CURRENT National Toxicology Program LIST OF HUMAN CARCINOGENS ADDED 3/25/2006
While it is true that some forms of the metals in sludge may not be carcinogens, most are and we really have no idea of what is in sludge. The survival and regrowth of carcinogenic pathogens in Class A are another concern. Note below, that most Class A sludge couldn't be placed within 150 meters of the boundary of a permitted part 503 surface disposal site.
Virtually, every environmental law, and 503 ,states that if you are exposed to the organic chemicals (some are metals), inorganic chemicals (metals) or pathogens through the air, food chain or water, their is a high risk of death, disease or cancer. They also state the EPA Administrator has the documents on file to prove the point.
Proposed part 503 (1989) EPA has admitted (1989) there are at least twenty-one carcinogens (cancer causing agents) in sludge which were removed from the final 503. (Federal Register 54,p. 5777).
EPA has admitted (1989) that five of the admitted twenty-one carcinogens in sludge are carcinogenic when inhaled in dust -- Arsenic, Beryllium, Cadmium, Chromium IV and Nickel. (Federal Register 54, p. 5777)
Arsenic (NIOSH CC 4025000) by inhalation or ingestion-carcinogen-mutagenic data. Cadmium (NIOSH EU 9800000) by inhalation and other routes-carcinogen-mutagenic data. Chromium (NIOSH GB 4200005) by inhalation and other routes-carcinogen-mutagenic data. Copper (NIOSH GL 5325000) by ingestion and other routes-carcinogen-mutagenic data. Lead (NIOSH OF 7525000) by ingestion and other routes-carcinogen-mutagenic data. Mercury (NIOSH OV 4550000) by inhalation and other routes-carcinogen-mutagenic data. Molybdenum (NIOSH QA 4680000) by inhalation, ingestion and other routes. Nickel (NIOSH QR 5950000) by inhalation, ingestion and other routes-carcinogen-mutagenic data. Selenium (NIOSH US 7700000) by inhalation and other unknown routes-carcinogen (causes blind staggers in cattle). Zinc (NIOSH ZG 8600000) by ingestion and other routes-carcinogen.
Agents that cause cancer or increase the risk of cancer either by initiating or promoting it, are called carcinogens. Carcinogens can enter the body through the skin, lungs, or the digestive system and act directly or indirectly to cause cancer. Direct acting carcinogens usually cause cancer at the site of exposure, for example, skin contact with coke oven emissions may cause skin cancer. Indirect acting carcinogens are changed by the body into carcinogenic substances that cause cancer at sites other than the initial exposure site. Benzidine, for example, entering the body through the skin does not cause skin cancer. Instead it is transformed to a reactive species in the body and eliminated in the urine causing bladder cancer. Other substances, called promoters, do not cause cancer themselves but are necessary for some chemicals to express their carcinogenicity.
Table 2 of § 503.23_Pollutant Concentrations_Active Sewage Sludge Unit Without a Liner and Leachate Collection System That Has a Unit Boundary to Property Line Distance Less Than 150 Meters ------------------------------------------------------------------------ Unit boundary to property line Pollutant concentration 1 ------------------------------------------------------------------------ Arsenic Chromium Nickel Distance (meters) (mg/kg) (mg/kg) (mg/kg) ------------------------------------------------------------------------ 0 to less than 25........................ 30 200 210 25 to less than 50....................... 34 220 240 50 to less than 75....................... 39 260 270 75 to less than 100...................... 46 300 320 100 to less than 125..................... 53 360 390 125 to less than 150..................... 62 450 420 ------------------------------------------------------------------------
Report on Carcinogens, Eleventh Edition; U.S. Department of Health and Human Services, Public Health Service, National Toxicology Program .
Carcinogens Listed in the Eleventh Report Part A. Known to be Human Carcinogens.
Name or synonym Page No. III Aflatoxins 8 Alcoholic Beverage Consumption 10 4-Aminobiphenyl 13 Analgesic Mixtures Containing Phenacetin (See Phenacetin and Analgesic Mixtures Containing Phenacetin) 212 Arsenic Compounds, Inorganic 18 Asbestos 21 Azathioprine 25 Benzene 26 Benzidine (See Benzidine and Dyes Metabolized to Benzidine) 28 Beryllium and Beryllium Compounds 32 1,3-Butadiene 37 1,4-Butanediol Dimethanesulfonate (Myleran®) 39 Cadmium and Cadmium Compounds 42 Chlorambucil 47 1-(2-Chloroethyl)-3-(4-methylcyclohexyl)-1-nitrosourea (MeCCNU) 53 bis(Chloromethyl) Ether and Technical-Grade Chloromethyl Methyl Ether 56 Chromium Hexavalent Compounds 63 Coal Tar Pitches (See Coal Tars and Coal Tar Pitches) 68 Coal Tars (See Coal Tars and Coal Tar Pitches) 68 Coke Oven Emissions 71 Cyclophosphamide 74 Cyclosporin A 75 Diethylstilbestrol 98 Dyes Metabolized to Benzidine (See Benzidine and Dyes Metabolized to Benzidine) 29 Environmental Tobacco Smoke (See Tobacco Related Exposures) 251 Erionite 114 Estrogens, Steroidal 115 Ethylene Oxide 118 Hepatitis B Virus 131 Hepatitis C Virus 133 Human Papillomas Viruses: Some Genital-Mucosal Types 142 Melphalan 164 Methoxsalen with Ultraviolet A Therapy (PUVA) 165 Mineral Oils (Untreated and Mildly Treated) 174 Mustard Gas 176 2-Naphthylamine 179 Neutrons (See Ionizing Radiation) 150 Nickel Compounds (See Nickel Compounds and Metallic Nickel) 181 Radon (See Ionizing Radiation) 152 Silica, Crystalline (Respirable Size) 231 Smokeless Tobacco (See Tobacco Related Exposures) 253 Solar Radiation (See Ultraviolet Radiation Related Exposures) 266 Soots 233 Strong Inorganic Acid Mists Containing Sulfuric Acid 234 Sunlamps or Sunbeds, Exposure to (See Ultraviolet Radiation Related Exposures) 266 Tamoxifen 239 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD); “Dioxin” 241 Thiotepa 249 Thorium Dioxide (See Ionizing Radiation) 154 Tobacco Smoking (See Tobacco Related Exposures) 255 Vinyl Chloride 272 Ultraviolet Radiation, Broad Spectrum UV Radiation (See Ultraviolet Radiation Related Exposures) 266 Wood Dust 276 X-Radiation and Gamma Radiation (See Ionizing Radiation) 147 Bold entries indicate new or changed listing in The Report on Carcinogens, Eleventh Edition.