Subj: Letter to editor -- Open letter to Director Couch
Date: 8/1/2005 9:02:57 AM Central Daylight Time
Columbia County's Application for disposal of biological hazards
Georgia Environmental Protection Division
As the highly educated Director of the Georgia Environmental Protection Division,
we would like to believe you are aware of the definition of a hazardous substance in the RCRA, a
toxic pollutant in the CWA and a polluant in 40 CFR 503.9(t) which shows that exposure to
Sludge/Biosolids meets the definition of exposure to a biological weapon. This could cause
"death, disease, cancer" as well as physical and mental disorders.
"Biological weapons may expose people to bacteria, viruses, or toxins as fine airborne particles.
Biological agents are infectious through one or more of the following mechanisms of exposure,
depending upon the particular type of agent: inhalation, with infection through respiratory
mucosa or lung tissues; ingestion; contact with the mucous membranes of the eyes, or nasal
tissues; or penetration of the skin through open cuts (even very small cuts and abrasions of
which employees might be unaware). Organic airborne particles share the same physical
characteristics in air or on surfaces as inorganic particles from hazardous dusts. This has been
demonstrated in military research on biological weapons and in civilian research to control the
spread of infection in hospitals." http://www.cdc.gov/niosh/unp-intrecppe.htm
Diseases from infectious agents
Family members have contracted infectious diseases such as scabies and Q fever from agents
brought home on contaminated clothing and skin of workers engaged in agriculture, hospital, and
laboratory work. As intended by Congress, infectious agents are included as hazardous
substances to the extent that pathogens can be transported on a worker's person or clothing.
We would like to believe that you have ensured a requirement in the permit that farmers receiving
sludge/biosolids are also given hazardous materials awareness training of the same quality as
the waste treatment plant employees and truckers are required to have for handling an
49 CFR 171.8 GENERAL INFORMATION, REGULATIONS, AND DEFINITIONS-Agricultural
product means a hazardous material, other than a hazardous waste, whose end use directly
supports the production of an agricultural commodity including, but not limited to a fertilizer,
pesticide, soil amendment or fuel. An agricultural product is limited to a material in Class 3, 8 or
9, Division 2.1, 2.2, 5.1, or 6.1, or an ORM-D
We would also like to believe you are aware that in 1992, the U.S. Congress passed the Workers'
Family Protection Act (Public Law 102-522, 29 U.S.C. 671) which has provided the following
"Agriculture ranks among the most hazardous industries. Farmers are at high risk for fatal and
nonfatal injuries, work-related lung diseases, noise-induced hearing loss, skin diseases, and
certain cancers associated with chemical use and prolonged sun exposure. Farming is one of the
few industries in which the families (who often share the work and live on the premises) are also
at risk for injuries, illness, and death."
"The NIOSH Farm Family Health and Hazard Surveillance (FFHHS) project focuses on identifying
health risks to the American farm family. It was developed to respond to Congress's concern that
agricultural workers and their families experience a disproportionate share of disease and injury
associated with the chemical, biological, physical, ergonomic, and psychological hazards of
"Prior to 1960, beryllium, toxaphene, mercury vapors, and diethylstilbestrol were also identified as
hazards to the families of workers. In the last 10 years, 10 additional chemical substances have
been identified in incidents of workers' home contamination, as well as allergens, radioactive
materials, and infectious agents."
To believe the foregoing points, we would have to believe that you are actually knowingly
proposing to deliberately issue a permit with the potential to kill a farmer and his family, as well as
his workers and neighbors in violation of the intent of the federal laws.
It is more likely that you have accepted EPA's word that sludge is safe based on the exclusions in
federal law used to create the sludge rules. It is also highly unlikely that the farmer and workers
involved are/or have been made aware they and their families are being put at such a high risk.
We the people would like to know what authority you propose to use to issue such a permit which
has the potential to do so much human health and environmental damage?
PO Box 682
Smithville, Mo. 64089