Chapter Thirteen   


           CONCLUSION



The National Academy of Sciences and the National

Research Council has been used by the EPA and WEF to

give credibility to the EPA's contention that sludge is

safe for use on crops. The public health perception

study requested of them was part of the EPA/WEF's

public relations campaign to get the public to accept

the beneficial use of sludge (biosolids).

As the purpose of this group was to assist the

government, in this case the EPA, they had little choice

in becoming a part of the public relations program of

the EPA/WEF as outlined by the Powell Tate,

Communication Plan on Biosolids.

This group, the NCR, did not conduct an independent

risk assessment of possible health effects from the use

of sludge on cropland. Instead, they conducted a

literature review of selected studies and EPA risk

assessment models to conclude that consumption of

sludge-grown crops did not pose a significant risk for

the general public. NRC apparently based it's opinion on

studies that indicated treated wastewater has been used

safely for crop irrigation, on a limited scale, and the

federal regulations are designed to assure that there is

no significant risk to the general public.

NRC also qualified its statements by noting that

there must be adequate program management and oversite

and proper treatment that reliably reduce the pathogens

to acceptable levels in sludge to avoid contamination of

surface or groundwater.

Based on the selected studies NRC reviewed, it

found no scientific documented cases of human ill health

effects from the use of sludge on crops in the United

States.  However, it noted that reports from other

countries indicated that the use of untreated wastewater

effluent could result in infectious disease outbreaks.

Plus, it pointed out that viruses had been found in

groundwater almost 100 feet below a wastewater effluent

application site.

The NRC Report also discussed the limits of the

study which included: (1) low illness rate, (2)

insufficient sensitivity of current techniques to detect

low-level disease transmission, and (3) no way to

actually assess exposure levels. These limits were

imposed on the study because diseases from exposure to

wastewater were under-reported, scattered, and some

effects may be unrecorded.

The NRC Report expressed concern about the EPA's

exemption of organic pollutants because they were either

banned in the United States or appeared in less than 5

percent of the sludges or they were not found in

quantities that exceeded the risk-based loading

frequency. The Committee found that some pollutants

could exceed the risk-based limits in a small percentage

of sludges.

The NRC Report indicated there were little if any

economic incentives for food processors to accept

sludge-grown crops or for farmers to use sludge unless

they were paid for taking it.

And finally, the NRC Report suggested that

consumers, farmers, and the general public could deter

inappropriate behavior under the common law liability of

the Constitution.

However, one member of the NRC Committee has

already issued a public statement disagreeing with the

report.

As NRC Committee member Baram pointed out in a

media article, everyone involved in the report had a

vested interest.  Furthermore, he explained that there

were many topics of concern they didn't include in the

risk-analysis.  Baram's public statement included the

fact that he would not purchase sludge-grown foods or

want it in his community, because it poses risks to

persons exposed to it.

In reality, the NRC Committee acknowledged that

sludge use was not safe under the current conditions.

It left the most damaging statement on the use of sludge

and the EPA/WEF's public relations campaign until the

last paragraph of the Report.

I leave you with the Committee's final words in the

study and what appears to be an added editorial opinion.

"The suite of existing federal regulations,

available avenues for additional state and local

regulatory actions, and private sector forces appear

adequate to allow, with time and education, the

development of safe beneficial reuse of reclaimed

wastewater and sludge."

And the editorial opinion. "In fact, there are many

such programs already in operation."

Prev                         ****
Review of National Academy of Science's (NAS) 1996 literary review report by
its National Research Council (NRC) Committee :

"Use of Reclaimed Water and  Sludge in Food Crop Production"

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