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)

In the 1993 Preamble to the final Part 503 sludge rule EPA claimed many carcinogens were not regulated because
of a lack of data.

Carcinogens in sludge

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-


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

National Toxicology Program
Pursuant to Section 301(b) (4) of the Public Health Service Act as Amended by Section 262, PL 95-622

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.