Airborne aerosols: pathogens, Toxins, chemicals and metals (pollutants) in SLUDGE/BIOSOLIDS
                                                                                   by
                                                     Jim Bynum and  Gail Bynum Ph.D

5-9-2006                                                                                                                                              
References

Sewage sludge contains everything that goes down the drains from industry, hospitals, homes and in many cases what
washes off the streets and land. That includes all of the elements harmful to human health and the environment. These
are disease causing organisms, which create gases as the sludge decomposes, chemicals which volatize off the
disposal sites, and toxic metals carried on the gases and wind  when the sludge is mixed with dirt and dust.. The
aerosols off a sludge site  not only put the health of farmers,  home owners, and neighbors near the sludge sites at risk,
but also health of the  public at risk miles from the sludge/biosolids disposal sites.

Merriam Webster defines Aerosol as "a suspension of fine solid or liquid particles in gas <smoke, fog, and mist are
aerosols>." To that definition EPA has added biological materials such as bacteria, viruses, endotoxins, etc.: bioaerosols.

At this late date EPA is considering addressing some bioaerosols of interest.In a presentation,
National Update and
Trends in Biosolids Management
 in the U.S., December 7, 2005, Robert K. Bastian (84) (EPA) notes, "Addressing
areas of growing interest, (e.g., Odors, Dioxins, Radiation, Bioaerosols, Bioassay),"

In this paper we are looking not just at bioaerosols, but all airborrne pollutants (e.g., disease causing agents, some
chemicals,  some heavy metals, and dust) coming  from land application and composting of sewage sludge/biosolids..
One of CDC and NIH concerns has been worker safety in laboratory and health care settings, including exposure to
airborne pathogens.

In the CDC manual,  
Biosafety in Microbiological and Biomedical Laboratories (4th Edition 1999), They state
"As this edition goes to press, there is growing concern about the re-emergence of M. tuberculosis and worker safety in
laboratory and health care settings. The BMBL's underlying principles, which seek to ensure safe practices, procedures
and facilities, are applicable to the control of this airborne pathogen, including its multi-drug-resistant strains."
In looking at the manual, we find as early as 1967, scientists knew that aerosols were a hazard to lab workers. "Hanson
et al reported 428 overt laboratory-associated infections with arboviruses. In some instances, the ability of a given
arbovirus to produce human disease was first confirmed as the result of unintentional infection of laboratory personnel.
Exposure to infectious aerosols was considered the most common source of infection."

In the biosafety manual, it lists four Biosafety Levels for personnel involved in handling disease causing organisms.  In
BIOSAFETY LEVEL 2, BIOSAFETY LEVEL 3 and  BIOSAFETY LEVEL 4,  certain procedures are required when
working with infectious aerosols to protect the workers:

(2) BIOSAFETY LEVEL 2 is similar to Level 1 and is suitable for work involving agents of moderate potential hazard to
personnel and the environment: (1) laboratory personnel have specific training in handling pathogenic agents and are
directed by competent scientists; (2) access to the laboratory is limited when work is being conducted; (3) extreme
precautions are taken with contaminated sharp items; and (4) certain procedures in which infectious aerosols or
splashes may be created are conducted in biological safety cabinets or other physical containment equipment

(3) BIOSAFETY LEVEL 3 is applicable to clinical, diagnostic, teaching, research, or production facilities in which work is
done with indigenous or exotic agents which may cause serious or potentially lethal disease as a result of exposure by
the inhalation route. All procedures involving the manipulation of infectious materials are conducted within biological
safety cabinets or other physical containment devices, or by personnel wearing appropriate personal protective clothing
and equipment. The laboratory has special engineering and design features.

(4) BIOSAFETY LEVEL 4 is required for work with dangerous and exotic agents which pose a high individual risk of
aerosol-transmitted laboratory infections and life-threatening disease. (30)

Some scientists are looking at aerosols in the spread of infectious diseases. SARS and fear of an outbreak of  Avian Flu
have directed them to study airborne transmission.

One of these scientists, Donald Milton, lecturer on occupational and environmental health at the Harvard School of
Public Health and co-author of  the article,
"Airborne Transmission Underestimated As Cause When Investigating
Disease Outbreaks"
, a perspective in the April 22, 2004 issue of the New England Journal of Medicine."
According to a Harvard Press release (Boston- 2004 }, "Current thinking on how most communicable respiratory
infections are spread --- by large droplets over short distances or by coming in contact with contaminated surfaces (face
to face)--- needs to be reconsidered.

"The authors argue that in certain cases, illustrated by the SARS Amoy Gardens apartment complex outbreak, where
aerosolized, fine particle spread of SARS was implicated, aerosol transmission of respiratory infection has been
overlooked. This is due in part because the most widely recognized aerosol transmittable diseases, measles and
tuberculosis, are spread by airborne transmission and have been controlled, and because infectious aerosols are
extremely dilute with fine particles that are difficult to collect and culture, obscuring their role in disease spread."
"Calling for a critical reevaluation of the phenomenon, the authors offer a novel way to classify aerosol transmitted
airborne diseases, dividing them into three categories: obligate, an infection that is only initiated under natural
conditions via aerosols that are deposited in the lung; preferential, caused by agents that can naturally initiate infection
by multiple routes but are predominately transmitted by aerosols deposited deep in the lung, and opportunistic;
infections that require trafficking by pulmonary cells to produce full-blown disease and may include viral rashes such as
measles or smallpox. The authors note all three have one common element, the capability of creating infection from a
minute dose delivered to the lung in a single airborne particle. By their definition, the Amoy Gardens SARS outbreak
would most closely resemble an opportunistic aerosol transmitted airborne disease." (15)

Elinor Levy, PH.D an immununologist and associate Professor at Boston University and Boston Medical Center, in her
book ,
The New Killer Diseases, describes how much this airborne pathogen has cost in human lives,  "As of the time of
this writing, SARS had already exacted a terrible cost in human lives. By May 17, the WHO had reported 7,761 cases,
including 623 deaths, in 28 countries on 5 continents.8 Of those, 66 patients (though no fatalities) were in the United
States; 5,209 cases and 282 deaths were in mainland China, and another 1,710 cases and 243 deaths were in Hong
Kong. Although the WHO had noted that the epidemic might show signs of subsiding, it remained vigilant. Closer
examination of cases indicated the overall death rate was 15 percent— much higher than first expected—and was more
than 50 percent in people over age 65 who had been hospitalized."

She adds further, "The next time a newly evolved disease breaks out in the world, the cost could be even higher. During
the short weeks of the SARS outbreak, other pathogens were breaking out across the world, yet they were lost in the
news. An Ebola outbreak in Africa went into its fourth and fifth months. A new strain of avian flu was wiping out chickens
across Belgium and the Netherlands, had already caused 79 human cases of conjunctivitis, as well as several cases of
a flu-like illness that was responsible for pneumonia that killed a 57-year-old veterinary surgeon. More than 19 million
birds had been slaughtered. And world health experts feared that if this avian flu recombined with a human flu virus, a
pandemic could erupt that would dwarf the current SARS epidemic" (p.31) (
40)

The media's concern with the threat of Avian Flu has led to numerous newspaper articles, websites, news program and  
Tuesday, 9th of May, ABC  will air
"Fatal Contact: Bird Flu in America." "According to R.D Heldenfels, of  the Akron
Beacon Journal,it is  "a movie that speculates about avian flu spreading through human-to-human contact and resulting
in a pandemic". He cites, Executive Producer Judith Verno, who "has called it ``a plausible worst-case scenario.'' A
preview copy of the movie included a note calling it ``a fictional examination of the question, `What if?'... ''``What if''
includes millions dead, a breakdown in basic services, food shortages and the mutation of the flu into a vaccine-
resistant strain that launches a second wave of death. The movie is timely, with the Bush administration releasing its
plans for dealing with a flu pandemic last week. Preparations for the movie began in November 2005, and it was filmed in
February" (41)

According to NewScientist.com news service, May 6, 2006, information from Shaoni Bhattacharya, Singapore, warns that
there is more than one bird flu to worry about. "At an international meeting of top scientists and policymakers in
Singapore on Wednesday, several other avian flu viruses were highlighted. Hiroshi Kida, at Hokkaido University in
Sapporo, Japan, told New Scientist he was concerned that only the H5N1 virus was being considered in terms of
producing a human vaccine. "There are other possibilities," he says." "There are about three human flu pandemics
every century, and most scientists agree that the world is overdue for the next one. This would happen if an avian
influenza strain either mutated or swapped genes with other flu strains to become both highly pathogenic and easily
transmissible between humans". "It is "perfectly possible" that the next pandemic strain could derive from something
other than the H5N1 strain, agrees Malik Peiris, a microbiologist at the University of Hong Kong, China."(42)
Once in the environment, these deadly viruses will be passed through the air.  

Scientists like John Gloster,  have questioned the conditions necessary for viral transmission and survival.  In a 1972
study he found,  "Meteorological conditions are the major determinant of the downwind concentrations of airborne virus.
On highly convective days, virus is quickly dispersed vertically and as a result, downwind virus concentrations are low.
Conversely under stable conditions there is limited vertical dispersion and downwind concentrations are much higher.
The virus is stable in aerosols at a relative humidity above 55–60% and at temperatures below 33 C. Sunlight and the
pollution complex termed ''the outside air factor'' have minimal direct effects on virus survival"

In their 1973 study,
Airborne Stability of Simian Virus 40 , T. G. AKERS, et al., (186)   found viruses could also be viable
(infectious), but non-culturable (VBNC). They said, "Previous studies, which have revealed that infectious viral nucleic
acids were not damaged with respect to biological activity either by atomization, aerosol storage, or collection (3),
indicated that airborne inactivation of SV40 virus at 32 C must be associated primarily with damage to the protein
component of the virion (conformational changes) which, in turn, caused a change in moiety or collapse of the SV40
deoxyribonucleic acid (DNA) molecule. More than likely, however, the SV40 DNA retained its infectivity."  "The authors
noted that infectivity of ribonucleic acid (RNA) extracted from intact virions collected from poliovirus aerosols was stable
at RH values deleterious to whole virus survival. This, coupled with the finding of Akers et al. (2) that aerosols of
infectious EMC-viral RNA could infect mice, may point to another aspect of the biohazard potentials for airborne SV40
virus." Considering the wide use of SV40 virus for oncogenic studies and the unusual airborne stability reported herein,
it is obvious that laboratory procedures must be carefully assessed with respect to creating biohazardous aerosols.
Moreover, because of their airborne stability, the inhalation route for oncogenic viruses must not be excluded as a
means of accidental transmission."

Studies on Bacteria and fungi have also questioned their transmission and survival in the air.

BACTERIA

In their 1993 study, SURVEY OF AIRBORNE BACTERIA AT FOUR DIVERSE LOCATIONS IN OREGON: URBAN, RURAL,
FOREST, AND COASTAL, Brenda T. Shaffera and Bruce Lighthartb,  state, "If microbial air pollution is a future risk, how
can we protect our environment without knowing the current "natural" levels and types of bacteria"

In their study they found that the time of day was a factor in bacterial concentration and reduction. "Bacterial
concentration in general tended to peak at sunrise and sunset, decrease during the solar noon hours, with the lowest
numbers occurring between 2100-0400 hours. In the evening, a stable nocturnal boundary layer develops where there
is little mixing or turbulent air. At sunrise, the ground begins to heat from solar radiation, and a mixed layer due to
convective heating begins to form, increasing air turbulence (Kim, 1994). However, as solar radiation increases, the
bacteria are reduced in numbers due to the damaging effects of UV radiation (Cox, 1989).

"Bacillus was found to be the highest single genus represented at all locations (15-45%). Since the atmosphere is a very
harsh environment for bacteria, primarily due to desiccation, it is not surprising that a spore-former represents the
largest genus present."(18)

Several studies show some nonspore forming bacteria are temporarily inactivated when they are  under stress, in
water,  in air, or starving, as a protective response. which makes them viable, but non-culturable (VBNC) under standard
laboratory procedures. However, other studies show special laboratory procedures can increase culturable airborne
bacteria by as much a 95 percent..

James D. Oliver,(48) Department of Biology, University of North Carolina at Charlotte, 2005, notes, "Since the original
1982 paper from the laboratory of Rita Colwell (Xu et al., 1982), over 400 papers have appeared which describe various
aspects of the phenomenon most commonly referred to as the " but nonculturable (VBNC) state" Futhermore, he said,
"The number of species described to enter the VBNC state constantly increases, with approximately 60 now reported to
demonstrate this physiological response. Included are a large number of human pathogens, including Campylobacter
spp., E. coli (including EHEC strains), Francisella tularensis, Helicobacter pylori, Legionella pneumophila, Listeria
monocytogenes, Mycobacterium tuberculosis, Pseudomonas aeruginosa, several Salmonella and Shigella spp. and
Vibrio cholerae, V. Parahaemolyticus, and V. Vulnificus."

Using standard culture methods for bacteria in water, only 1/10 th of the bacteria are culturable.

In a World Health study, H. Leclerc, Relationships between common water bacteria and pathogens in drinking-
water
,  states, "Many other bacterial species have been isolated in drinking-water systems, generally in lower numbers.
There are members of the genera Bacillus and Clostridium, the common Gram-positive cocci, including the genera
Micrococcus, Staphylococcus and Streptococcus, and the environmental or ubiquitous coliforms (Leclerc et al. 2001),
among which the members of the genera Klebsiella, Enterobacter and Citrobacter are the most successful colonizers in
distribution networks. The well known problem, greatly emphasized by Szewzyk et al. (2000), is that the percentage of
culturable cells in these bacterial communities is always very low, only representing <0.1% of the number of total cells
determined by acridine orange direct count. Therefore, the inferred question arose: "Are the 99.9% of total cell numbers
that are not detectable by plate counts equivalent to the VBNC of known bacteria, or do they represent other, so-far-
unknown, bacteria that are present in high numbers in drinking water?" (11)

In air, only a few bacterial cells are culturable using standard procdures..

In a study referenced in Science Daily ,1997,  on the Effect of aerosolization on culturability and viability of gram-
negative bacteria
.,  the authors "concluded that the bacterial strains included in this study did not respond to standard
culture methods after aerosolization," .... "The plate [colony] count provides an estimate of only those few cells least
affected by exposure to air."

Spore forming bacteria as well as starved bacteria are nonculturable using standard procedures.

Sabina Heim et al., in The Viable but Nonculturable State and Starvation Are Different Stress Responses of
Enterococcus faecalis, as Determined by Proteome Analysis, 2002, states, "Interestingly, other high-molecular-weight
proteins, such as the putative proteins enolase and ATP-synthase ß-chain, or the homologue of the elongation factor
Tu (EF-Tu) of Staphylococcus aureus, are dramatically reduced in VBNC cells." The authors state, "While a number of
microorganisms can survive by forming resistant spores, nonsporulating microorganisms are able to persist in adverse
environments as vegetative cells with low metabolic activity, via the activation of the viable but nonculturable (VBNC)
state (1, 4). In contrast, nutrient deprivation or exhaustion stimulates a starvation response, which allows bacterial long-
term persistence in a nongrowing but culturable state (18).

Nonculturable vegetable cell bacteria require special procedures to identify infectious quantities in the air
harmful to humans and the environment.

In other studies researchers were able to culture high levels of airborne bacteria.   In their 1990 study Effects of betaine
on enumeration of airborne bacteria., B Marthi and B Lighthart, found that when, "the osmoprotectant betaine was
incorporated into collection fluid and enumeration medium to determine its effects on the colony-forming abilities of
airborne bacteria,--- addition of 2 to 5 mM betaine caused a significant increase (from 21.6 to 61.3%) in colonial
outgrowth, compared with the growth rate of controls without betaine. The presence of betaine in both the collection fluid
and the enumeration medium had an additive effect on the colony-forming ability of airborne bacteria compared with the
presence of betaine in either one alone. (207)

In their 1991 study,
Resuscitation effects of catalase on airborne bacteria, B Marthi, B T Shaffer, B Lighthart, and L
Ganio, found "Catalase incorporation into enumeration media caused a significant increase (greater than 63%) in the
colony-forming abilities of airborne bacteria. Incubation for 30 to 60 min of airborne bacteria in collection fluid containing
catalase caused a greater than 95% increase in colony-forming ability. However, catalase did not have any effects on
enumeration at high relative humidities (80 to 90%)."

In
A nationwide census of airborne bacteria, Scientists at the Lawrence Berkeley National Labs (LBNL), 2003, found
concentrations varied from city to city. Todd DeSantis states, "analyzed data collected during the summer of 2003 from
two cities in Texas. Separated by only 80 miles, Austin and San Antonio show some significant differences in their
bacterial biota. Both cities have airborne bacteria from the genera Pirellula, Pseudomonas, Rickettsia, Clostridium, and
Bacillus. But San Antonio has a much greater diversity of bacteria and also supports Denitrovibrio, Legionella, and
Actinomyces. It is not known why two cities so close geographically differ so dramatically in their bacteria. "There must
be some local reservoirs for the bacteria," speculates Andersen. "We're looking at weather patterns to see if that might
explain it." (19)

In
Cataloging Airborne Bacteria, City by City,  2004, Dan Krotz, also noted "E. coli and other organisms that usually
reside in animal intestines.... are more prevalent in urban areas than rural areas, perhaps because there's more
sewage and garbage". (21)

FUNGI

Transmission of airborne bacteria and viruses are less well understood than fungi which are documented to be carried
high into the air and over long distances.

In the AG Technologies (Disease Management),  report,
Transmission of Plant Diseases, it notes that fungal spores are
carried by wind currents at low to very high altitudes and great distances. - Fungal spores produced externally on host
surfaces are most easily carried by wind currents and this is the most dangerous mode of transmission of plant
pathogenic fungi. like those causing powdery and downy mildews, leaf spots, blasts, blights and rust diseases. The
black stem rust disease of wheat in India perpetuates on wild grasses in the Nilgiri hills in the south India from where the
rust spores are carried to south, central & then to north India by wind currents every year. Spores may be carried from
low to very high altitudes of 12,000 to 14,000 feet and from short distances to very long distances of several hundred
kilometers" (28).

An important fungal disease coccidioidomycosis is spreading in the southwest and west  through the air.
In an article "
Valley fever severity rises to level that is 'unbelievable'" Reporter Carla McClain (166)  2006, ARIZONA
DAILY STAR , said its "Known scientifically as coccidioidomycosis, valley fever is caused by a soil fungus that grows only
in parts of the southwestern United States, Mexico and South America. When inhaled, the fungal spores usually attack
the lungs, but they can spread through the bloodstream to the brain, skin and bones to cause severe, sometimes fatal
disease." "It can take only one spore to cause an infection, even a serious infection," said Dr. John Galgiani, director of
the UA's Valley Fever Center for Excellence." "With monthly case numbers also spiking statewide, Arizona expects to
easily surpass last year's total 3,778 cases." "The problem is starting to show up in the records. In Pima County, a total
of 259 valley fever cases have been reported in the most recent three-month period, from November through January.
That is an increase of more than 40 percent over the 183 cases reported during the same period last year."

According to a recent (April 2006) report, there were 2,000 cases in Arizona in the first three months of the year. As we
understand the general theory, what we are dealing with is very ancient pathogenic spores in the soil created by a fungi,
which bioaersols with dust under windy conditions. However, the dramatic increase in infection rates appear to parallel
the increased spreading of sludge on dry desert soils which, according to some scientists, also contains the spores that
cause coccidioidomycosis (Valley fever)..

Coccidioidomycosis (i.e., valley fever) is a BIOSAFETY LEVEL 3 disease causing organism.

According to the CDC, (176) "During 1991, reported cases of coccidioidomycosis (i.e., valley fever)  in California
increased more than threefold over the annual number of cases reported since 1986; during 1992, the number of
reported cases increased 10-fold. Coccidioidomycosis, a fungal disease caused by Coccidioides immitis, is endemic in
certain parts of Arizona, California, Nevada, New Mexico, Texas, and Utah."

In 1991, 1208 new cases of coccidioidomycosis were reported to the California Department of Health Services (CDHS),
compared with an average of 450 cases per year during the previous 5 years. Of these cases, 959 (80%) were reported
from Kern County, where coccidioidomycosis is known to be endemic and where the county health department serves as
a referral laboratory for coccidioidomycosis serologic tests. Of all cases reported to CDHS in 1991, 765 (63%) were
reported from October through December. In 1992, 4541 cases of coccidioidomycosis were reported to CDHS (Figure
1). Of these, 4198 (92%) were reported from the central valley and southern California, including 3027 (67%) from Kern
County. Reports from the Coccidioidomycosis Serology Laboratory of the University of California at Davis, a reference
laboratory that receives specimens from areas of California other than Kern County, also documented an increased
incidence in 1991 and 1992."

DUST PARTICLES

Fine particle dust, which can carry  mold, spores and pollen as well as heavy metals and chemical compounds is a major
concern for the Pima County, Arizona health department which not only has to contend.with coccidioidomycosis fungal
spores, but also has to contend with an epidemic of invasive necrotizing fasciitis. Necrotizing fasciitis is generally
associated with toxin producing Streptococcus and Staphylococcus, with Clostridium as the agent causing gas gangrene.

In a
Yellow Alert fact sheet, Pima County Department of Environmental Quality, (185)  2004, states, "Scientific studies
have linked breathing particulate matter to a series of significant health problems, including: aggravated asthma;
increases in respiratory symptoms like coughing and difficult or painful breathing; throat irritation, chronic bronchitis;
decreased lung function; and premature death."

The fact sheet states, "Particulates come from a variety of sources such as, ...
. tilled fields. In addition, wind-borne
particulates can travel into the valley from other areas or be generated locally."

The smaller particles are lighter and they stay in the air longer and travel farther. PM10 (big) particles can stay in the air
for minutes or hours while PM2.5 (small) particles can stay in the air for days or weeks. And travel? PM10 particles can
travel as little as a hundred yards or as much as 30 miles. PM2.5 particles go even farther; many hundreds of miles.
If the particle is small and it gets very far into the lungs, special cells in the lung trap the particles and then they can't get
out and this can result in lung disease, emphysema, lung cancer.

Both PM10 (big) and PM2.5 (small) particles can cause health problems; specifically respiratory health (.. the lungs and
airway). Because the PM2.5 travels deeper into the lungs AND because the PM2.5 is made up [of] things that are more
toxic (like heavy metals and cancer causing organic compounds), PM2.5 can have worse health effects than the bigger
PM10.

Exposure to particulate matter leads to increased use of medication and more visits to the doctor or emergency room.
Health effects include the following:
  • Coughing, wheezing, shortness of breath
  • Aggravated asthma
  • Lung damage (including decreased lung function and lifelong respiratory disease)
  • *Premature death in individuals with existing heart or lung diseases

Fine particulate pollution (PM2.5), is of specific concern because it contains a high proportion of various toxic metals
and acids, and aerodynamically it can penetrate deeper into the respiratory tract.

Several epidemiological studies have linked both PM10 and specially PM2.5 with significant health problems, including:
premature mortality, chronic respiratory disease, respiratory emergency room visits and hospital admissions,
aggravated asthma, acute respiratory symptoms, and decreased lung function. Like the other criteria pollutants, the
elderly, whose physiological reserves decline with age and who have higher prevalence of cardiorespiratory conditions,
and children, whose respiratory systems' are still developing and who spend more time outdoors, are most at risk from
exposure to particulate matter. Also, individuals with preexisting heart or lung disease and asthmatics are sensitive
to PM effects. Fine particulate pollution (PM2.5), is of specific concern because it contains a high proportion of various
toxic metals and acids, and aerodynamically it can penetrate deeper into the respiratory tract.

P
REMATURE MORTALITY

Historically, the association between PM10 and mortality has been manifested in many air pollution episodes such as
those which occurred in Belgium (1930), Pennsylvania (1948), London (1952), New York (1953), and London (1962),
where the number of deaths attributed to air pollution was 63, 20, 4000, 200 and 700, respectively. Several studies
have demonstrated the relationship between low concentrations of PM10 and PM2.5 and increase in daily mortality. A
study conducted by Pope, et al., 1996, demonstrated the association between PM10 air pollution and cardiopulmonary
and lung cancer mortality. The relationship was stronger for PM2.5 than PM10. PM2.5 was associated with a 36%
increase in death from lung cancer and 26% in cardiopulmonary deaths, the risk being higher for people over the age of
65.

Conclusion of Pima County

Extensive epidemiological evidence demonstrated that increases in ambient particulates concentrations are associated
with increases in total mortality from respiratory and cardiac diseases, increases in hospitalizations and emergency room
visits for respiratory and cardiac diseases, increases in daily respiratory symptoms and decreases in pulmonary
function. Sensitive groups including the elderly, children and individuals with cardiopulmonary diseases such as asthma
and COPD, are at greater risk of developing adverse health effects from particulate exposure. Several recently
published health studies indicate that increases in cardiorespiratory mortality and morbidity can be expected with
particle levels below the particulate matter standard.

Numerous epidemiological studies have mentioned that the relationship between PM2.5 and adverse health effects is
stronger than PM10. Fine particulate pollution is of specific concern because it contains a higher proportion of various
toxic metals and acid species, and aerodynamically it can penetrate deeper into the respiratory tract. However, the
number of studies that demonstrating PM10 adverse health effects is greater than PM2.5. (9)

The prevailing scientific estimate is one in three people in the United States is at a high risk to experience airborne
pollutant related health effects. According to EPA, "Roughly one out of every three people in the United States is at a
higher risk of experiencing PM2.5 related health effects. One group at high risk is active children because they often
spend a lot of time playing outdoors and their bodies are still developing. In addition, oftentimes the elderly population
are at risk. People of all ages who are active outdoors are at increased risk because, during physical activity, PM-2.5
penetrates deeper into the parts of the lungs that are more vulnerable to injury." (33)

Human health is not the only damage associated with airborne pollutants. The environment is at risk as EPA
acknowledges, "Particles can be carried over long distances by wind and then settle on ground or water. The effects of
this settling include: making lakes and streams acidic; changing the nutrient balance in coastal waters and large river
basins; depleting the nutrients in soil; damaging sensitive forests and farm crops; and affecting the diversity of
ecosystems."  (34)

Scientists at the Jet Propulsion Laboratory have found that dust particles can carry multiple spore forming bacteria on a
single speck of dust which  may survive all treatment processes. In a study of dust particles entering space craft at the
Jet Propulsion Laboratory, California Institute of Technology, Y. Lin, et al.,
Quantification of spore-forming bacteria
carried by dust particles
, state, "Our data also confirms the existence of multiple spores on a single particle and spore
clumps." (2)

In another study, Myron, T, et al.,
Bacillus odysseyi sp. nov., a round-spore-forming bacillus isolated from the Mars
Odyssey spacecraft
,  found, "Of all strains tested, the spores of this strain were the most consistently resistant and
survived all of the challenges posed, i.e. exposure to conditions of desiccation (100 % survival), H2O2 [hydrogen
peroxide] (26 % survival), UV radiation (10 % survival at 660 J m-2) and gamma radiation (0·4 % survival)."  (3)

SLUDGE/BIOSOLIDS

In the early days of sludge use little thought was given to emerging disease causing organisms, spore forming bacteria,
or airborne particles carrying disease organisms, chemicals or metals. EPA standards for Class A sludge/biosolids do
not require testing for disease causing spore forming bacteria which are virtually indestructible.. One of the approved
treatment processes is mixing sludge with lime to create biosolids. Yet, in his 2004 paper,  
Evaluation of bacteriological
indicators of disinfection for alkaline treated biosolids
, EPA's Mark Meckes,  cautioned, "Again, it can be stated that lime
treatment did not significantly reduce the number of spore forming bacteria." (4)

The  sludge standard only requires nondetection of vegetable cell type bacteria, generally E. coli or Salmonella, to
prove sludge/biosolids compost is safe. Yet, as early as 1988, William Yanko found in his study,
OCCURRENCE OF
PATHOGENS IN DISTRIBUTION AND MARKETING MUNICIPAL SLUDGES,
one form of the plague causing bacteria
Yersina survived in sludge compost. He said, "The potential bacterial pathogens detected were salmonella and Yersinia.
Salmonellae were detected at both facilities. Yersinia only occurred significantly at the static pile facility and were
isolated in a pattern consistent with a seasonal occurrence. At the windrow facility, salmonellae were primarily isolated
from amended compost products. Toxigenic E. coli were randomly isolated."

Yanko acknowledged a lack of scientific information on disease causing organisms, such as,  "Campylobacter and
Yersinia have been referred to as "pathogens of emerging significance." Although much work has focused on Yersinia.
there is very little information concerning these organisms in sludges. One study reported 2 X 105 Yersinia
enterocolitica per gram total suspended solids in one digested sample. A study in Seattle reported Yersinia
enterocolitica levels of 107 to 109 per gram in various sludge samples. The significance of these
numbers i s unknown. Many Y. enterocolitica-like .organisms, unusual Y. enterocolitica or atypical Y. enterocolitica have
been reported.
The pathogenicity of individual strains is unknown, and the role of these organisms in human
disease has not been completely discerned.
.

Yanko warned, "Many different bacterial pathogens may be present in sewage and sludge. In the major concern
category, E. Coli pathogenic strains), Salmonella sp., Campylobacter jejuni, Yersinia enterocolitica, Leptospira spp.,
Shigella spp., and Vibrio cholerae."

He adds, "A number of pathogenic or allergic fungi can be isolated from sludge. These include yeasts, such as certain
specious of Candida, Cryptocuccus and Trichosporon, and pathogenic members of some filamentous genera, such as
Aspergillus, Phialophora, Geotrichum, Trichophyton and Epidermophyton. Aspergillus fumigatus, an opportunistic
pathogen to individuals with pulmonary problems and a strong allergen to many, may proliferate in some composting
systems."  (44)

Since Yanko's first study on composts, scientific methods have improved. Not only that, but as sludge disposal has
moved from isolated areas to populated areas it has become more important to address odors, bioaerosols like disease
causing organisms, endotoxins and volatile organic compounds as well as dust.

In EPA's current Technology Fact Sheet,
Use of Composting for Biosolids Management, to create Class A
sludge/biosolids, it is  pointed out that: "In addition to odors, other bioaerosols, such as pathogens, endotoxins, and
various volatile organic compounds, must also be controlled" "Dust and airborne particles from a composting operation
may affect air quality. The impact to adjacent areas may need to be mitigated and permitted. EPA further points out that,
"spore counts at  composting facilities are high, and the risk of operators and persons handling composted biosolids
[consumers] being exposed to these spores is also high"

If only one bacteria survives treatment it can cause adverse health effects because, according to the Federal Drug
Aministration, "A single bacterium can grow to millions in 10 to 12 hours! Water, wind, insects, plants, and animals can
carry bacteria." (26

ODORS

The most recent study on odors addresses three potential mechanisms for odors to cause health symptoms;
compounds with odor properties, (irritation); innate (genetically coded) or learned aversions to odors, and a copollutant
(such as endotoxin) that is part of an odorant mixture."

Susan S. Schiffman,(15)  2005, Department of Psychiatry, Duke University Medical Center, in the study,
Science of Odor
as a Potential Health Issue
said,  "Malodors emitted from large animal production facilities and wastewater treatment
plants, for example, elicit complaints of 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. There are at least three mechanisms by which ambient odors may produce health symptoms. First, symptoms
can be induced by exposure to odorants (compounds with odor properties) at levels that also cause irritation or other
toxicological effects. That is, irritation—rather than the odor—is the cause of the health symptoms, and odor (the
sensation) simply serves as an exposure marker. Second, health symptoms from odorants at nonirritant concentrations
can be due to innate (genetically coded) or learned aversions. Third, symptoms may be due to a  copollutant (such as
endotoxin) that is part of an odorant mixture." (46)

HYDROGEN SULFIDE EXPOSURE FROM BACTERIA CREATING THE GAS DURING DECOMPOSING
SLUDGE/BIOSOLIDS

Hydrogen sulfide is created by anaerobic bacteria as they decompose sludge/biosolids.  Schiffman uses Hydrogen
Sulfide (H2S) as an example of an odorant and describes several cases where very low levels do cause health effects.
Hydrogen Sulfide's rotten egg odor can be detected at 0.5 ppb (parts per billion). The gas is created by bacteria
converting sulfates to sulfides. Hydrogen Sulfide is just as deadly as Hydrogen Cyanide. It is heavier that air and
concentrates in low places.  For this reason children will be subject to higher doses than adults.

The National Institute for Occupational Safety and Health (NIOSH) recommends a 10-minute ceiling limit of 10 ppm (parts
per million) in the workplace. Maximum airborne concentration below which it is believed that nearly all individuals could
be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms
which could impair an individual's ability to take protective action) = 30 ppm.

OSHA maximum peak exposure = 50 ppm (10 minutes, once, no other exposure), NIOSH IDLH (immediately dangerous
to life or health) = 100 ppm,

Olfactory nerve fatigue occurs [nerves in the nose are deaden] in 2 to 15 minutes at concentrations over 100 ppm,
Symptoms of acute exposure include nausea, headaches, delirium, disturbed equilibrium, tremors, convulsions, and skin
and eye irritation. Inhalation of high concentrations of hydrogen sulfide can produce extremely rapid unconsciousness
and death

Repeated or prolonged exposure has been reported to cause low blood pressure, headache, nausea, loss of appetite,
weight loss, ataxia, eye-membrane inflammation, and chronic cough. Neurologic symptoms, including psychological
disorders, have been associated with chronic exposure. Chronic exposure may be more serious for children because of
their potential longer latency period.

Exposure to lower concentrations can result in eye irritation (because of the high alkality of the SH- anion), a sore throat
and cough, shortness of breath, and fluid in the lungs. These symptoms usually go away in a few weeks. Long-term, low-
level exposure may result in fatigue, loss of appetite, headaches, irritability, poor memory, and dizziness.
Most studies do not address the potential hazards to human health posed by airborne aerosols from animal facilities or
sludge sites. According to the Union for Concerned Scientists, "Dr. James Zahn, a research microbiologist at the U.S.
Department of Agriculture (USDA), 2002, asserts that he was prohibited on no fewer than 11 occasions from publicizing
his research on the potential hazards to human health posed by airborne bacteria originating in farm wastes."
"Zahn's research had discovered significant levels of antibiotic-resistant bacteria in the air near hog confinement
operations in Iowa and Missouri. But, as Zahn recounts, he was repeatedly barred by his superiors from presenting his
research at scientific conferences in 2002. In at least one instance, a message from a supervisor advised Zahn that,
"politically sensitive and controversial issues require discretion." (22)

To get a full understanding of the aerosol of odorant gases, bacteria and endotoxins associated with animal production
facilities, wastewater treatment plants and sludge/biosolids we have to look at a  2005 study,
Airborne Multidrug-
Resistant Bacteria Isolated from a Concentrated Swine Feeding Operation
, where Amy Chapin, et al., found, "The types
of bacteria detected within the air of the swine facility investigated in this study are associated with a variety of human
infections. Enterococcus, particularly some of the species isolated in this study including E. faecalis and E. faecium, has
emerged as one of the leading causes of nosocomial [hospital aquired] bacteremias, urinary tract infections, and wound
infections in the United States.  Similarly, coagulase-negative staphylococci are the third most common causes of
nosocomial infections and the most common causes of nosocomial bacteremias. The presence of multidrug-resistant
Enterococcus and coagulase-negative staphylococci in patients significantly limits the treatment options available for
these life-threatening infections. Although viridans [generally non-pathogenic streptococci] group streptococci are part
of the normal flora of the human respiratory tract, they also have been implicated as the cause of infective endocarditis
and life-threatening septicemias in neutropenic [immune compromised] patients. In addition, viridans group streptococci
have been implicated as reservoirs of erythromycin-resistance genes, possibly capable of transferring resistance
determinants to more pathogenic species including Streptococcus pneumoniae and Streptococcus pyogenes."

Moreover, "The mean concentration of presumptive Enterococcus present in the air of the swine CAFO on both 9
December 2003 and 5 January 2004 was 4 × 104 CFU/m3. After bacterial speciation was completed on 137 presumptive
Enterococcus isolates, only 47 out of 137 isolates (34%) were confirmed to be Enterococcus.  Forty-four isolates (32%)
were identified as staphylococci, 45 isolates (33%) were viridans group streptococci, and 1 isolate was identified as
Micrococcus luteus."

Furthermore, "Endotoxins, exotoxins, and other chemical components in dusts associated with animal waste and human
sludge have been linked to hypersensitivity reactions among individuals living near land application areas. These
reactions have been shown to result in increased susceptibility to serious respiratory infections, including those caused
by S. Aureus.  Thus, the presence of high concentrations of multidrug-resistant staphylococci and other bacterial
pathogens amidst endotoxin-containing dust from animal and human waste could pose unique health concerns to
people living near land application areas."(13)

BIOAEORSOLS - ENDOTOXINS

In 1981, Edwards JH., (50) discussing "Organic dust diseases and endotoxins", writes, "On the basis of available
information it is not justifiable to conclude that endotoxins are responsible for extrinsic allergic alveolitis by biological
activities that are associated with endotoxin properties per se. Endotoxin-like material has been found in materials
associated with byssinosis, farmer's lung and sewage sludge disease and a case for their involvement in the aetiology of
byssinosis and sewage sludge disease can be made out. However, endotoxin-like activity in farmer's lung is less
important than the hypersensitivity reaction except possibly where heavy doses of mouldy [fungi contaminated] hay dust
are inhaled."

By 1986 Australia (52) had enough information to make the connection that bacterial endotoxin in sewage sludge was
an antigen which caused extrinsic allergic alveolitis. Since then Canada (53) has agreed that bacterial endotoxins from
heat dried sludge causes  extrinsic allergic alveolitis and it is called sewage sludge disease. CCOSH said, "Intense or
prolonged exposure to animal or vegetable dusts can result in extrinsic allergic alveolitis. The dust particles must be 5
microns or smaller to get into the alveoli. Animal and vegetable dusts are complex mixtures originating from many
different sources such as husks, bark, wood, animal dander, [sludge], and microorganisms including bacteria and fungi.
The microorganisms produce toxic chemicals that form part of the mixture."

VARIOUS VOLATILE ORGANIC COMPOUNDS

Organic Gases (Volatile Organic Compounds - VOCs) are emitted as gases from certain solids or liquids. VOCs include
a variety of chemicals, some of which may have short- and long-term adverse health effects. According to EPA, heath
effects of volatile organic compounds are: "Eye, nose, and throat irritation; headaches, loss of coordination, nausea;
damage to liver, kidney, and central nervous system. Some organics can cause cancer in animals; some are suspected
or known to cause cancer in humans. Key signs or symptoms associated with exposure to VOCs include conjunctival
irritation, nose and throat discomfort, headache, allergic skin reaction, dyspnea, declines in serum cholinesterase levels,
nausea, emesis, epistaxis, fatigue, dizziness." (32)

One example of the danger of volatile compound volatilization,  according to EPA documents, is  the chemical
Acetonitrile. . "Acetonitrile is metabolized in the body to hydrogen cyanide and thiocyanate; these chemicals are thought
to be responsible for the adverse effects of acetonitrile."

"Acetonitrile has been detected in air near ground levels, ranging from 2 to 7 ppb in both urban and rural areas (HSDB
1994)."

"Acetonitrile liquid or vapor is irritating to the skin, eyes, and respiratory tract. At high enough doses, death can occur
quickly from respiratory failure. Lower doses cause typical symptoms of cyanide poisoning such as salivation, nausea,
vomiting, anxiety, confusion, hyperpnea, dyspnea, rapid pulse, unconsciousness, and convulsions."

According to EPA documents, "Acetonitrile is expected to adsorb weakly to soils as predicted by its KOC value; removal
occurs primarily by volatilization and leaching into groundwater (HSDB 1994)"

There was 32.3 million pounds produced in the United States in 1992. Secondary uses are "as a chemical intermediate
in pesticide manufacturing; and as a solvent for both inorganic and organic compounds" It is also used in
pharmaceuticals, perfumes, and nitrile rubber. (8)

EPA gave the potential health effects for cyanide, but not thiocynate.

Thiocyanate -- WARNING! HARMFUL IF SWALLOWED OR INHALED. CAUSES IRRITATION TO SKIN, EYES AND
RESPIRATORY TRACT.  
Hazadous!
Potential Health Effects
----------------------------------
Inhalation:
Causes irritation to the respiratory tract. Symptoms may include coughing, shortness of breath.
Ingestion:
May cause psychosis, vomiting, disorientation, weakness, low blood pressure, convulsions and death which may be
delayed. The probable lethal dose is between 15-30 grams.
Skin Contact:
Causes irritation to skin. Symptoms include redness, itching, and pain.
Eye Contact:
Causes irritation, redness, and pain.
Chronic Exposure:
Prolonged or repeated skin exposure may cause dermatitis. Repeated ingestion of small amounts may cause weakness,
confusion, central nervous system effects, nausea and skin eruptions. (17)

IRRITANTS

As early as 1981 researchers have been aware of airborne Irritants in sludge. J. R. Nethercott in his article "Airborne
Irritant Contact Dermatitis due to Sewage "Sludge", 1981, reported how an airborne irrritant in sewage sludge caused an
outbreak of cases of dermatitis among incinerator workers employed in a sewage treatment facility. The cause of the
problem was traced to contamination of the workplace and workers' clothing by sludge from the interstices of an
incinerator exhaust fan.  Tests on rabbits confirmed the irritancy of the sludge. (16)

In 1996 EPA microbiologist David Lewis,  did get authority to investigate anecdotal reports alleging illness and deaths
from exposure to sewage sludge. Forty-eight individuals at 10 sites in Alabama, California, Florida,  New Hampshire,
Ohio, Pennsylvania, Texas and Ontario, Canada, were surveyed.

In Congressional testimony on February 4, 2004. Lewis explained the studies, "As part of my official EPA duties from
1996-2003, I researched the growing number of anecdotal reports alleging illnesses and deaths from exposure to
sewage sludge applied under EPA's guidance.  To do this, I surveyed the affected individuals, obtained their medical
records, collaborated with some of their treating physicians, gathered local government records on land application, and
analyzed environmental samples and other relevant information."

He added, "Based on these studies, I wrote a research paper co-authored with several University of Georgia scientists
and one of the physicians treating children exposed to sewage sludge. We concluded that the nature and timing of
these illnesses suggested that chemical irritants in sludge dusts, which irritated the skin, mucous membranes, sinuses,
and respiratory tract, rendered people susceptible to infection. This was the first study linking illness to land applied
sewage sludge and it revealed an important exposure pathway -  airborne dusts - which EPA had overlooked." (45)

In the 2002, David L. Lewis, et al., published the results of the studies as,
Interactions of pathogens and irritant
chemicals in land-applied sewage sludges (biosolids)
,where they found, "Affected residents lived within approximately 1
km of land application sites and generally complained of irritation (e.g., skin rashes and burning of the eyes, throat, and
lungs) after exposure to winds blowing from treated fields. A prevalence of Staphylococcus aureus infections of the skin
and respiratory tract was found. Approximately 1 in 4 of 54 individuals were infected, including 2 mortalities
(septicaemia, pneumonia).."

The primary complaints (a fourth or more reporting the symptom) within 1 h of exposure were coughing (63%, 8 sites),
burning throat (56%, 10 sites), burning eyes (56%, 9 sites), and headaches (46%, 6 sites). Within 24 h, residents
developed nasal and chest congestion (77%, 7 sites), difficulty in breathing (71%, 8 sites), nausea/vomiting (46%, 7
sites), fatigue (33%, 7 sites), and flu-like symptoms (29%, 5 sites). In some cases, symptoms of chemical irritation (e.g.,
burning eyes, burning throat) recurred for over a year after applications ceased.

These scientists from the US Environmental Protection Agency, National Exposure Research Laboratory, Athens, GA,  
Departments of Marine Sciences University of Georgia, Athens, GA, Biological & Agricultural Engineering University of
Georgia, Athens, GA, Medical Microbiology University of Georgia, Athens, GA, and Prime Care of Sun City, Menifee, CA,
stated, "Further research is needed to address illnesses among residents exposed to Class B biosolids, especially
airborne dusts [particles], and the role irritant chemicals may play in risks posed by low levels of pathogens." (6)

Lewis et al., in their study confirms that people living near sludge application sites suffer adverse health effects from
airborne contaminants. People, especially children, are also suffering from the same adverse effects from airborne
pollutants from their nearness to composting and pelletizing plants.

In a South Bronx community in New York City, the faculty and children of P.S. 48 experienced headaches, sore throats,
nausea, sinus congestion, runny eyes, nosebleeds, tight chests and asthma. More than a quarter of the 1100 students
had asthma and were frequently hospitalized. Forty-seven percent of one first grade class had asthma and thirty-three
percent had been hospitalized. The school is located five blocks from a pelletization plant which processes New York
City sludge into Class A sludge fertilizer. A terrible stench emanated from the plant causing nausea and upset stomachs.

Within fifteen yards of the school, uncovered trucks transported foul-smelling sludge (containing live disease causing
organisms, toxic organic chemicals and toxic heavy metals) from the treatment plants to the pelletization plant everyday.
When the appalling situation of the children and faculty in the South Bronx Senator Serrano he called on the EPA to
investigate.

According to Ms. X, the teacher from the South Bronx, who ask not to be named because she had already suffered a
demotion for trying to get help for the suffering children, the EPA's response was contemptible. She related the
unconsciousable behavior of the EPA who was sent to investigate the situation there. She said that it was obvious from
the beginning that EPA wasn't there out of genuine concern for the health of the children, but to point the finger of
blame away from the pelletizing plant, who just happened to be one of the stakeholders in EPA/WEF
biosolids promotion plan.

Using the "blame the victim tactic" they said the cause of all the adverse health effects the children were suffering was
from rat feces and cockroach feces found in their own homes. Ms. X said what they did next was despicable. They had
devised a questionnaire that the children were given at school to take home for their parents to fill out. In this
questionnaire the parents were asked if there dwellings were rat-infested and cockroach-infested. She said this is a
poor section--there probably isn't a dwelling in the whole area that isn't rat-infested or cochroach-infested.

To entice the children to make sure their parents would fill out the questionnaire, with the rat and cockroach infestation
questions, that would substantiate their findings that the cause was rat feces and cockroach feces, they were to receive
a free t-shirt. Whatsmore any teacher who had a 100 percent return rate received $100. This agency in their role as a
promoter of biosolids (sludge) would go to any lengths--even bribing little children--to protect one of their polluting
partners. (38)

There was one thing wrong with EPA's findings. They ignored the faculty who also exhibited some of the same symptoms
as the children. According to the New York Post article of February 13, 1996, the Jewish teachers in the school, who live
in the suburbs, are suffering from asthma and respiratory problems too. Evidently EPA in their investigation purposefully
ignored the report of the tests run at PS 48 in the South Bronx prepared for the American Journal syndicated TV show
aired, on February 28, 1996, which documented air pollution in the school.

The preliminary screening report on the indoor air quality of the school was prepared by Environmental  Medicine and
Engineering of Phoenix, Arizona. When EME examined the elements in the dust samples there, they found the
particulate (average inside air in particles per cubic foot of air) was very high:

Particulate size 0.5 micron level was 187,880. The recommended level was 30,000--6.26 times higher than
recommended level!

Particulate size 5.0 micron level was 8,366. The recommended level was 1200--6.9 times higher than recommended
level!

Eleven heavy metals in the dust samples exceeded the recommended values.
Lead (Pb) was 30.5 times higher than recommended,
Cadmium (Cd) was 24 times higher,
Nickel (Ni) was 9.2 times higher,
Cobalt (Co) was 1.7 times higher,
Zinc (Zn) was 1150 times higher,
Arsenic (Ar) was 2.5 times higher,
Iron (FE) was 4.1 times higher,
Selenium was 4.3 times higher,
Beryllium (Br) was 4.6 times higher,
Barium

(Ba) was 43.3 times higher, and
Copper (Cu) was 8.8 times higher.

When the symptoms that these various metals are capable of causing, which were referenced in Heavy Metals and
Potential Health Effects from U.S. Dept. of Health and Human Services National Institute for Occupational Safety and
Health of June 1990, were compared with the actual symptoms exhibited by the children at PS 48 there was a definite
correlation between the two.

Respiratory symptoms

Cadmium causes pulmonary edema {an abnormal accumulation of fluid in the lungs, resulting in swelling} and dyspnea
{shortness of breath}.

Barium causes upper respiratory irritation.

Cobalt decreases pulmonary function.

Beryllium affects the respiratory system.

Titanium Dust causes a slight lung fibrosis.

Nosebleeds

Arsenic causes ulceration of nasal septum.

Copper causes irritation of the nasal mucus membrane.

Selenium and Zinc cause irritation of the nose.

Burning Eyes

Selenium causes irritation of the eyes as does Vanadium dust and Conjunctivitis (inflammation of the membrane of the
eyelids}

Coughing

Cobalt causes coughing as does Zinc. Zinc also cause copius sputum.

Sore Throats

Selenium and Zinc both cause irritation of the throat.

Weakness

Lead and Beryllium cause weakness and fatigue.

The report states that "EPA identified five agents in contaminated dust that are carcinogenic when inhaled (Arsenic,
Beryllium, Cadmium, Chromium, and Nickel (FR 54-Page 5777)." (39)

LEAD

In spite of their knowledge about the adverse effects of exposure to lead,  EPA allows 840 ppm of lead in sludge to be
sprayed into the air with a total disposal land load of 300 kilograms per hectare. If sludge is not involved, the
cleanup
level for a home lawn with a young child is 400 ppm.

EPA facts:
  • FACT: Lead exposure can harm young children and babies even before they are born.
  • FACT: Even children who seem healthy can have high levels of lead in their bodies.
  • FACT: You can get lead in your body by breathing or swallowing lead dust, or by eating soil or paint chips
    containing lead.

Health Effects of Lead

*Childhood lead poisoning remains a major environmental health problem in the U.S..*
*Even children who appear healthy can have dangerous levels of lead in their bodies.*
Children's blood lead levels tend to increase rapidly from 6 to 12 months of age, and tend to peak at 18 to 24 months of
age.
People can get lead in their body if they:
Put their hands or other objects covered with lead dust in their mouths.
Eat paint chips or soil that contains lead.
Breathe in lead dust (especially during renovations that disturb painted surfaces).

Lead is even more dangerous to children than adults because:
Babies and young children often put their hands and other objects in their mouths. These objects can have lead dust on
them.
Children's growing bodies absorb more lead.
Children's brains and nervous systems are more sensitive to the damaging effects of lead.

If not detected early, children with high levels of lead in their bodies can suffer from:
Damage to the brain and nervous system
Behavior and learning problems (such as hyperactivity)
Slowed growth
Hearing problems
Headaches

In soil around a home. (Soil can pick up lead from exterior paint, or other sources such as past use of leaded gas in
cars.) [and sludge/biosolids] Household dust. (Dust can pick up lead from deteriorating lead-based paint or from soil
tracked into a home.) The job. If you work with lead, you could bring it home on your hands or clothes. Shower and
change clothes before coming home. Launder your work clothes separately from the rest of your family's clothes
[Lead in sludge is a dust when dry] Lead dust can form when lead-based paint is dry scraped, dry sanded, or heated.
Dust also forms when painted surfaces bump or rub together. Lead chips and dust can get on surfaces and objects that
people touch. Settled lead dust can re-enter the air when people vacuum, sweep, or walk through it. Lead in soil can be
a hazard when children play in bare soil or when people bring soil into the house on their shoes.

Contact the National Lead Information Center (NLIC) to find out about testing soil for lead.

Clean or remove shoes before entering your home to avoid tracking in lead from soil.
A risk assessment tells you if there are any sources of serious lead exposure (such as peeling paint and lead dust). It
also tells you what actions to take to address these hazards. Have qualified professionals do the work. There are
standards in place for certifying lead-based paint professionals to ensure the work is done safely, reliably, and
effectively.

To permanently remove lead hazards, you must hire a certified lead "abatement" contractor. Abatement (or permanent
hazard elimination) methods include removing, sealing, or enclosing lead-based paint with special materials. Just
painting over the hazard with regular paint is not enough. Always hire a person with special training for correcting lead
problems--someone who knows how to do this work safely and has the proper equipment to clean up thoroughly.
Certified contractors will employ qualified workers and follow strict safety rules set by their state or the federal
government.

Contact the National Lead Information Center(NLIC) for help with locating certified contractors in your area
and to see if financial assistance is available.

Exposure to lead is so harmful to children and adults that, Federal law requires that individuals receive certain
information before renting or buying a pre-1978 housing:
Residential Lead-Based Paint Disclosure Program

LANDLORDS have to disclose known information on lead-based paint and lead-based paint hazards before leases take
effect. Leases must include a disclosure form about lead-based paint.

SELLERS have to disclose known information on lead-based paint and lead-based paint hazards before selling a house.
Sales contracts must include a disclosure form about lead-based paint. Buyers have up to 10 days to check for lead
hazards.

Also, Federal law requires that contractors provide lead information to residents before renovating a pre-1978 housing:
Pre-Renovation Education Program (PRE)

RENOVATORS have to give you a pamphlet titled "Protect Your Family from Lead in Your Home", before starting work.
(36)

Not only does EPA know how harmful lead dust can be to human health, but lead in the soil not caused by sludge must
be cleaned up by the polluter when the lead in soil is above 400 ppm where young children live.

In fact, EPA stated,  "Protecting the children in Herculaneum, Missouri is a top priority for the U.S. Environmental
Protection Agency"

The order directs Doe Run to:
#  Clean up homes, within 30 days, of  children six years old and younger who have elevated blood lead levels. As new
homes are identified, Doe Run will clean up these homes within 30 days

Clean up all homes, within four months, where lead in the soil is above 400 parts per million (ppm) and children six years
old and younger live at the home

Clean up homes, parks, playgrounds, and schools, within six months, where lead in the soil is above 10,000 ppm

Clean up homes, parks, playgrounds, and schools, within one year, where lead in the soils is between 2,500 and 10,000
ppm

Clean up the interior of the homes within 20 days of the yard cleanup completions

Health Information

The Agency for Toxic Substances and Disease Registry and the Missouri Department of Health and Senior Services
continue to work very closely with EPA and MNDR.

We encourage you to have your child tested for lead exposure. Please contact your private physician or the Jefferson
County Health Department at 636-789-3372 to have your child tested

We advise you to continue to take the following actions to reduce your and your children's exposure to lead. It is
advisable to take the following actions:
# Have children play on solid grass cover in yards or parks.
# Remove shoes before entering your home.
# Do not allow children to play in the street or on the curbs.
# Encourage children not to put their hands in their mouths.
# Encourage frequent hand and face washing before eating, drinking and sleeping. (37)

In a letter addressing  Mr. Doug Olson's sludge complaint against a compost site in California, Tracy Barreau, REHS,
Senior Environmental Scientist, with the California Environmental Health Investigations Branch, admitted Olson could be
in a hazardous environment -- but -- there were no standards that applied to this situation and it would probably take
several years to answer questions about the safety of sludge.

Barreau said, "In studies discussing potential exposure to pathogen-contaminated dust and runoff water from land-
applied biosolids and composting (biosolids and green/yard waste), the health concerns reported by the adjacent
communities show similar patterns (NRC 2002, Herr 2002). Symptoms commonly reported include respiratory infections,
skin rashes, burning eyes, burning lungs, difficulty breathing, and gastrointestinal effects. These effects can be more
severe in immunocompromised individuals, individuals with chronic disease, and other sensitive populations. Similar
health effects have been observed in workers at composting and sewage treatment facilities. In some studies, workers
have been shown to have higher rates of airway mucous membrane complaints, respiratory inflammation, skin rashes,
and diseases involving immunological hypersensitivity reactions (Gattie 2004, Herr 2002). In a cross-sectional study,
researchers investigated effects of bioaerosol (organic dusts - mixtures of air and microorganisms) polluted outdoor on
airways of residents living next to a composting facility in Germany. Researchers compared self-reported health
complaints to measurable bioaerosol pollution in residential outdoor air. The microorganisms measured in the study
included, total bacteria, molds, thermophilic and thermotolerant actinomycetes. The study found detectable levels of
bioaerosol pollution at a distance of 550 meters (maximum distance sampled in study), with the highest levels measured
closest to the site. All exposure groups, including residents living the furthest away from the site (> 400-500 meters /
~1/3 mile) reported higher rates of health complaints compared to the unexposed controls. Researchers concluded,
"this bioaerosol exposure in turn could be associated, as far as concentrations of bioaerosols and duration of exposure
were concerned, with symptoms suggestive of airway inflammation also reported in respective workplaces" (Herr 2002)."

With all the state and federal laws enacted to protect public health and the environment, Barreau said, "Rule
503 was implemented without an evaluation of the health risks from exposure to pathogens" and "There are no health-
based standards that directly apply to this situation."

Moreover, Barreau passed the buck when he said,  "DHS plans to make further inquiry with the various agencies (city,
county, state, and federal), along with experts in the field, to explore ways in addressing public health concerns around
this issue. As acknowledged by the NRC, the USEPA, and other experts in the field, many uncertainties need to be
addressed in understanding the full range of public health issues associated with land application and composting of
biosolids. We recognize that it may take years to answer these important questions." (12)


EPA and the states recognize that aerosols of dust disease causing organisms, toxic chemicals and metals off sludge
sites are harmful to human health and the environment. Yet, rather than protect human health and the environment --
air, water and land on which life depend, we get bioaerosols studies that claim that risks are low for residents living near
these sites..

Two studies are of interest. In a presentation at the NATIONAL BIOSOLIDS WORKSHOP,(120)  University of Arizona
professor Ian Pepper noted in,
"STUDIES ON BIOAEROSOLS FROM LAND APPLIED BIOSOLIDS
• Overall very little information available"

In their 2005 study,  A national study on the residential impact of biological aerosols from the land application of
biosolids
, (130) Pepper and Gerba claim et al.,, " The purpose of this study was to evaluate the community risk of
infection from bioaerosols to residents living near biosolids land application sites." "Samples were collected for a total of
20 min or c. 250 l of sampled air."'All samples were heat shocked at 70C for 20 min prior to sample analysis."

They claim, "This study evaluated the overall incidence of aerosolized microorganisms from the land application of
biosolids and subsequently determined that microbial risks of infection were low for residents close to biosolids
application sites."

Yet, they noted several limitations which invalidated the claim for determining risk of infection was low when they stated ,
"As aerosol samples were collected during 20-min sampling periods, it is conceivable that during this
sampling period, high concentrations of aerosolized coliforms or coliphage may have been missed.".

Furthermore, they warned, "It is noteworthy to state that this study does not take into account other
pathogenic bacteria present in biosolids and
assumes that the greatest risk would be from a pathogenic
bacterial genus (Salmonella) that is more prevalent in biosolids."

As a final warning, they state, "The use of coliphage as an indicator of enteric viruses present in biosolids is a source of
uncertainty, as to date there is no study showing this relationship exists, however to date an approved indicator for
enteric viruses in biosolids is still lacking. As such, the same can be said regarding aerosolized enteric viruses and
aerosolized coliphage from biosolids land application"

In another presentation critical of the  National Academy of Science titled,
REVIEW OF NAS REPORT, (122) Biosolids
Applied to Land:
Advancing Standards and Practices.,  professor Pepper said,
"• Facts not fiction should be presented"               
"•
Facts should be based on scientific studies"       
"• Academics should conduct research in the needed areas of interest with respect to land
application of biosolids"

CONCLUSION

In 2005,  EPA listed bioaerosols as one of the major concerns. Our research on bioaerosols confirms that  they should
be a major priority as they are one of the main paths of exposure to the pollutants in sludge/biosolids.

There has always been enough scientific studies done that show there is a danger to the public from inhalation of
viruses, bacteria, fugus and dust off of sludge sites and from composting.

In spite of the all the evidence, EPA still promotes sludge/biosolids at the expense of public health and the environment
-- air, water, and land we depend on to survive.