EPA Watch --- Hazardous Sewage Sludge Disposal as Fertilizer

In 1993, under court order, EPA's  Office of Water released a deadly sewage sludge
disposal program it likes to refer to as a regulation. The main purpose of the program
was to be able to
issue removal credits to polluters for land application of ten toxic and
very hazardous inorganic chemicals. EPA had no concern for what  the military would
call collateral damage of sludge disposal (i.e., death, disease, cancer).   

Hazardous sewage sludge disposal effects everyone exposed to the toxic pollutants in
sludge (AKA as Biosolids) used as a fertilizer through air, water or food.  Milwaukee
started the first program to sell toxic contaminated Class A sludge to the public as a
fertilizer in 1926. Many cities followed Milwaukee's example. The secondary aspect of
the program was to protect these cities.

EPA has never had, not even one, scientific study to state without qualification that the
use of sewage sludge/biosolids is safe to use as a fertilizer. In fact, EPA claims it does
not have data on most of the deadly  inorganic and organic chemicals, or infectious
disease organisms which can be found in sludge. EPA does say that exposure to these
pollutant may kill you. Yet, it asked the National Academy of Science to agree with its
program as a means to change public perception about the danger of being exposed to
this hazardous infectious waste sold as an unlabeled fertilizer.

For 25 years, EPA has ignored the Congressional mandate in RCRA  section 4004 to
find; (g)(6) methods to reclaim areas which have been used for disposal of sludge or
which have been damaged by sludge."(Public Law 89-272 title III #4004 -Pl 94-580)

There is no debate. Congress and EPA says its not even safe to put sludge in a
landfill!  However, EPA says that if sludge can't be sold as an unlabeled Class A
fertilizer to home owners, or put on food crop production land, then it must be put in a
highly regulated landfill. The trick is that EPA's "Exception Quality" sludge fertilizer is too
contaminated to be disposed of in a part 503 landfill referred to as a surface disposal
site and most removal credits are eliminated.

Not only that, but EPA has stated, it never considered doing a risk assessment for the
cancer causing metals in sludge it approved for removal credits, or any inorganic
chemical not included in part 503, or for any of the organic chemicals which were not
banned, no longer manufactured, or had restricted use.
Cancer causing agents.

EPA has never published a risk assessment for all of the disease causing organisms in
sludge because it doesn't want the public to know its Class A treatment process does
not destroy many pathogens. It only makes the pathogens undetectable by standard
test methods for a little while.

                                                        What exactly is sludge?
Congress identifies it this way in the RCRA: The term ``sludge'' means any solid,
semisolid or liquid waste generated from a municipal, commercial, or industrial
wastewater treatment plant, water supply treatment plant, or air pollution control facility
or any other such waste having similar characteristics and effects.

John Stauber,
TOXIC SLUDGE IS GOOD FOR YOU  looked this one up:  The Harper
Collins Dictionary of Environmental Science defines 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 a
sewage treatment plant." [10] Over 60,000 toxic substances and chemical compounds
can be found in sewage sludge, and scientists are developing 700 to 1,000 new
chemicals per year.

 What are the characteristics and effects that concerned Congress in the

because of its quantity, concentration, or physical, chemical, or infectious
characteristics may--
(A) cause, or significantly contribute to an increase in mortality or an increase in
serious irreversible, or incapacitating reversible, illness; or
(B) pose a substantial present or potential hazard to human health or the environment
when improperly treated, stored, transported, or disposed of, or otherwise managed.

  What causes those  effects that concerned Congress in the RCRA  &

``toxic  pollutants, or combinations of pollutants, including disease-causing agents,
which after discharge and upon exposure, ingestion, inhalation or assimilation into any
organism, either directly from the environment or indirectly by ingestion through food
chains, will, on the basis of information available to the Administrator, cause death,
behavioral abnormalities, cancer, genetic mutations, physiological malfunctions
(including malfunctions in reproduction) or physical deformations, in such
or their offspring.

Merriam Webster Dictionary defines organism as: 2 : an individual constituted
to carry on the activities of life by means of organs separate in function but mutually
dependent : a living being

A living being? I do believe that refers to the humans and animals that are being killed
by this policy!

Is there any science noted in the part 503 sludge use  and disposal policy?

                                  One small scientific disclaimer for safety!

503.9(t) Pollutant is an organic substance, an inorganic substance, a combination of
organic and inorganic substances, or a pathogenic organism that, after discharge and
upon exposure, ingestion, inhalation, or assimilation into an organism 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.

there is no scientific study that has ever directly addressed the toxic
pollutants. Particularly infectious agents. . Nor has any scientific study stated "Class A"
sludge disposed of as a fertilizer is safe.  Moreover, it is unlikely that any scientists who
claimed to have done a study on a few pollutants in sludge would admit he/she has
ever read this disclaimer of safety.


TOXIC SUBSTANCE:  A substance that can cause death, disease, behavioral
abnormalities, cancer, genetic mutations, or physiological or reproductive malfunctions
or physical deformities in any organism or its offspring, or a substance that can become
poisonous after concentration in the food chain or in combination with other substances.

                                    WHAT CAN WE EXPECT FOR PUBLIC HEALTH?

An epidemic of Methicillin-resistant Staphylococcus aureus (MRSA) infections out side
hospitals would appear to indicate that sludge has failed the public safety test. The
CDC has just reported in the New England Journal of Medicine that from 2001 through
2002, 1647 cases of community-acquired MRSA infection were reported.  That is from
just three places, Baltimore and Atlanta and from hospital-laboratory–based sentinel
surveillance of 12 hospitals in Minnesota.

In the study Interactions of pathogens and irritant chemicals in land-applied
sewage sludges (biosolids).
Dr. Lewis and his associates said: "A prevalence of Staphylococcus aureus
infections of the skin and respiratory tract was found. Approximately [25%] 1 in
4 of 54  individuals were infected, including 2 mortalities [deaths from]
(septicaemia, pneumonia).


Besides the health and death risks associated with hazardous sewage sludge disposal
as a fertilizer, there is a legal risk in many states if anyone complains that their food has
been contaminated by the toxic pollutants.  They could be sued under the food slander
laws, unless they have the scientific data to prove their point.

Don't expect help from the Health Departments. The Environmental Departments, who
approve sludge disposal as a fertilizer, have more statutory power than the Health

On the other hand, how do you explains some state health departments who actually
handle the permitting on hazardous sludge open dump sites based on EPA policy?

What can you do to stop hazardous sludge dumping on your food and your

Tell your friends and neighbors

Tell the media - newspaper - TV

Tell your Congressperson and you Senator

This is a political situation - EPA has deliberately promoted violations of  the laws it was
created to enforce.
Apparently, with criminal intent to violate the laws and put the public
in harms way.