Chromium which was removed from the beneficial sludge/biosolids use section of part 503. EPA has no limits for
restrictions on the amount of chromium in sludge/biosolids sprayed  on farmland or use as a soil amendment.
According to a 1991-93 Canadian Government study (8/97), "Airborne Hexavalent Chromium in Southwestern Ontario",
approximately 20% of the routinely monitored ambient airborne chromium (Cr) was in the hexavalent form." In addition,
the range of carcinogenic health risks attributed to airborne Cr(vi) was determined to be between 1.4 (in 100,000) and
3.0 (in 10,000) for people living in the Winsor area." For people spending all of their time outdoors the range increased
to between 3.6 in 100,000 and 5.5 in 10,000. This estimate was based on potency factors developed by our own EPA,
the California Department of Health Services and the World Health Organization. [23]

If there is that much airborne hexavalent chromium in the air in Canada and it is that dangerous, how much could we
have in our cities or volatilizing off  large sludge farm dumpsites? What are these "expert" sludge scientists doing to us?
Apparently they have never done any basic research or they would have found that hexavalent chromium (Cr-VI) is
almost exclusively man made. Natural occurring chromium is in the trivalent (Cr-III) form.

Hexavalent chromium has been found in glue, cement, detergents and other materials including chromite ore. It is/was
used in the chrome plating, corrosion inhibitors, dye, graphic art supplies, fungicides, lithography solutions, paper
matches, paint pigment manufacturing, wood preservation and the leather industry.

Hexavalent chromium is produced by three methods, high-lime, low-lime, and lime-free processes. In 1975, most of the
chromite ore came from the Republic of South Africa, Southern Rhodesia, and the USSR. No chromite ore has been
mined in the United States since 1961.

EPA has suggested that the sewage treatment process changes the carcinogenic nature of hexavalent chromium-VI
used in the leather industry to the non-carcinogenic form chromium-III. The literature suggests that chromium-VI at low
pH (less than 4) can oxidize water to oxygen thereby resulting in chromium-III. However, the literature also suggest that
above ph 4, chromium-III will be oxidized by oxygen into Chromium-VI. Cropland must be maintained at a pH of 6-7 to
prevent other toxic metals from being taken up by plants. In effect, all metals and particularly, chromium compounds are
very sensitive to pH balance and the oxidization process would appear to become extremely effective in transforming
natural occurring chromium-III from the soil into Chromium-VI when the pH is raised to 11 or 12.

Adding lime during the waste treatment process to create Class A sludge raises the pH to 11 or 12. It is used to control
odors and is one of the recommended methods of treating sludge to reduce pathogens--- sludge is mixed with lime, and
the pH is raised above 12, where it must remain for at least 72 hours. In effect, it would appear the EPA's Class A
treatment process is at a minimum reactivating the chromium-VI compounds. As we saw from the Canadian study,
chromium may be one of the most dangerous long-term elements in the sludge products EPA is promoting for
uncontrolled distribution to the public.

According to the New Jersey Department of Health and AQUIRE Database, ERL-Duluth, U.S.EPA, chromium is a cancer
causing agent and a mutagen. "It has been shown to cause lung and throat cancer." Under the New Jersey Department
of Health Right to Know Program, "Chromium (III) and chromium (VI) both have high chronic toxicity to aquatic life; no
data are available on the long-term effects of chromium to plants, birds, or land animals." According to the report, "Some
substances increase in concentration, or bioacummulate in living organisms as they breath contaminated air, drink
contaminated water or eat contaminated food. These chemicals can become concentrated in the tissues and internal
organs of animals and humans."

The report notes that, "Acute (short-term) toxic effects [which are seen two to four days after animals or plants come in
contact] may include the death of animals, birds, or fish, and death or low growth rate in plants." "...chronic (long term)
health effects can occur at some time after exposure to chromium and can last for months or years." "Chronic toxic
effects may include shortened lifespan, reproductive problems, lower fertility and changes in appearance or

"REASON FOR (New Jersey's) CITATION of chromium in the Right to Know Program:

* It is on the (EPA) Hazardous Substance List because it is regulated by OSHA and sited by ACGIH, NTP and ARC.

* This chemical is also on the Special Health Hazard Substance List because it is a CANCER CAUSING AGENT and a

* Chromium is a CANCER CAUSING AGENT in humans. There may be no safe level of exposure to a carcinogen, so all
contact should be reduced to the lowest possible level.

The National Institute on Occupational Safety and Health (NIOSH) lists Chromium as a poison. It is also on the "Special
Health Hazard Substance list, as well as #15 and #72 on the 1995 CERCLA/EPA Priority List of Hazardous substances
found in landfills.

NIOSH first recommended standards for Occupational Exposure to Chromium (VI) in 1975. It was so concerned about
the medical and carcinogenic dangers that "Preplacement X-ray and X-rays for the 5 years preceding termination of
employment and all medical records with pertinent supporting documents shall be retained at least 30 years after the
individual's employment is terminated."

Although government regulatory agencies (e.g., OSHA, ACGIH, EPA) recognize that chromium is very dangerous in the
workplace at 8 hour exposure levels, EPA claims farmers and neighbors can't be hurt when they are exposed 24 hours a
day. As an example:

OSHA: The legal airborne permissible exposure limit (PEL) is 1 mg/m3 averaged over an 8 hour work shift. [That is 1
ppm per cubic meter of air]

ACGIH: The recommended airborne exposure limit is 0.5 mg/m3 averaged over an 8 hour workshift. [That is 1/2 ppm per
cubic meter of air]

1.5 How can chromium affect my health?        
The health effects resulting from exposure to chromium(III) and chromium(VI) are fairly well described in the literature. In
general, chromium(VI) is more toxic than chromium(III). Breathing in high levels (greater than 2 µg/m³) chromium(VI),
such as in a compound known as chromic acid or chromium(VI) trioxide, can cause irritation to the nose, such as runny
nose, sneezing, itching, nosebleeds, ulcers, and holes in the nasal septum. These effects have primarily occurred in
factory workers who make or use chromium(VI) for several months to many years.

Long-term exposure to chromium has been associated with lung cancer in workers exposed to levels in air that were 100
to 1,000 times higher than those found in the natural environment. Lung cancer may occur long after exposure to
chromium has ended. Chromium(VI) is believed to be primarily responsible for the increased lung cancer rates observed
in workers who were exposed to high levels of chromium in workroom air. Breathing in small amounts of chromium(VI) for
short or long periods does not cause a problem in most people.

However, high levels of chromium in the workplace have caused asthma attacks in people who are allergic to chromium.
Breathing in chromium(III) does not cause irritation to the nose or mouth in most people. In the same way, small amounts
of chromium(VI) that you swallow will not hurt you; however, accidental or intentional swallowing of larger amounts has
caused stomach upsets and ulcers, convulsions, kidney and liver damage, and even death. The levels of chromium(VI)
that caused these effects were far greater than those that you might be exposed to in food or water. Although
chromium(III) in small amounts is a nutrient needed by the body, swallowing large amounts of chromium(III) may cause
health problems. Workers handling liquids or solids that have chromium(VI) in them have developed skin ulcers. Some
people have been found to be extremely sensitive to chromium(VI) or chromium(III).

Allergic reactions consisting of severe redness and swelling of the skin have been noted. Exposure to chromium(III) is
less likely than exposure to chromium(VI) to cause skin rashes in chromium-sensitive people. The metal, chromium(0), is
less common and does not occur naturally. We do not know much about how it affects your health, but chromium(0) is
not currently believed to cause a serious health risk.

We have no reliable information that any form of chromium has harmful effects on reproduction or causes birth defects
in humans, though it does not seem likely that the amount of chromium that most people are exposed to will result in
reproductive or developmental effects. In animals that breathed high levels of chromium, harmful effects on the
respiratory system and a lower ability to fight disease were noted. However, we do not know if chromium can lower a
person's ability to fight disease. Some of the female mice that were given chromium(VI) by mouth had fewer offspring
and had offspring with birth defects. Some male mice that were given chromium(VI) or chromium(III) by mouth had
decreased numbers of sperm in the testes. The birth defects or the decrease in sperm occurred in mice at levels about
several thousand times higher than the normal daily intake by humans. Some chromium(VI) compounds produced lung
cancer in animals that breathed in the particles or had the particles placed directly in their lungs. In animals that were
injected with some chromium(VI) compounds, tumors formed at the site of injection.

Because some chromium(VI) compounds have been associated with lung cancer in workers and caused cancer in
animals, the Department of Health and Human Services has determined that certain chromium(VI) compounds (calcium
chromate, chromium trioxide, lead chromate, strontium chromate, and zinc chromate) are known human carcinogens.
The International Agency for Research on Cancer (IARC) has determined that chromium(VI) is carcinogenic to humans,
based on sufficient evidence in humans for the carcinogenicity of chromium(VI) compounds as found in chromate
production, chromate pigment production, and chromium plating industries. IARC's determination is also based on
sufficient evidence in experimental animals for the carcinogenicity of calcium chromate, zinc chromate, strontium
chromate, and lead chromate; and limited evidence in experimental animals for the carcinogenicity of chromium trioxide
(chromic acid) and sodium dichromate. IARC has also determined that chromium(0) and chromium(III) compounds are
not classifiable as to their carcinogenicity to humans.

The EPA has determined that chromium(VI) in air is a human carcinogen. The EPA has also determined that there is
insufficient information to determine whether chromium(VI) in water or food and chromium(III) are human carcinogens