said, "Spores of Aspergillus fumigatus have been found to be abundantly
present in the outdoor air at a site where large scale experimental composting of sewage sludge is in progress at
Beltsville, Maryland. The health significance of this finding, for that site and for others in the future, is still only
incompletely understood. Further studies are in progress to characterize absolute concentrations of the spores of
the fungus in air at the site, spore dispersal by air from composting operations, and background environmental spore
levels in air."(20)

In the 1988 Yanko study of compost, he said, "The occurrence of pathogenic bacteria in distributed and marketed
,municipal sewage sludge products represents a potential health hazard. However, the extent of risk associated with use
of such products remains to be determined."
"The potential bacterial pathogens regularly detected were Salmonella and Yersinia."  "Results indicated t h a t current
composting practices may not insure complete elimination of pathogenic bacteria."  "--significant increases in bacterial
populations, including salmonellae, occurred during subsequent production of commercial s o i l amendment products."
"Although the use of sludge as a soil amendment is attractive, it is not without potential health risks. Toxic
chemicals,including heavy metals and industrial organics, may enter the food chain and present long-term health risks."
"Of the various reuse options,home use of treated sludge via some form of marketing or distribution program would
appear to present the greatest potential for significant health effects due to increased exposure. The routes of exposure
may take various forms, including handwork in gardens and eating uncooked vegetables grown in sludge amended
soils. Perhaps at the highest risk of ingesting pathogenic organisms are very young children playing in yards and
gardens that have been treated with sludge products." "Little is known about the occurrence orfate of enteropathogenic
E. coli in sludge and sludge treatment processes." "Other experiments demonstrated regrowth of indigenous
salmonellae within the naturally occurring mixed microbial population of compost." "Salmonellosis outbreaks that may
have been initiatedby infective doses as low as 10-100cells have been described in the literature."  "A number of
pathogenic or allergic fungi can be isolated from sludge. These include yeasts, such as certain specious of Candida,
Cryptocuccus andTrichosporon, and pathogenic members of some filamentous genera, such as Aspergillus,
Phialophora, Geotrichum, Trichophyton and Epidermophyton."  "The general consensus, however,is that fungi in treated
sludges present a minimal hazard. With the exception of the aspergilli, little work has been done to define the
relationships of fungi in polluted environments or sludges. The significance, if any, of fungal types and diversity in
compost is unknown." "Parasitic infections present a potential health risk associated with home use of sludge due to the
existence of highly resistant stages of the organisms and low infective doses." "The lack of information on health
problems associated with D & M sludges may reflect the absence of a problem, the lack of intensive surveillance, or the
inability to detect recurrent small-scale incidents of disease." "Further studies are recommended to quantitate toxigenic
E. coli populations.Gene probe techniques may be applicable to this task."

According to Dr. Vincent Marinkovich:
Aspergillus is a well-known human pathogen. It is the scourge of the modern hospital in that its control is difficult. It kills
patients with diminished immunity and can cause serious illnesses in exposed individuals who are otherwise normal.
Some species produce aflatoxin, the most potent cancer-producing chemical known, bar none. Its optimal growth
temperature is 37 degrees centigrade, which is human body temperature. It easily colonizes damaged human tissues
such as sinuses and lungs. Once established, it is very difficult to eradicate.

Harry Dobin, who worked 1000 feet away from a compost site in Islip, NY for 5 years, died from aspergillosis. In excerpts
from his poignant letter, Kenneth Dobin, tells of his son's terrible suffering and death. From July 1991 until January
1992, the doctors treated him for asthma, arthritis, Weggener's disease, Lyme disease, kidney disorder, and bronchitis.
Finally in January 1992, when he could no longer breath, they performed an open lung biopsy and discovered this
fungus called aspergillosis had invaded his lungs. But, after being exposed for such a long period of time to this
compost site, which is a natural breeding ground for this fungus, which took over my son's entire body. No antibiotic
could stop this fungus. Every time the doctors thought he was cured, it showed up somewhere else in his body. First his
lungs, then he had an aneurism, then in his spine, then in his legs (which they wanted to amputate). After 15 months,
this fungus destroyed him completely. It finally went to his heart valve and at that time the  doctors decided not to
remove his legs or replace the heart valve, but we should make him as comfortable as possibly and let Harry pass on
and end his suffering. September 23, 1992, five days after the fungus invaded his heart valve and legs, Harry died.

In 1996, "the NRC Report (31), "Use of Reclaimed Water and Sludge in Food Crop Production", "assured the public that
Coxsackie Viruses and Echoviruses in sludge only cause "flu-like" symptoms. However, according to Tabor's Cylopedic
Medical Dictionary, the sixty species (`EPA ,(5)') of the two viruses can also cause inflammation of the heart, spinal
cord and brain".

"The NRC report did add that, "Many of the variables associated with the transmission of infectious disease from
wastewater and sludge are either not well understood or are unpredictable." (p. 93-94)"

Although both EPA and WEF have been claiming sludge/biosolids are safe from pathogens, the NRC report (31)  
pointed out the concerns NRC had in regard to pathogens in sludge/biosolids, "There is a great diversity of pathogenic
agents involved in the fecal-oral exposure route, and an equal diversity of the dose-response relationships. Monitoring
for all these agents is impractical; therefore, the use of indicator organisms has been the traditional approach to
estimating sanitary quality. Coliform bacteria have been the most used in this regard...(however, they)...may not
adequately predict the present of viruses, protozoa or helmiths. Many enteric viruses, for example, have a greater
resistance to chemical disinfection and irradiation than do most bacterial indicators.....There are instances in sludge
processing, such as composting, in which the coliform levels can not be satisfactorily reduced even though there is
reason to believe that the sanitary level of the material is acceptable (EPA, 1992b;...

Some pathogens have even developed resistance to time-tested controls such as heat and
refrigeration. Several of the alternatives to reduce pathogens in sludge products use
heat at temperatures of 55 C and above to achieve Class A status. However, according to the
article "Pathogen Destruction and Biosolids Composting" in Biocycle of June of 1996, "There is
some evidence that coliforms and Salmonella sp. can survive prolonged exposure to
temperatures of 55 C." They cite a study done by Droffner and Brinton (1995) using DNA gene probes, where they
detected E. coli and Salmonella sp. in samples collected from an in-vessel composting facility after the first 15 days of
active composting at a temperature above 55 C. In Table 5-4 Processes to Further Reduce Pathogens in A Plain
English Guide to the EPA Part 503 Biosolids Rule, composting time and temperature requirements for within-vessel
composting method was 55 C or higher for three days! Droffner and Brinton found that it took 56 days and
90 days for the densities of Salmonella sp. and E. Coli, respectively, to decline below the
detection limit...These investigators also "cite evidence of mutant strains of E. coli and Salmonella sp. resistant to
thermal environments in composting." (p. 68)

Viable but non-culturable states: A phenomena commonly known as viable but non-culturable state has been described
for many bacteria including Campylobacter, E. coli, Salmonella enteritidis, Vibrio cholerae,Vibrio spp., and Legionella
pneumophila (Rollins and Colwell, 1986; Chowdhury et al.,1994; Roszak, Grimes,  Colwell, 1984; Oliver et al., 1995) .
The bacteria are still viable (exhibit low levels of metabolic activity) but fail to develop colonies on most traditional solid
culture medium. Moreover, pathogens in this viable but non-culturable state have demonstrated the ability to return to
an active potentially disease causing state (Colwell etal., 1985)

WEF waste disposal scientists now admit, "The issue of viable but non-culturable (VBNC) bacteria was advanced in the  
1980s, and gained significant interest in medicine, the food industry, and many other fields."

For the past twenty-five years public health, our lives, as well as the quality of our air, water and food has been firmly in
the hands of waste disposal people within EPA and WEF. After 25 years of putting the public health, air, water and food
chain at risk by promoting sewage sludge as a safe fertilizer  and garden soil amendment free of disease causing
organisms -- Twelve years of running a government funded public relations program to discredit people who have been
exposed to the disease causing organisms and suffered sickness, and even death --
Ten years of funding scientific studies to assure the public disease causing organisms in sludge are eliminated or killed
-- Yet,  these waste disposal scientists now want us to give them time to study the problem and how to fix it. But, WEF
only plans to do more research on one non-disease causing organism as an indicator for the 1,407 human pathogen
species that may be in sludge and there is no fix to kill a spore forming bacteria or fungi.

EPA's 2006, Biosolids Technology Fact Sheet, Use of Composting for Biosolids Management, based on Yanko's 1988
study states, Under some conditions, explosive regrowth of pathogenic microorganisms is possible. Composting is not a
sterilization process and a properly composted product maintains an active population of beneficial microorganisms that
compete against the pathogenic members

Limitations: Odor production at the composting site. Survival and presence of primary pathogens in the product.
Dispersion of secondary pathogens such as Aspergillus fumigatus, particulate matter, other airborne allergens. Lack of
consistency in product quality with reference to metals, stability, and maturity. In addition to odors, other bioaerosols,
such as pathogens, endotoxins, and various volatile organic compounds, must also be controlled. Biofilters are often
used to control odors, but the biofilters themselves can give off bioaerosols. Http://

Rubin's regulation-setting standards (40 CFR 503.9(t)) specifically state that exposure to these pollutants, which EPA
assures us is in the final biosolids compost, may cause death, disease, etc., through the air, food or water.

The question remains -- Is death from exposure to these pollutants in sludge/biosolids